Advanced Packaging Association
APA
The Advanced Packaging Association (APA) brings together the key polymer industry players who believe that polyamide (PA) is a sustainable, high-performance material for packaging applications.
ID: 284729897390-71
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Feedback to consultation. 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 support the transition to a circular economy and provide fact-based, science-driven guidance on the integration of polyamide (PA) into existing polyolefin waste management systems. APA welcomes the European Commissions ambition to strengthen Europes competitiveness and sustainability through its Circular Economy Act. By introducing simplified and EU-harmonised Extended Producer Responsibility (EPR) schemes and clear end-of-waste criteria, the Act has the potential to position the EU as a global leader in sustainable production and resource efficiency. To ensure the Act achieves its objectives, APA highlights 3 priority areas: Efficient Extended Producer Responsibility (EPR) schemes: currently, the European Union knows dozens of EPR schemes, managed at national and even sometimes at regional levels. These schemes are key for the good functioning of circular economy but also currently very bureaucratic. o APA recommendation: The Circular Economy Act should establish a simplified and harmonised framework with minimum common rules while preserving flexibility for regional or national adaptation where local waste management systems perform effectively. This subsidiarity-based approach will reduce bureaucracy while improving efficiency and transparency. Recognition of technological neutrality to achieve minimum [EU] recycled content targets: While ambitious minimum recycled content targets are key to driving circularity, they are currently difficult to achieve due to limited availability of high-quality recyclates and the absence of a harmonised methodology for calculating recycled content. The lack of clarity creates uncertainty for producers and hinders investment in advanced recycling solutions. Mechanical recycling alone cannot meet the growing demand with the required quality and performance. o APA recommendation: The Act should explicitly recognise chemical recycling and mass balance approaches as valid methods for achieving recycled content targets across the board. This would expand the supply of high-quality recycled materials, improve price competitiveness, and limit illegal waste exports. In parallel, clear and harmonised methodologies for calculating recycled content should be adopted to ensure consistency across the Single Market. Competition from 3rd countries: Without equivalent environmental obligations for imported goods, EU industry faces unfair competition. Cheaper imported products that do not meet EU standards can displace EU-made goods on the market, thereby lowering demand for domestically recycled materials. Over time, this weakens the economic viability of recycling infrastructure and limits the availability of high-quality secondary raw materials needed to meet EU circularity targets. o APA recommendation: Financial incentives, including tax breaks, VAT reductions, and eco-modulated EPR fees, should apply exclusively to plastics and related products manufactured within the EU. Granting these benefits to imported recycled materials or circular goods could weaken the competitiveness of Europes plastics sector and create imbalances in the internal market. Conclusion: The Circular Economy Act represents a key opportunity to make Europe a global leader in circular value chains. A successful European circular economy will depend on clear and harmonised standards, fair competition, and recognition of advanced recycling technologies. By pursuing these priorities, the EU can build a circular economy that is both environmentally and economically viable, setting a global benchmark for sustainable growth.
Read full responseResponse to EU rules for the calculation and reporting of recycled content in single-use plastic bottles
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 support the transition to a circular economy and provide fact-based, science-driven guidance on the integration of polyamide (PA) into existing polyolefin waste management systems. Advanced packaging containing polyamide reduces food waste due to its strong mechanical properties and barrier protection, leading to a better overall environmental footprint. It can be recycled through both mechanical and chemical recycling. However, given the limitations of mechanical recycling (particularly for food-contact materials and mixed waste streams), chemical recycling through mass balance accounting is a key enabler for our industry. While we acknowledge that industry views differ, APA supports the inclusion of a Fuel Use Exempt (FUE) mass balance approach as a fundamental element for circularity, particularly where it creates a level playing field for a broad range of technologies and processes. Considerations on mass balance APA strongly supports mass balance accounting as a vital mechanism to enable the circular use of plastics, including polyamide. However, the proposed text may fall short of achieving long-term improvements in plastic circularity and should not serve as a direct model for future legislative frameworks, for several reasons: Limited recognition of industry processes: The proposal does not fully consider well-established industrial practices, particularly those that rely on co-processing, which significantly contribute to achieving recycled content targets. Technological neutrality: A truly circular approach requires both a level playing field and technological neutrality. As currently drafted, the constraints on eligible recycled content risk undermining the economic case for using waste-based feedstocks. This may, in turn, limit the potential of mass balance accounting in the chemical industrys circular transition. The Waste Framework Directive was adopted in 2008, long before the emergence of chemical recycling and large-scale use of circular feedstocks. Consequently, the proposed FUE model, originally designed for single-use PET bottles, is not suited for broader applications. Administrative burdens: Certain provisions in the text introduce unnecessary complexity, which could lead to excessive administrative requirements. The industry supports a comprehensive, streamlined mass balance FUE approach that captures all processes and outputs. This could be more effectively implemented at the level of a single operator per site, using standardized conversion factors that account for all losses and outputs. Therefore, we urge policymakers to adopt a more pragmatic, result-oriented approach that aligns with digital operations. Terminology and definitions: The definition of mass balance accounting is not fit for all circular feedstocks. Additionally, the wording in the proposed definition of Mass Balance accounting (Article 1 (11)) should be aligned with that of the ISO 22095 to secure a clear understanding and allow for the model to be replicated for different circular feedstocks beyond recycled ones. Conclusion The approach to mass balance must also be consistent with broader EU objectives, including those laid out in the Chemicals Strategy for Sustainability, which calls for enabling circularity and material recovery within a safe and sustainable chemicals framework. To unlock this potential, APA advocates for a consistent interpretation of the mass balance approach with FUE. This proposal should be treated as a test case specific to PET bottles, not a one-size-fits-all model for other value chains. Significant adjustments would be needed before applying this model in broader legislation, such as the PPWR.
Read full response