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EPRO

To monitor developments and best practice activities in the field of collection, pre-treatment, and recycling of waste plastic, and also the use of recycled polymer.

Lobbying Activity

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

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 fuel-exempt allocation method and not proportional nor polymer only. This will create the conditions for the use of recyclates from chemical recycling for achievement of the SUPD recycled content targets for single use plastic beverage bottles. So we welcome that the EU supports all recycling technologies that are better for the environment than incineration or landfill, and that the rules are meant to enable all of them to attain economic viability (recital 6). Given the size of the investments required, it will take several years to scale up chemical recycling capacity. For the time being, the lack of legal certainty around the rules for calculating recycled content, has been a major barrier to industrial deployment of chemical recycling technologies. EPRO and EXPRA call for a quick adoption of this SUPD Implementing Act. However, we would like to raise the attention of the Commission on some important points of this draft Implementing Act in order to obtain a clear calculation methodology, benefiting the environment and helping to establish Europe as a leader in sustainable innovation. Therefore, please find our full joint response in the attached document.
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