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EU rules for the calculation and reporting of recycled content in single-use plastic bottles

Environment

This initiative will lay down common rules for the calculation, verification and reporting of recycled content in single-use plastic beverage bottles. This will give legal clarity to the recycling industry to do the right investments and help Member States to properly implement the Single Use Plastics legislation throughout the EU, thereby contributing to increase recycling and reduce plastic waste incineration and landfill.

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Public consultation

ID: 13467

Lobbying Activity

109 responses

Environmental groups demand stricter plastic recycling content rules

European Environmental Bureau, 14 Aug 2025

The organization demands that only post-consumer plastic waste count toward recycled content targets, excluding pre-consumer waste. They want the concept of dual-use outputs removed and segregation models prioritized over mass balance accounting. They also call for European sustainability criteria before accepting chemical recycling technologies.
This would support their goal of reducing virgin plastic production and advancing circular economy objectives.
Chemical recycling companies lose flexibility in claiming recycled content without strict sustainability criteria.

Consultation response

European Chemical Industry Council, 19 Aug 2025

Please find attached the contribution of the European Chemical Industry Council (CEFIC) into the stakeholder consultation for the Single Use Plastic Directive Implementing Act (SUPD IA). This contribution reflects the discussions and different positions of the Cefic members, who are engaged in…

Cefic calls for mandatory mass balance in EU recycling rules

European Chemical Industry Council, 30 May 2023

Cefic requests changing the rules to mandate a specific mass balance chain of custody model. This would ensure that chemical recycling is properly counted alongside other methods by late 2023.
The industry would benefit by repurposing existing industrial installations for circular processes.

Volkswagen urges flexible plastic recycling rules for the automotive sector

Volkswagen Aktiengesellschaft, 8 Aug 2025

VW requests a pragmatic mass balance approach avoiding mandatory physical segregation. They suggest these beverage rules should serve as a sectoral blueprint.
Flexible accounting reduces administrative burdens and helps meet upcoming quotas.
Environmentalists lose because mass balance permits blending recycled and virgin materials.

ClientEarth urges strict standards for reporting recycled plastic content

ClientEarth AISBL, 30 May 2023

ClientEarth calls for traceable chain of custody models while banning mass balance approaches that could mislead shoppers. They demand that all company data undergoes independent third-party verification to ensure reliability. Additionally, they advocate restricting the definition of recycled plastic to post-consumer waste only.
Stricter reporting rules would strengthen legal avenues to challenge deceptive green marketing claims.
Chemical recycling firms would lose the flexibility to allocate recycled content credits across different product lines.

BASF urges flexibility in mass balance rules for recycled plastics

BASF SE, 18 Aug 2025

BASF requests the EU allow all business models to participate in the mass balance approach, limit rules to verifiable certification without excessive bureaucracy, and revise the text before applying it to other legislation. They argue the current draft creates an uneven playing field by excluding established co-processing models.
This would protect their existing chemical recycling operations and avoid costly facility duplications.
Environmental groups lose stricter tracking of recycled content through production chains.

ExxonMobil Urges Flexible Rules for Chemical Recycling Credits

ExxonMobil Petroleum Chemical, 19 Aug 2025

ExxonMobil requests a flexible, technology-neutral mass balance framework to incentivize chemical recycling investments. They advocate for credit reallocation and simplified verification based on technical feasibility.
Flexible rules would secure the economic viability of ExxonMobil's major recycling infrastructure projects.
The European chemical industry loses competitiveness and resilience under the proposed restrictive regulations.

Eni Urges EU to Recognize Chemical Recycling in Plastic Rules

Eni S.p.A., 12 Aug 2025

Versalis asks for a broader definition of recycling technology to include outputs like recycled oil. They also propose allowing credit transfers between facilities and protecting confidential commercial information.
These changes would unlock investment in advanced recycling and lower logistical and transport costs.
European industry could lose competitiveness if imports avoid the same strict verification standards.

Food Industry Backs EU Rules on Recycled Plastic Reporting

FoodDrinkEurope, 13 Aug 2025

The organization requests adoption of the implementing act by Q4 2025 with current mass balance allocation rules including fuel use exemption. They seek allowance for annual facility-based reporting rather than batch-wise records and permission to transfer mass balance credits between facilities.
This would reduce compliance costs while enabling chemical recycling needed for food-safe packaging.

Neste warns EU plastic rules threaten chemical recycling investments

Neste Oyj, 19 Aug 2025

Neste urges the EU to include existing refineries in the chemical recycling chain. They call for a full impact assessment on industry competitiveness.
This would protect Neste's multimillion-euro investments and lower costs for the chemical recycling industry.
European industry faces reduced competitiveness and reliance on imports if investments move abroad.

Unilever urges EU to adopt flexible chemical recycling rules

Unilever, 18 Aug 2025

Unilever supports a technology-neutral approach where chemical recycling complements mechanical processes. They advocate for a mass balance system to handle materials unsuitable for mechanical recycling. The company also suggests digital reporting tools to reduce administrative burdens.
This provides an economically viable way for Unilever to meet food-grade packaging targets.
Mechanical recyclers could lose feedstock if chemical recycling plants compete for the same plastic waste.

Deutsche Umwelthilfe Rejects Chemical Recycling for Plastic Bottle Targets

Deutsche Umwelthilfe e.V., 19 Aug 2025

The organization firmly rejects chemical recycling for counting recycled content in single-use bottles. They argue that only post-consumer plastic waste should be eligible to meet targets. Regulatory rules must prioritize mechanical recycling instead of less efficient technological alternatives.
This protects existing mechanical recycling markets by preventing competition from the chemical industry.
Consumers lose transparency and risk being misled by products containing fewer recycled materials.

Germanwatch urges stricter rules for recycled plastic content

Germanwatch, 19 Aug 2025

Germanwatch argues recycled content targets must be limited to post-consumer plastic waste. They demand removing dual-use outputs and criticize the complex mass balance method.
The group would successfully uphold environmental standards and prevent the dilution of circular goals.
Fuel producers and chemical recyclers lose the ability to label non-plastic outputs as recycled.

SUEZ urges broader recycled plastic rules for beverage bottles

SUEZ Group, 30 May 2023

SUEZ requests including PET depolymerization and expanding the recycled plastic definition to include pre-consumer waste. They recommend integrating a precise chain of custody for depolymerization.
Providing a clear timeline and including new technologies ensures predictability for industry investors.
Innovative recycling firms lose out if the legislation focuses exclusively on mechanical processes.

VCI Urges Inclusive Rules for Chemical Recycling in Plastic Bottles

Verband der Chemischen Industrie e.V., 19 Aug 2025

The association demands that all chemical recycling technologies be recognized. They advocate for a mass balance method and allowing credit transfers between sites.
Utilizing existing refinery infrastructure would reduce investment costs and help companies meet circularity targets.
Foreign manufacturers would face stricter enforcement and penalties to prevent unfair competition with EU industry.

Seas At Risk Demands Stricter Rules for Plastic Recycling Content

Seas At Risk, 18 Aug 2025

The organization requests that recycled content targets only include post-consumer plastic waste as input, excluding pre-consumer waste even when mixed. They demand removal of dual-use output concepts and prioritization of segregation and controlled blending models for accounting. They call for European sustainability criteria on plastic recycling technologies before accepting chemical recycling.
This would prevent chemical recycling from counting toward targets without proven environmental benefits.
The chemical recycling industry loses ability to claim recycled content credits without guarantees.

Seas At Risk demands stricter tracking for recycled plastic content

Seas At Risk, 25 May 2023

Seas At Risk wants calculations based on total bottles sold, including those littered. They demand mandatory third-party certification for all operators to ensure chemical and physical traceability.
Stricter rules would verify environmental claims and protect the reputation of European recyclers.
Importers and low-standard manufacturers would lose the ability to use unverified recycling claims.

Danish food industry urges simplified plastic recycling reporting rules

Landbrug Fødevarer - Danish Agriculture and Food Council, 12 Aug 2025

The group proposes annual facility-level reporting instead of burdensome batch-wise records. They also advocate for transferring credits between facilities to improve operational flexibility.
Reducing record-keeping requirements would lower administrative burdens and overall compliance costs.

Danish Agriculture Council Urges Reduced Plastic Reporting Frequency

Landbrug Fødevarer - Danish Agriculture and Food Council, 30 May 2023

The council requests replacing annual reporting with single reports in 2025 and 2030. They also advocate for mass-balance principles and seek clarification on compliance for bottle components.
These changes would lower compliance costs and simplify cross-border transport of bottles.

Plastics Europe Urges Flexible Rules for Chemical Recycling Investment

Plastics Europe, 18 Aug 2025

The association calls for targeted changes to ensure rules are simple and technology-neutral. They advocate using these rules as a monitored test case before applying them to other legislation.
This would allow producers to use existing industrial assets to scale up recycling capacity efficiently.
Domestic producers face lost competitiveness if rules fail to address cheap imports from third countries.

CEOE urges broader recycling standards and faster implementation

CEOE - Confederación Española de Organizaciones Empresariales, 30 May 2023

CEOE requests that chemical recycling and mass balance accounting methods be officially recognized. They propose measuring recycled content as a producer-level average and excluding labels and sleeves from bottle definitions.
This would provide plastic manufacturers with greater technical flexibility and legal certainty.

Consultation response

Zero Waste Europe, 19 Aug 2025

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the Implementing Decision proposal for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles. This proposal will likely serve as a blueprint for future legislation introducing…

German conservation group warns plastic recycling rules favor polluting pyrolysis

Naturschutzbund Deutschland e.V., 14 Aug 2025

NABU requests that the EU require proportional allocation for pyrolysis-based recycling and remove the dual-use approach. They argue the current mass balance method lacks transparency and gives unfair advantages to environmentally harmful processes over mechanical recycling.
This would ensure mechanical recycling gets fair treatment and prevent greenwashing of inferior technologies.
Pyrolysis plant operators lose favorable allocation rules that let them claim recycled content artificially.

Zero Waste Europe Urges Strict Recycled Plastic Reporting Rules

Zero Waste Europe, 30 May 2023

The organization requests that recycling process losses be excluded from recycled content calculations. They also advocate for mandatory third-party certification and prioritizing models that ensure the highest traceability.
This would prevent misleading claims and ensure a level playing field for high-quality recycling.
Chemical recycling firms using pyrolysis would lose the ability to count process losses.

ECOS Warns EU Plastic Rules Risk Widespread Corporate Greenwashing

Environmental Coalition on Standards, 1 Aug 2025

The organization calls for replacing the complex fuel-exempt methodology with a proportional attribution system to ensure transparency. They demand that only post-consumer waste is counted to prevent rewarding inefficient production processes.
This would protect the credibility of environmental standards and ensure a fair market for recyclers.
Mechanical recycling businesses face unfair competition and potential job losses under the current proposal.

ECOS demands strict standards for recycled plastic bottle content

Environmental Coalition on Standards, 30 May 2023

ECOS demands that recycled content only includes post-consumer waste and excludes all recycling losses. They advocate for mandatory third-party audits to verify reporting and ensure market trust. The group also insists on proportional accounting methods to prevent misleading labels on products.
Stronger rules protect the credibility of recycled content claims and prevent greenwashing.
Inefficient recycling technologies lose the ability to use flexible accounting to claim targets.

Veolia Urges Stronger Traceability to Protect Mechanical Plastic Recycling

Veolia Environnement, 18 Aug 2025

Veolia requests legal priority for mechanical recycling based on environmental impact. They demand physical traceability to ensure consumers receive credible recycled content information.
This would protect Veolia's mechanical recycling investments from unfair competition and market volatility.
Consumers face a high risk of greenwashing through misleading allegations about plastic circularity.

EUROPEN urges legal clarity for chemical recycling in plastic bottles

The European Organisation for Packaging and the Environment, 18 Aug 2025

EUROPEN calls for legal recognition of chemical recycling and mass balance accounting to meet targets. They argue that rules should cover only bottle bodies, caps, and lids, excluding labels.
Flexible rules would lower compliance costs and simplify administration for packaging manufacturers.
Environmental groups lose as excluding labels reduces the total volume of required recycled plastic.

Repsol Urges Flexible EU Rules for Chemical Plastic Recycling

Repsol, S.A., 18 Aug 2025

Repsol seeks a broader recycling definition and a flexible credit-based accounting method. They want to use existing petrochemical infrastructure to process multiple waste streams.
Repsol would avoid expensive new investments by integrating recycling into its existing refineries.
Non-EU exporters would face tougher entry requirements under Repsol’s proposed enforcement framework.

EUROPEN urges exclusion of labels from recycled content rules

The European Organisation for Packaging and the Environment, 25 May 2023

EUROPEN requests that bottle definitions exclude labels to align with primary law. They also advocate for mass balance methods to support chemical recycling.
This would prevent companies from having to source extra recycled material to offset virgin labels.

Tyre industry urges EU to recognize chemical recycling methods

European Tyre & Rubber Manufacturers' Association, 19 Aug 2025

ETRMA requests the formal recognition of chemical recycling as a distinct process to recover high quality material. They advocate for extending the mass balance approach to other product groups such as tyres. The association also emphasizes the need for clear definitions and certification schemes for sustainable feedstocks.
This would help tyre manufacturers meet circularity targets by simplifying the use of recycled feedstocks.
Environmental interests may be harmed by reclassifying industrial incineration processes as recycling operations.

German environmental group BUND urges stricter plastic recycling standards

Bund für Umwelt und Naturschutz Deutschland e. V., 19 Aug 2025

BUND rejects the proposed mass balance model and demands that only post-consumer waste be labeled as recycled content. They call for strict, verifiable standards for imported materials to prevent market distortion and greenwashing.
Stricter rules would prioritize mechanical recycling and support the economic viability of European recyclers.
Consumers face increased risks of greenwashing due to unreliable environmental labels and low-quality imports.

BUND rejects mass balance for recycled plastic bottle content

Bund für Umwelt und Naturschutz Deutschland e. V., 30 May 2023

The organization criticizes mass balance accounting, arguing it threatens resource protection and consumer transparency. They demand legally binding norms based on actual physical material shares rather than mathematically assigned percentages. Furthermore, they insist that actual material losses during chemical recycling must be clearly disclosed.
This would prevent greenwashing and ensure industry claims match real-world environmental impacts.
The chemical industry loses the ability to easily assign recycled status to their products.

EuRIC demands fair recycled plastic rules

European Recycling Industries' Confederation, 18 Aug 2025

EuRIC requests prioritizing mechanical recycling over chemical methods and implementing a 'mirror clause' for imported materials. They also demand separate categories for plastic and non-fuel products to ensure transparent traceability.
This would safeguard the competitiveness of European recyclers against cheap foreign imports.
Chemical recycling firms would lose feedstock if mechanical recycling is technically and environmentally preferable.

Plastics Recyclers Europe urges stricter rules for recycled content

Plastics Recyclers Europe, 19 Aug 2025

PRE calls for EU-based auditors and protecting European waste markets. They also want to eliminate administrative duplication and prioritize mechanical recycling.
These measures would protect European recyclers from unfair competition and lower administrative burdens.
Chemical recycling firms lose out as waste is prioritized for mechanical recycling processes.

Plastics Recyclers Europe demands third-party verification for recycling targets

Plastics Recyclers Europe, 24 May 2023

The group demands mandatory third-party checks and annual auditing to ensure reporting reliability. They also call for calculation methods that create a level playing field across technologies.
Mandatory auditing would protect the market position of established high-quality European recyclers.
Firms using self-declaration systems would face increased administrative burdens and stricter compliance costs.

Kemira Urges EU to Differentiate Biomass Balance Methodologies

Kemira Oyj, 18 Aug 2025

Kemira requests that forthcoming guidance clearly distinguishes among various mass balance applications. They urge the Commission to provide regulatory support for biomass-balanced chemicals.
Establishing a framework would strengthen the credibility and adoption of their renewable chemicals.
Fossil fuel suppliers lose as the industry accelerates its shift away from fossil resources.

Consultation response

Union of European Beverages Association, 14 Aug 2025

UNESDA Soft Drinks Europe welcomes the European Commissions draft Implementing Act setting out harmonised rules to calculate, verify, and report the share of recycled plastic in single-use plastic (SUP) beverage bottles and supports its speedy adoption by Q4 2025. This act provides a critical…

Soft Drinks Europe urges EU to recognize chemical recycling

Union of European Beverages Association, 30 May 2023

The group requests the inclusion of chemical recycling and pre-consumer waste. They want calculation based only on the major component of the beverage bottle.
This provides flexibility and ensures easier access to limited food-grade recycled plastic supplies.
Environmental groups lose when factory scrap replaces post-consumer waste in official recycling targets.

Topsoe Urges Flexible Rules to Scale Chemical Plastic Recycling

TOPSOE A/S, 19 Aug 2025

Topsoe recommends permitting a company to transfer attributed amounts between sites on a like-for-like basis. They advocate for leveraging existing refineries as a cost-competitive pathway to scaling up chemical recycling. Effective enforcement is requested to place European recyclers on a level playing field.
Utilising existing infrastructure will ensure an affordable transition and reduce the EU's investment needs.
European recyclers lose out to imports from regions that implement more flexible mass balance accounting.

MOL Group urges swift adoption of chemical recycling rules

MOL Hungarian Oil and Gas Company, 18 Aug 2025

MOL Group calls for the swift adoption of rules to secure investment certainty. They support the fuel-use excluded methodology as a blueprint for future recycling regulations.
MOL would benefit from utilizing its existing chemical assets and protecting its confidential information.
Environmental advocates lose if credit transfers across different industrial sites are permitted.

LEGO Group backs EU rules for recycled plastic content

The LEGO Group, 19 Aug 2025

LEGO supports the fuel-use excluded approach and strict chemical traceability. They recommend adding clear definitions to prevent overcompensation in complex products. The group urges fast adoption to provide investment certainty for manufacturers.
A robust standard provides legal clarity to enable investments in sustainable plastic production.
Brands using less rigorous accounting would lose the ability to make sustainability claims.

FEAD coalition urges stricter rules for chemical plastic recycling

FEAD, 19 Aug 2025

The coalition advocates for prioritizing mechanical recycling and demands strict traceability safeguards for chemical methods. They also call for a 'mirror clause' to ensure imported plastics meet EU environmental and social standards.
These safeguards would protect the competitiveness of European recyclers against cheaper, lower-standard imports.
Chemical recycling companies could face higher reporting burdens and reduced demand for their products.

Orlen urges EU to adopt flexible chemical recycling rules

Orlen S.A., 19 Aug 2025

Orlen requests a non-proportional mass balance approach that excludes fuel use. They propose allowing credit transfers between production sites and broadening definitions to include all chemical building blocks, not just polymers.
This allows Orlen to utilize existing refinery assets instead of building expensive new installations.
Consumers face higher costs as recycled materials become unnecessarily scarce and expensive.

Evonik Urges Swift EU Adoption of Chemical Recycling Rules

EVONIK INDUSTRIES AG, 19 Aug 2025

Evonik calls for the swift adoption of rules by 2025 to ensure investment certainty. They support mass balance methods but warn against provisions that make using existing assets economically unviable.
This framework provides legal certainty for the company to invest in new recycling installations.
General consumers could suffer from price inflation and an overall loss in welfare.

Consultation response

Eastman Chemical Company, 19 Aug 2025

Eastman, a specialty material company seeking to further invest in Europe, welcomes the European Commissions proposed Implementing Act under the Single-Use Plastics Directive (SUPD), which outlines the methodology for calculating, verifying, and reporting recycled plastic content in single-use…

IKEA urges transparent rules for recycled plastic content

Inter Ikea Systems BV, 18 Aug 2025

IKEA calls for a transparent methodology ensuring physical and chemical traceability of materials. They advocate for a 12-month limit on credit transfers and simple, transparent counting methods. They also suggest parallel reporting to identify inconsistencies in the data.
Clear rules provide the legal certainty needed for IKEA to transition its materials.
Experimental chemical recycling firms lose out as only scalable technologies would be permitted.

Consultation response

Eastman Chemical Company, 30 May 2023

Eastman believes the SUPD draft implementing act phase I, which is limited to mechanical recycling of PET beverage bottles, is a missed opportunity in reducing Europes plastic waste production and increasing plastic recycling across the bloc. When it comes to waste management and circularity,…

OMV Urges Flexible Mass-Balance Rules for Chemical Recycling

OMV Aktiengesellschaft, 19 Aug 2025

OMV requests flexible mass-balance rules because physical segregation of waste-derived input is currently impossible. They advocate for controlled allocation to provide incentives for scaling chemical recycling technology economically.
This allows OMV to utilize existing refinery infrastructure, reducing costs and environmental footprints.
Europe's chemical industry loses competitiveness under current rules requiring unnecessary processing of fossil feedstocks.

Flexible Packaging Europe urges swift approval of plastic recycling rules

Flexible Packaging Europe, 11 Aug 2025

The association supports the proposed rules for calculating and reporting recycled plastic content. They urge the European Commission to approve the act quickly to provide certainty.
The organization would benefit from increased legal clarity for its manufacturing members.

Henkel urges acceptance of mass balance for recycled materials

Henkel AG & Co. KGaA, 18 Aug 2025

Henkel calls for policies that accept credible mass balance approaches for sustainable materials. They advocate using a complete life cycle approach to compare different recycling technologies.
Adopting these standards helps the company turn waste into valuable circular resources.
Companies producing fuel from plastic lose out as their processes are exempted.

ChemSec warns against creative accounting for recycled plastic bottles

International Chemical Secretariat, 30 May 2023

ChemSec demands removing references to chemical recycling and creative mass balance accounting. They urge for reporting that reflects true content through strict, batch-level traceability.
This ensures truthful consumer information and protects mechanical recyclers from unfair competition.
Large chemical companies lose the ability to use credit transfers for marketing products.

European Plastics Converters demand strict controls on recycled imports

European Plastics Converters Association, 19 Aug 2025

The association urges the quick adoption of rules to give investors confidence. They demand equal verification for imports to ensure a level playing field. They also want to remove requirements that force companies to disclose confidential supplier names.
Stricter import rules would safeguard the competitiveness of the European recycling industry.
International suppliers could be barred from the European market without expensive certification.

ANEC Demands Chemical Safety Standards for Recycled Plastic Bottles

The European Consumer Voice in Standardisation, 30 May 2023

ANEC calls for recycled content requirements to be aligned with the Chemicals Strategy for Sustainability. They demand urgent updates to food contact material rules to prevent human exposure to toxic substances.
Consumers gain stronger health protections by preventing the use of contaminated recycled packaging materials.
The recycling industry could face complete bans on using recycled plastics for beverages.

European Plastics Converters Urge Alignment on Bottle Definitions

European Plastics Converters Association, 30 May 2023

EuPC requests aligning definitions to exclude labels and sleeves from the calculation base. They also advocate for a unified waste definition and a single reporting format.
This prevents an unjustified expansion of regulatory scope and reduces administrative burdens for companies.
Environmental groups lose if components like labels are excluded from mandatory recycling targets.

Westenergy seeks recycled status for captured carbon

Westenergy Oy, 19 Aug 2025

Westenergy advocates for recognizing carbon captured from waste-to-energy processes as a recycled feedstock. They propose a 'circular content' category for carbon reused via capture technologies.
This would incentivize their carbon capture investments by allowing their output to meet recycling targets.
Fossil fuel suppliers lose as captured carbon replaces virgin fossil carbon in plastic production.

Waste-to-Energy Industry Demands Stricter Definition of Recycled Plastic Content

Confederation of European Waste-to-Energy Plants, 19 Aug 2025

The organization requests that only waste input be counted as recycled content, excluding non-waste materials. They want the Waste Framework Directive recycling definition explicitly included and additional guidance with concrete calculation examples.
This would protect their competitive position by preventing virgin plastics from being counted as recycled content.
Plastic producers using chemical recycling or advanced processing methods may face stricter eligibility requirements.

Water producers urge flexible rules for plastic bottle recycling

Natural Mineral Waters Europe aisbl, 30 May 2023

NMWE wants to include factory scraps in recycling targets and average results across producers. They also recommend reporting data only in 2025 and 2030 rather than every year.
Including industrial scraps makes it easier for producers to meet mandatory targets.
Environmentalists lose if using factory waste masks a failure to recycle consumer plastic.

Consultation response

LyondellBasell Industries N.V., 19 Aug 2025

LyondellBasell (LYB) welcomes the proposed draft implementing decision of Directive (EU) 2019/904, establishing a recycled content calculation methodology for single-use plastic beverage bottles. We support a clear, transparent and credible approach that recognizes chemical recycling of plastics -…

Port of Antwerp-Bruges demands clear rules for chemical recycling

Havenbedrijf Antwerpen - Brugge NV van publiek recht, 19 Aug 2025

The organization requests clear rules that recognize chemical recycling as a valid method. They want flexibility to use existing industrial infrastructure and transfer credits between sites. They also seek a simple system that ensures fair global competition.
This would allow the port to secure major chemical recycling investments.
Waste incineration companies lose out as plastic is diverted to recycling.

Valmet urges technology-neutral rules for chemical plastic recycling

Valmet Oyj, 19 Aug 2025

Valmet supports using a mass balance method for chemical recycling technologies. They recommend a technology-neutral approach that does not favor mechanical recycling.
This would secure regulatory acceptance and encourage investment in their recycling solutions.
Traditional mechanical recycling companies would lose their preferred status in EU regulation.

Consultation response

PETCORE EUROPE, 19 Aug 2025

ETCORE EUROPE welcomes the new draft Commission Implementing Decision laying down rules for the application of Directive (EU) 2019/904 as regards the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles and repealing Commission…

Consultation response

PETCORE EUROPE, 30 May 2023

PETCORE Europe welcomes the European Commissions efforts to support the implementation of the Directive on Single-Use Plastics (Directive (EU) 2019/904, also known as SUP Directive). The SUP directive remains the main instrument to encourage responsible consumer behaviour and to promote the…

Czech Chamber of Commerce urges unified plastic recycling rules

Hospodářská komora České republiky, 26 May 2023

The Chamber demands consistent reporting standards and clear rules for chemical recycling. They also seek precise definitions and alignment with food safety regulations.
Unified standards would reduce administrative burdens and provide certainty for new investments.
Investors in chemical recycling face delays due to the absence of calculation rules.

Consultation response

SYSTEMIQ LIMITED, 19 Aug 2025

Feedback on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles. Feedback…

Polish Cosmetics Industry Demands Wider Chemical Recycling Rules

Polski Związek Przemysłu Kosmetycznego, 13 Aug 2025

The organization requests that legal rules for chemical recycling apply horizontally to all industrial sectors. They argue these methodologies should be included in the wider Packaging and Packaging Waste Regulation.
This would allow cosmetic companies to meet mandatory recycling targets using high-quality materials.

CO2 Value Europe urges 'circular content' quotas for plastic bottles

CO2 Value Europe AISBL, 13 Aug 2025

The association proposes broadening the mandate through a 'circular content' quota. This category should cover both recycled waste and carbon capture and utilisation.
Including carbon capture technologies allows their members to supply feedstock for plastic production.
Waste recyclers would lose their exclusive position as the sole recognized carbon source.

Ecopreneur.eu urges proportional allocation for recycled content reporting

Ecopreneur.eu, 30 May 2023

The federation requests that recycled content be allocated proportionally at a batch level. They oppose methods allowing misleading labels on products with minimal recycled material.
This would protect mechanical recycling investments and ensure a stable market for materials.
Chemical recyclers lose the flexibility to claim high recycled content using flexible accounting.

Consultation response

Extended Producer Responsibility Alliance, 30 May 2023

EXPRA is pleased to provide the following feedback on the draft. If a non-plastic (for example paper) label is a part of the bottle, the methodology requires that it is deducted from the weight of the plastic bottle. This is different to the Commission Implementing Decision (EU) 2019/665…

French waste group warns against favoring chemical recycling

Fédération Nationale des Activités de Dépollution et de l'Environnement, 19 Aug 2025

FNADE advocates for the prioritisation of mechanical recycling over chemical recycling in the legislation. They demand a robust mirror clause to safeguard EU recyclers against cheap foreign imports. The group wants a polymer-only methodology to provide greater transparency for the consumer.
This would help French mechanical recyclers survive the current crisis and unfair competition.
Chemical recyclers lose the competitive edge granted by the proposed fuel-use exempt methodology.

Consultation response

ALPLA Werke Alwin Lehner GmbH Co KG, 19 Aug 2025

ALPLA is a global leader in the development and manufacturing of rigid plastic packaging solutions. The company operates 200 manufacturing plants across 46 countries, employing over 24,000 people worldwide. ALPLA specializes in innovative packaging systems, bottles, closures, and injection-molded…

Consultation response

Halte à l'obsolescence programmée (HOP), 14 Aug 2025

Créée en 2015, HOP - Halte à l'obsolescence programmée est une association agréée protection de l'environnement qui plaide pour l'allongement de la durée de vie des produits. Notre travail étant directement lié à léconomie circulaire, les enjeux de recyclage font partie intégrante de nos sujets…

Consultation response

Polyolefin Circular Economy Platform, 19 Aug 2025

The Polyolefin Circular Economy Platform (PCEP) represents stakeholders across the polyolefin value chain, working to advance circularity in the most widely used plastics family. Polyolefins constitute 71.4% of Europes plastic packaging and 71% of plastic waste collected for recycling. They…

Consultation response

Allianz Verpackung und Umwelt e.V., 17 Jul 2025

Zukunftsfähige Kreislaufwirtschaft mechanisch und chemisch Die Kreislaufführung von Verpackungen leistet einen wichtigen Beitrag zum Ressourcen- und Klimaschutz. Sie reduziert den Bedarf an fossilen Rohstoffen und spart so CO-Emissionen ein. Da Verpackungen in Haushalten, Handel und Industrie in…

Malta Business Bureau urges flexible recycled plastic rules

Malta Business Foundation, 30 May 2023

The bureau requests calculation metrics only refer to the major component and include pre-consumer waste. They also advocate for the immediate inclusion of a mass balance approach.
Maltese businesses would avoid penalties for factors outside their direct manufacturing control.
Recyclers lose efficiency if the rules indirectly encourage using detrimental paper labels.

Consultation response

Aquafil SpA, 18 Aug 2025

Please find attached Aquafil's detailed feedback.

Consultation response

Koninklijke Vopak N.V., 19 Aug 2025

At Vopak, we welcome the European Commission's draft Implementing Decision laying down rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles. The proposal, in our view, rightfully includes and acknowledges the role of chemical…

Consultation response

Verband Österreichischer Entsorgungsbetriebe, 18 Aug 2025

The VOEB - Association of Austrian Waste Management Companies - would like to express its gratitude for the opportunity to comment on the European Commission's new Draft Implementing Decision for the implementation of Directive (EU) 2019/904 (SUPD) - please find our Statement attached. With this…

Consultation response

Renewable Carbon Initiative, 19 Aug 2025

For a full version of our feedback, please refer to the attached file. RCI welcomes the draft Implementing Decision and supports the Commissions efforts to establish a methodology for MBA a key step to defossilise the chemical industry and promote sustainable carbon cycles. MBA is essential for…

Consultation response

Stichting CEFLEX, 19 Aug 2025

CEFLEX welcomes the publication and public consultation on a draft SUPD Implementing Act on rules for calculating, verifying and reporting on recycled content. Our key messages are summarised here; please see the attachment for our more detailed feedback. The draft SUPD Implementing Act, which many…

Consultation response

Citeo, 8 Aug 2025

Citeo welcomes the publication of the methodology of calculating the integration of recycled content with mass balance approach, which is essential for the development of an EU secondary material markets. We underline the following points: Support for the prioritization of mechanical recycling…

Consultation response

MAIRE0 Group - NextChem, 30 Jul 2025

MAIRE Group emphasizes the significance of the document's explicit acknowledgement of the pivotal role of chemical recycling. This plastic recycling process is particularly valued as it enables the management of plastic waste that cannot be recycled with currently available mechanical recycling…

Consultation response

CONSORZIO NAZIONALE IMBALLAGGI, 30 May 2023

The proposed act itself introduces separate reporting on the recycled content per component (bottle, cap and label) for the economic operator (packaging producer and/or user) and places the burden of data collection, coordination and supervision on the responsibility of the MS. In this context,…

Consultation response

Citeo, 30 May 2023

Citeo underlines the risk of misunderstanding and legal uncertainty with the existence of definitions of recycled plastic in two legal instruments. In order to calculate the weight of the beverage bottle, Citeo believes all the components should be taken into account and not only the plastic parts…

Consultation response

The European Plastic Pipes and Fittings Association, 19 Aug 2025

TEPPFA welcomes the European Commissions public consultation regarding the draft Single-Use Plastics Directive (SUPD) Implementing Decision, which proposes a credit-based mass balance method for attributing chemically recycled content in plastic beverage bottles. It is essential that EU…

Consultation response

Fair Resource Foundation, 18 Aug 2025

The Fair Resource Foundation appreciates the chance to provide feedback on the draft Implementing Decision concerning Directive (EU) 2019/904, which sets out rules for calculating, verifying, and reporting on recycled plastic content in single-use plastic beverage bottles. For this act to be…

Consultation response

PET EUROPE - Producers' Association aisbl, 18 Aug 2025

PET EUROPE welcomes the new draft of the second Implementing Act of the Single Use Plastics Directive, which supports the use of recycling technologies beyond mechanical recycling, such as depolymerization, that will contribute to achieving the European Unions recycling targets. However, we have…

Consultation response

Der Grüne Punkt Holding GmbH Co. KG, 12 Aug 2025

GreenDot very much welcomes the draft proposal. 1. It provides clear recognition of chemical recycling of plastics, a critical capability necessary to enable the delivery of recycled content targets and recycling rate targets in the Single Use Plastics Directive (SUPD) and the Packaging and…

Chemical distributors urge simpler rules and broader recycling definitions

European Association of Chemical Distributors, 12 Aug 2025

The association favors a proportional mass balance approach based on batch-level allocation to simplify verification. They also recommend including glycolysis-based chemical recycling and broadening the definition of recycled plastic to include pre-consumer waste.
Simplified accounting methods would reduce high verification costs and administrative uncertainty for distributors.
Environmental goals focused on post-consumer waste may be undermined by including industrial scraps.

Consultation response

NRW.Energy4Climate GmbH, 6 Aug 2025

NRW.Energy4Climate welcomes the endeavour to implement rules on the recycling of single-use plastic bottles. In the attached file, we would like to provide feedback on the current draft and outline possible adjustments and recent debates on the North Rhine-Westphalian (NRW) level.

Consultation response

EUROPEAN CHEMICAL REGIONS NETWORK, 22 Jul 2025

The European Chemical Regions Network (ECRN) welcomes the European Commissions draft Implementing Decision laying down rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles, in line with Directive (EU) 2019/904. This proposal…

Consultation response

Health and Environment Justice Support, 30 May 2023

This is a submission on behalf of the NGO Coalition Exit Plastik. Members of the Coalition are: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., Heinrich-Böll-Stiftung, HEJSupport e.V., Küste gegen Plastik e.V., Surfrider Foundation…

Consultation response

PET EUROPE - Producers' Association aisbl, 30 May 2023

PET Europe - feedback to the public consultation on the Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content initiative. PET EUROPE is a non-profit trade association that represents the European PET resin producers. PET EUROPE represents…

Polish chemical industry demands flexible rules for chemical recycling

Polska Izba Przemysłu Chemicznego, 19 Aug 2025

The group requests flexible mass balance accounting and removal of credit transfer restrictions. They also seek broader technology definitions and protections for confidential business information.
These changes would lower investment risks and allow companies to leverage existing infrastructure.
Consumers could face higher costs and artificial scarcity of recycled materials.

Consultation response

Werner & Mertz, 18 Aug 2025

Werner & Mertz welcomes the Commissions effort to establish a consistent and transparent methodology for calculating, verifying, and reporting the recycled content of plastics. We particularly appreciate the focus on using actual measured plant data and the explicit limitation of certain…

Consultation response

Deutsche Bauchemie e.V., 18 Aug 2025

The German Construction Chemicals Industry Association supports the EU Commission´s efforts to establish mass balance (MB) accounting rules by enabling chemical recycling pathways under the draft SUPD IA. However, we would like to draw your attention to the fact that not all industrial branches and…

Consultation response

EPRO, 19 Aug 2025

Stakeholders feedback from EPRO and EXPRA. Submitted by EPRO on behalf of EPRO and EXPRA. EPRO and EXPRA support the effort of the European Commission to establishing credit-based mass balance as the method for calculating recycled content from chemical recycling processes. EPRO and EXPRA support a…

Consultation response

SIG Group, 19 Aug 2025

As a global provider of food and beverage packaging systems and solutions, such as aseptic beverage cartons, spouted pouches and bag-in-box , SIG welcomes the EU Commissions proposal for harmonised rules to calculate, verify and report on the recycled plastic content targets introduced by Directive…

Consultation response

, 19 Aug 2025

Danish Industry (DI) would like to thank the EU Commission for the opportunity to comment on this proposal. DI represents 20.000 Danish companies across many different industries and sectors. >A level playing field and continued investment in technology DI welcomes harmonized rules to calculate,…

Consultation response

IK Industrievereinigung Kunststoffverpackungen e.V., 19 Aug 2025

Although the implementing decision pursuant to Article 6(5) SUPD only concerns single-use beverage bottles, it is of landmark significance for the implementing act pursuant to Article 7(8) PPWR and therefore for the entire plastic packaging market in Europe. Against the backdrop of the mandatory…

Consultation response

Federation of European Rigid Polyurethane Foam Associations, 19 Aug 2025

PU Europe represents the European polyurethane (PUR/PIR) insulation industry, covering factory-produced and in-situ formed PU foam. With over 110 manufacturing sites and more than 20,000 direct jobs including raw material suppliers, the sector contributes significantly to reducing building-related…

Consultation response

Advanced Packaging Association, 19 Aug 2025

Established in 2024, the Advanced Packaging Association (APA) brings together key industry stakeholders who recognize polyamide (PA) as a sustainable, high-performance material for packaging applications. APAs mission is to foster collaboration across the flexible packaging value chain, actively…

Consultation response

Vereniging Vlaamse Steden en Gemeenten, 18 Aug 2025

We welcome the fact that the calculation method also includes caps and sleeves, as well as the correction for exports. This ensures that only what is actually placed on the national market is taken into account. The current text places chemical recycling on the same level as mechanical recycling.…

Consultation response

Sterile Barrier Association, 14 Aug 2025

Attached the letter that the Sterile Barrier Association's regulatory committee has developed for the SUPD mass balance consultation

Consultation response

Faerch A/S, 14 Aug 2025

Faerch welcomes the draft and strongly supports the proposed framework, particularly the recognition of mass balance accounting, which is a necessary methodology for transitioning to a circular economy and scaling up chemical recycling. We also welcome the clear requirement for using actual…

DigitalTrade4.EU advocates for digitalized recycled plastic reporting

DigitalTrade4.EU, 7 Aug 2025

The organization recommends using a digital interoperability ecosystem to enhance reporting transparency. They suggest utilizing Digital Product Passports to track lifecycle data and ensure traceability across platforms.
This would establish the consortium’s digital standards as the primary framework for EU compliance.

Consultation response

GIDARA-Energy, 30 May 2023

GIDARA Energy would like to provide feedback on the definition of Recycled Plastics incorporated in the Implementing Regulation. For further details please see attached file.

Consultation response

Polski Związek Przetwórców Tworzyw Sztucznych, 29 May 2023

Pierwsze istotne dla nas pytanie dotyczy tego, czy przekazywanie państwom członkowskim danych dotyczących zawartości tworzyw sztucznych pochodzących z recyklingu w jednorazowych plastikowych butelkach na napoje dotyczy również preform, ponieważ tekst odnosi się tylko do butelek PET. Termin…

Consultation response

Brussels For Human Rights Development, 26 May 2023

Brussels for Human Rights and Developments (BHRD) welcomes the European Commission's draft act on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. We believe that the act is a significant step forward in the EU's efforts to reduce…