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European Plastics Converters Association

EuPC

European Plastics Converters is a trade association representing 50,000 companies in the plastic industry.

Lobbying Activity

Plastics converters urge EU to recognize materials as critical

6 Nov 2025
Topic — The EU is consulting on the Circular Economy Act to enhance sustainability and competitiveness.
Message — The industry requests designating plastics as critical molecules and creating a dedicated circularity fund. They also demand the removal of the plastic waste levy and simplified regulatory burdens.12
Why — These measures would lower operational costs and provide financial support for circular investments.3
Impact — Foreign producers might face restricted market access through new 'green lists' and trade barriers.45
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Meeting with Jessika Roswall (Commissioner) and

29 Oct 2025 · Roundtable- closing the Loop : Addressing the Plastic Recycling Crisis in Europe

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Plastics Europe and

29 Sept 2025 · Discussion of several issues that European plastics value chain is facing.

European Plastics Converters demand strict controls on recycled imports

19 Aug 2025
Topic — The EU is establishing rules for measuring and reporting recycled content in bottles.
Message — 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.123
Why — Stricter import rules would safeguard the competitiveness of the European recycling industry.4
Impact — International suppliers could be barred from the European market without expensive certification.5
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Meeting with Pauline Weinzierl (Head of Unit Trade)

16 Jun 2025 · EuPC Annual Conference devoted to “The Future of Plastics: Circular and Competitive

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Meeting with Karin Karlsbro (Member of the European Parliament, Shadow rapporteur)

13 Jan 2025 · Plastpellets

Meeting with Liesbet Sommen (Member of the European Parliament, Shadow rapporteur)

6 Jan 2025 · Regulation on preventing plastic pellet losses to reduce microplastic pollution

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

The Contact Sensitive and Food Contact Plastics Regulatory Expert Panel (CFREP), a sector group of European Plastics Converters (EuPC), welcomes the opportunity to give our industries feedback to the proposed amendment to Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food and Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food as regards recycled plastic and other matters related to quality control and manufacturing of plastic materials and articles intended to come into contact with food. We would like to highlight the following points: 1. It is problematic to continue specifying quality requirements for plastic packaging, as it leads to growing imbalances of measures for food contact packaging made from different materials. 2. The introduction of the proposed Article 3a, which includes the concept of a high degree of purity, raises significant concerns regarding practical compliance demonstration and shall take into consideration the most current scientifically accepted standards. 3. Regarding Article 6 on the use of biocidal products, we would propose to extend the scope to further product-types with the additional requirement that these need to be petitioned for food contact use. 4. Requiring manufacturers at all stages to know and share the composition could impose significant burdens and inefficiencies. We therefore propose to revise the wording of Article 8 to ensure a clear interpretation and consistent implementation. 5. The proposed labelling requirements on repeated used materials and articles (Article 14a) must remain practicable. 6. Removing the derogation for containers with volume less than 500 ml from Article 17 (2) represents a big impact, which is not supported by any justification or evidence of safety problems. 7. Regarding the reprocessing of by-products, definition of reprocessing does not adequately consider common industrial practices for re-processing at the manufacturing stage. Please find attached the document containing our detailed comments. We remain at your disposal for your questions and further discussion on this subject matter.
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Response to Measures to reduce microplastic pollution

17 Jan 2024

EuPC is the trade association of European Plastics Converters. We see the current European Commissions proposal as an additional important step towards the objective of near to zero pellet loss by creating a harmonized level playing-field across the whole supply chain. As responsible companies, we see it as important that pellet losses are prevented so as to prevent this source of microplastics to end up in the environment. As a more general remark, we would like to remind that this measure in itself should be considered in conjunction with other targeted at litter such as closing down of poorly managed landfills and dumpsites. We would like to emphasize the importance for this regulatory proposal to be rapidly adopted while keeping in mind the specific constraints of SMEs. We have as well taken note of the draft ENVI report and the ITRE proposed amendments. We would like to share our position on those and also suggest specific amendments related to technical aspects or the regulation or aiming at reducing its socio-economic burden on industry whilst ensuring a smoother and faster adoption and implementation taking into account the needs of SMES. Our comments may be found in attachment. They address the following topics : 1) Article 1: scope : We understand as handler of pellet covers all the actors in the supply chain: resin manufacturers, recyclers, masterbatchers and compounders, converters, transport and logistics operators including distribution. 2) Definitions : the EC proposal focuses on plastics pellet. The EP proposes to extend the definition to powders, flakes and dust. We do not oppose to the extension to powders and flakes, but dust should be treated separately (focus on prevention). 3)Companies in scope of certification, frequency of self-declaration, support to SMEs : The ENVI committee proposes in amendment 14 to make companies treating more than 250 T per site as well as small companies subject certification foreseeing self-declaration for micro-companies only. We believe appropriate measure should be considered to support SMEs. It should not solely focus on exemption from certification for small companies but foresee and obligation for EC and Member States to organize and support training, fiscal incentives to enable acquisition of equipment and postponed entry into force for smaller companies are part of the way forward to enable a successful deployment of the regulation. 4)Equipment and procedures : The EC has foreseen that equipment and procedures should be in place for preventing, containing and cleaning up pellet spills and losses. The annex I lists equipment and procedures to be considered taking into account the nature and size of the companies. Certain amendments of the ENVI committee intend to make those measure mandatory. This is not applicable, since not all risk management measures are applicable to all companies. Also, when considering the size of the companies the extent of releases may be significantly reduced calling for different measures to be implemented. 5) Exemption from certification for companies having in place an environmental or quality management system : Compliance with regulation and verification of this compliance is integral part of the ISO 9001 and 14001 certification for environmental management systems as well. We will proceed in a thematic manner. ISO 14001 concerns more particularly certification of an environmental management system, whilst ISO 9001 relates to a management system 6) Standardized methodology to measure pellet loss : a EC guidance would be ready faster and more flexible than standardization 7) Penalties and sanctions : we call for the original EC proposal to be supported without further amendments. Basis to calculate penalty should be the turnover of a company in a given Member State (jurisdiction), suspension of activity should not be made mandatory but subject to a proportionality assessment by a Competent Authority.
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Meeting with João Albuquerque (Member of the European Parliament, Rapporteur)

4 Dec 2023 · Preventing plastic pellet losses to reduce microplastic pollution

European Plastics Converters seek flexible recycled content rules

1 Dec 2023
Topic — The consultation reviews rules for vehicle recycling and circularity in car production.
Message — The association requests including pre-consumer waste and chemical recycling to meet the 25% recycled content target. They urge prioritizing open-loop recycling over closed-loop mandates to ensure material availability. Additionally, they propose a broader plastic definition to include thermosets and avoid overlapping chemical regulations.123
Why — Expanding the types of allowed recycled materials reduces compliance costs and production risks.4
Impact — The environment loses if industry prioritizes factory scrap over harder-to-recycle used vehicle waste.5
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European Plastics Converters Urge Alignment on Bottle Definitions

30 May 2023
Topic — This initiative defines rules for calculating and reporting recycled content in beverage bottles.
Message — 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.123
Why — This prevents an unjustified expansion of regulatory scope and reduces administrative burdens for companies.45
Impact — Environmental groups lose if components like labels are excluded from mandatory recycling targets.6
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Plastics converters demand consistent recycling targets and legacy rules

3 May 2023
Topic — The initiative establishes criteria for economic activities that contribute to circular economy and pollution objectives.
Message — EuPC requests aligning recycling targets with upcoming packaging waste regulations. They want permission to use recyclates containing legacy additives in controlled loops. They seek guarantees that municipal waste streams are classified as non-hazardous.123
Why — This allows companies to use existing recycled materials and reduces regulatory compliance costs.4
Impact — Environmental groups lose protections against the re-circulation of hazardous legacy chemicals in products.5
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Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

2 May 2023 · Discussion and policy paper handover: need for standards, consideration of derogrations for SME producers.

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

2 May 2023 · Discussion and follow up on proposed amendments

EuPC calls for harmonized rules and realistic recycling targets

21 Apr 2023
Topic — The European Commission is reviewing rules to reduce packaging waste and improve recycling.
Message — The association supports a unified EU law to prevent conflicting national rules. They want recycled content calculated as a yearly average to help businesses adapt. They also request a safety net for potential shortages of recycled materials.123
Why — These changes would reduce administrative costs and provide flexibility during material shortages.45
Impact — National governments lose the ability to set stricter environmental rules for their markets.6
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Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL and

9 Mar 2023 · PPWR

Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

PET Sheet Europe represents its members who are among the European PET Sheet converters. PET Sheet Europe is a sub-sector group of European Plastic Converters Association (EuPC) We welcome the European Commission’s plan to update food-contact plastic regulations and are grateful for the opportunity to respond with some member’s perspective and some concerns. PET Sheet Europe’s specific focus of response involves key importance of functional barrier for PET sheet converters. We intend to cover our perspective and concerns along the following: - How this regulation applies to functional barrier in PET sheet applications as post-processing step widely used in the EU and the rest of the world to produce recycled PET food packaging The following attached is content in support of the response of PET Sheet Europe and some members. PET Sheet Europe contact: John Sewell, Secretary General PET Sheet Europe, +32.496.255.640, john.sewell@pceu.eu
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Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager)

23 Nov 2021 · draft State Aid Guidelines on Climate, environmental protection and Energy

European Plastics Converters call for efficient standards and SME support

9 Aug 2021
Topic — This consultation addresses challenges in the European standardisation system for green and digital transitions.
Message — The association suggests using the Circular Plastics Alliance as a model for setting standardisation priorities through dialogue. They request a more agile and efficient process that delivers results in a timely manner. They also urge bodies to make it easier for small businesses to participate.123
Why — Streamlining the process would help the industry reach recycling targets while reducing costs for small businesses.45
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Meeting with Barbara Herbolzheimer (Cabinet of Commissioner Johannes Hahn), Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

2 Oct 2020 · European Green Deal, MFF negotiations and own resources

Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · COVID 19 economic impact on Energy intensive industries

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

ABOUT EUPC European Plastics Converters (EuPC) is the leading EU-level trade association, based in Brussels, representing European plastics converting companies. Plastics converters use plastics raw materials and recycled polymers to manufacture new products, which are purchased preferably in Europe or outside the Single Market. EuPC totals about 45 national as well as European plastics converting industry associations and represents more than 50,000 companies, producing over 50 million tons of plastic products every year. The European plastics industry makes a significant contribution to the welfare in Europe by enabling innovation, creating quality of life to citizens and facilitating resource efficiency and climate protection. More than 1.6 million people are working in EU converting companies (mainly SMEs) to create a turnover in excess of € 260 billion per year. Since its creation, EuPC has always been a great supporter of the EU initiatives for the industry and for the protection of the environment, those that reflect a true European vision. REASONING European Plastics Converters welcome the initiative of the European Commission to ensure a level playing field between European and non-European companies. Europe’s efforts to go climate-neutral by 2050 cannot be undermined by lack of ambition by other companies and countries around the world, especially looking at the International agreements we are bound and the need to truly protect our Environment. Hence, a new carbon border adjustment (CBA) mechanism that can impose direct and indirect carbon cost to importers similar to the cost already charged to European manufacturers would restore a level playing field on the European market. This will in turn create an incentive for importers to adopt climate policies in their own countries and allow the carbon content of products to be better reflected for the final customer, providing a more efficient and powerful signal for consumption and behavioural changes. For the European plastics industry, this is particularly relevant because the high quality of production, safety requirements (for workers, for the environment, for users…) and sophistication of production render it quite costly, especially when compared with competitors based in neighbouring or Asian countries. Reducing carbon emissions in line with the Paris Agreement will involve further investment and performance improvement that would make plastic manufacturing increasingly expensive in Europe. If this virtuosity is thwarted by imported raw materials and finished products with no carbon emissions’ compensation mechanism, this will nullify by default all European efforts. As said, the need to apply a level playing field and use a CBA, as proposed by the European Commission, is necessary for both raw materials as well as semi-finished and finished products. Otherwise, we wonder how a European company can compete in the global arena without having a legal protection from unfair and polluting counterparties. FINAL COMMENT In the light of the above exposed arguments, EuPC believes that a CBA mechanism must be applied to ensure there is no carbon leakage and to integrate the existing trade defence tools the EU has in place. Europe is ambitious in its green activities and, thanks to the Climate Deal and related Communications, is setting a higher benchmark for all European and non-European industries.
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Response to Commission Regulation amending Annex XIV to REACH

22 May 2019

EuPC , the European Plastics Converters association, calls The European Commission to exclude the ADCA from the annex XIV as authorization is not a proportionate risk management option and alternative regulatory options, should be investigated. The two alternative options are: 1) The introduction of an Occupation exposure limit under the CAD (beginning with the UK level as reference); 2) The inclusion of ADCA in annex XVII of REACH, by setting a Reference Maximum Inhalation Exposure Value to be met at workplaces. The procedure followed by the Commission is an irregular implementation the REACH regulation (articles 57.f and 58.8 regarding identification and inclusion of substances of very high concern in the annex XIV), latest case law (European Court of justice case C323-15P and C324-15P) and the article 5 of the Treaty on the European Union (proportionality) in isolation and in conjunction. EuPC calls on the Commission to withdraw the current draft decision adding substances to the annex XIV enabling for a separate assessment and vote to be made for individual substances of equivalent concern, in this case ADCA. Otherwise, the risk is that the Commission decision for the whole list would later on be cancelled. At the same time, EuPC calls on the Commission to adequately justify and separately assess whether ADCA should be subject to authorization. In case the Commission decides anyhow to submit its regulation to vote, EuPC calls on Member States to reject it as a whole. ADCA is a blowing agent widely used in the plastics industry. It is estimated that in Europe between 2 and 3 million tonnes of plastics products are foamed with ADCA, covering different sectors: building and construction, automotive and consumer products. Updated information on the use of ADCA in the plastics sector, medical data, exposure and impacts of the proposed measure may be found in the appended report. Strong new evidence suggests that ADCA is not a respiratory allergen (see report). Moreover, according to the European Court of Justice, the classification in itself (which already in this case is questionable) is not a sufficient condition to identify a substance as of an equivalent level of concern. Instead a multistep case by case assessment should be undertaken. In January 2019, a retrospective medical survey was carried out among the companies using ADCA in the plastics sector, referring to the last 20 years and with a coverage of about 21% of converters and about 9% of formulators and compounders in the EU. As a result, one case of occupational asthma was found, even though the occupational nature of this case still remains uncertain. Considering official statistics at national level, two additional cases of occupational asthma were found, but due to the lack of detailed information related to these case reports it is not sure whether the cause of these asthma cases are related to ADCA exposure. These findings suggest that, in the plastics sector where ADCA is used, the risk of exposure is adequately controlled. The EuPC survey confirmed that the occupational exposure limits set in the UK and Finland are met across Europe even without mask. Moreover, in 2014, the industry has published best practices which have been widely distributed in the sector to further minimize exposure. The inclusion of ADCA in Annex XIV would immediately cause the loss of 4,000-6,350 jobs across the supply chain within the EU and a revenue loss of € 1.3-2.2 billion expressed as yearly turnover (mainly through companies delocalizing their production lines outside Europe, at least partially). At the same time, a non-use scenario (authorisation not granted) would cause a job loss of 17,400-17,900 workers and a revenue loss of € 3.4-3.5 billion expressed as yearly turnover. In view, of the presented evidence we therefore ask this substance to be removed from the current draft annex XIV and more appropriate risk management options to be considered instead.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

7 Feb 2019

Please refer to the appended position paper for a better explanation of arguments and background. The new classification proposal of TiO2 is neither an efficient, nor a proportionate risk management option and therefore infringes the Principle of proportionality. Certain hazards cannot be addressed by classification and labelling, particularly where they relate to a mere physical form rather than to the chemical nature of a substance. The proposed classification is indeed based only on a non-substance specific dust effect. Such effect has only been observed with one laboratory animal species at high doses and not been observed in workers involved in the manufacturing of TIO2. Exposure to TIO2 dust would typically apply in the workplace, for which national OELs are already in place in a majority of Member States. EU workers are protected by occupational health regulations against dust. If dust effects were to be included into CLP, the scope of what could be classified and labelled will be considerably extended with an automatic domino effect on many other legislations. Classification would then greatly increase the amount of hazardous waste (600-700 kT for plastics), which would burden both plastic producers, downstream users, waste owners and recyclers. This classification will create uncertainty at consumer level where no exposure to dust is expected from plastics article and pressure for substitution (even a limited switch will cause damages in the supply chain : e.g. 5% of the turnover related to plastics articles containing TIO2 is already 13,5 billion € and 1% loss of employment 15,000 workers). A labelling of all titanium dioxide-containing products will lead to label fatigue, to the detriment of consumer protection and against the intention of the regulation to properly inform on hazard. CLP would lose its credibility to convey the right message on hazard. In light of the above, we suggest the European Commission to investigate into other more proportionate and efficient regulatory options. Should the authorities decide to proceed with the proposed measure in spite of the above we would like to make the following comment. The foreseen annex VI note 10 include the following derogation: “The classification as a carcinogen by inhalation applies only to mixtures p It is clear that the intention of this note is to exclude powders containing less than 1% TIO2 particles with an aerodynamic diameter ≤ 10 μm from classification as only those particles would be respirable. However, the text does not define what a powder is. As of when will a polymer/masterbatch/recyclate be considered a powder? We would therefore ask the EC to provide a definition of powder. Such reference exist in standard ISO 3252 on powder metallurgy defining powder as “an assembly of discrete particles usually less than 1 mm in size” Adding this definition could to a certain extent decrease the uncertainty on waste classification, since wastes are usually not powders. Also, literally read, the text could be interpreted that plastics powders with particles of a diameter of 500 µm, but containing dispersed TIO2 in a size inferior to 10 µm (which is generally the case for pigments) encapsulated in the plastics matrix , should be classified. We do not think this is the intention, but would recommend clarifying the text as follows: “The classification as a carcinogen by inhalation applies only to mixtures placed on the market in powder form containing 1% or more of titanium dioxide particles with an aerodynamic diameter ≤ 10 μm unless they are bound in matrices such as metals in massive form, alloys, mixtures containing polymers, mixtures containing elastomers . Or alternatively “The classification as a carcinogen by inhalation applies only to mixtures placed on the market in powder form containing 1% or more of titanium dioxide particles with diameter ≤ 10 μm not bound into a matrix.
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

5 Feb 2019 · Plastics Strategy

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and European Tyre & Rubber Manufacturers' Association and Environmental Resources Management

14 Jan 2019 · listing of ADCA in Annex XIV of REACH

Response to Reducing marine litter: action on single use plastics and fishing gear

23 Jul 2018

European Plastics Converters welcome this opportunity and present their comments in the attached file.
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Meeting with Vytenis Andriukaitis (Commissioner) and

15 Jun 2018 · HTA

Meeting with Elżbieta Bieńkowska (Commissioner) and

25 May 2018 · Exchange of views on current topics

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

11 Apr 2016 · Trade Defence Instruments

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

27 Oct 2015 · Presentation of the sector, availability of polymers, circular economy, French legislation on plastic carrier bags.

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

11 Jun 2015 · Duty free imports of two types of plastics

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and Plastics Recyclers Europe

25 Feb 2015 · Circular Economy

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen)

18 Feb 2015 · Skills

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

15 Dec 2014 · Plastic carrier bags