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Fair Resource Foundation

FRF

Fair Resource Foundation maakt zich hard voor systeemveranderingen die leiden tot een sterke reductie van het verbruik van grondstoffen en die helpen de negatieve (milieu)impact ervan te minimaliseren.

Lobbying Activity

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

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 effective, the methodology must be both reliable and transparent, with clear rules that reduce reliance on virgin plastics and ensure fair competition between different recycling technologies. It is important that the interests of petrochemical industry that is heavily investing in chemical recycling are not prioritised over robust environmental legislation. In line with the analysis of the Rethink Plastic Alliance, which we support, we underline several concerns: The proposal goes beyond the mandate of the Single-Use Plastics Directive by creating new categories such as dual-use outputs and by allowing recycled content claims without evidence that the material re-enters plastics production. Recycled content targets should be met solely with post-consumer waste. Pre-consumer waste, even when mixed with post-consumer fractions or primary raw materials, should not be counted. Dual-use outputs should be excluded, since only outputs that are actually reprocessed into materials serve the Directives objectives. To secure credibility, segregation and controlled blending must be prioritised. Where mass balance is used, only proportional allocation should be permitted. Verification and certification of recycling technologies must be robust and consistent. Chemical recycling should not be recognised unless EU-wide sustainability criteria for recycling technologies are established. More detailed arguments and technical evidence are set out in the submission of the Rethink Plastic Alliance, to which we refer for additional context and justification.
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Meeting with Mohammed Chahim (Member of the European Parliament)

29 Mar 2023 · PPWR

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

8 Nov 2022 · Implementation of circular economy and the revision of EU packaging rules