PET EUROPE - Producers' Association aisbl

PET EUROPE

PET EUROPE is a European non-profit trade association based in Brussels.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

PET EUROPE outlines key recommendations to ensure that the CEA reinforces Europes circular leadership and industrial resilience. The association calls for measures to foster market demand for high-quality, strengthen trade and market-defence tools to maintain a level playing field, and align EPR and recycled-content policies with Europes production and investment objectives. By embedding these priorities, the Circular Economy Act can safeguard Europes PET value chain as a cornerstone of a sustainable, competitive, and autonomous circular economy.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

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 identified certain provisions where further clarification or improvements would be beneficial to support consistent interpretation and effective enforcement. Please find attached PET EUROPEs feedback in response to the public consultation on the EU rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles.
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Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

PET EUROPE welcomes the opportunity to offer comments on the Commission's 18th Amendment to Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food. Representing virgin PET pellet producers and the Flake Injection (FI) Consortium, we appreciate further dialogue on this matter. Our feedback emphasizes the need for discussions with starting material producers to assess the feasibility and practicality of additional high purity requirements.
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Response to Measures to reduce microplastic pollution

16 Jan 2024

PET EUROPE supports the Commission's measures to reduce microplastic pollution but urges the inclusion of third-party importers in the scope of regulation, ensuring a fair and comprehensive framework for all market participants. PET EUROPE highlights pollution risks from non-EU producers. The association recommends aligning plastic pellet definitions with REACH regulations, establishing clear reporting cut-off points, harmonizing methodologies, and specifying the responsibilities of transport companies and calls for incorporating audits and certifications related to pellet loss within ISO 14001.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

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 an industry with a capacity of 3.5 million tonnes of Virgin PET (vPET) per year. European Terephthalic Acid (PTA) producers are associate members. PET EUROPE supports sustainable growth of PET manufacturing in Europe and welcomes the implementation of rules for the calculation, verification and reporting of the recycled content targets introduced by Directive (EU) 2019/904 on Single-Use Plastics (SUPD). Considering the current consultation for the draft implementing decision, PET Europe have provided some comment and observations in the attached file for the Commission to consider.
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Meeting with Marco Campomenosi (Member of the European Parliament)

15 Mar 2023 · Online meeting with PET Europe

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Sept 2021 · Introduction to the activities of the Committee and latest developments

Response to Revision of EU rules on food contact materials

27 Jan 2021

Please see attached file. If needed this can be provided in word format.
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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

The Committee of PET Manufacturers in Europe (CPME) is a European non-profit trade association based in Brussels. It represents all of the European poly ethyleneterephthalate (PET) resin producers who are collectively responsible for more than 3.3 million tonnes of European PET Resin production. We disagree with the proposals to classify titanium dioxide (TiO2) and request that it is removed from the 14th adaptation to technical and scientific progress (ATP). The adoption of the 14th ATP of the CLP can continue as scheduled without TiO2 while the open regulatory and legal questions are clarified to allow full consideration of the alternative regulatory options. According to the EU proportionality Principle there is a requirement that the Commission choose the least onerous regulatory measure to achieve the objective pursued. In the case of TiO2 and other poorly soluble low toxicity substances (PSLTs), alternative regulatory options are available which would address the potential particle inhalation concerns more effectively and proportionally and would provide the essential protection for users of encapsulated TiO2. Such measure could be the setting of a binding EU OEL. If a binding OEL was agreed, the issues laid out below could be disregarded. TiO2 is used as an opacifier in PET packaging and is essential for personal care and dairy based products. The Market for white PET is 150,000 tons/annum and is ~5% of the PET resin market. PET is the most recycled packaging resin in Europe. If this classification goes ahead PET post-consumer bottles containing more than 1% of TiO2 could be classified as hazardous under the EU waste legislation. This will threaten EU based recovery targets for the PET industry and may well have an adverse effect on the Circular Economy ambitions for the EU. Additionally, the classification of TiO2 could have a negative or at least ambiguous effect on the status of waste (hazardous/non-hazardous) under the Waste Framework Directive, which could have a negative impact on the recycling of this material within the EU. TiO2 has been approved for use in food contact materials and evidence from EFSA https://www.efsa.europa.eu/en/efsajournal/pub/2641 clearly demonstrate that fully encapsulated (nano) particles are completely safe for use in food contact materials. Of course, it is impossible to inhale encapsulated (TiO2) particles. The proposed classification has a very high potential to harm the perception of PET as a packaging material and could result in a consumer ban on PET containing TiO2 in toys and food contact materials although the hazard is not presented as encapsulated TiO2 cannot be inhaled. The supply chain pressure towards avoidance of TiO2 is likely to lead to badly affect the PET industry and will adversely affect the performance of any replacement plastic products as they will have a worse performance. Such a worse performance can include reduction of the time before a food that currently benefits from the protective function of the plastic packaging is kept from spoiling, as TiO2 protects produce from harmful UV radiation. Therefore, the classification can have an impact on food security of the EU. There are only a very small number of replacements for TIO2, which are all inferior in terms of their ability to opacify PET, provide UV resistance, and/or migration into food. Furthermore, these may be considered to be PSLT in the future and classified accordingly which would effectively remove our ability to trade in opaque PET. 1 Customers of PET producers (recyclers and virgin) may set specifications that go beyond legal requirements and there are examples of specifications that state that CMR class 1 or 2 substances are not allowed. Such specifications typically do not regard nuancing notes that are included in the CLP legislation.
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