OpenLobby.EU
Explore

Plastics Recyclers Europe

PRE

Plastics Recyclers Europe promotes plastics recycling and works to create conditions for profitable and sustainable recycling businesses.

Lobbying Activity

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

5 Dec 2025 · End-of-Life Vehicles Regulation

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union)

20 Nov 2025 · Creation of codes for recycled polymers

Meeting with César Luena (Member of the European Parliament)

6 Nov 2025 · Current situation of the plastic recycling sector

Plastics Recyclers Europe urges EU to protect domestic recycling from unfair imports

5 Nov 2025
Topic — New EU Circular Economy Act aims to boost recycled material use to 24% by 2030.
Message — The organization requests expanded recycled content targets across sectors, stronger import controls with dedicated customs codes for recyclates, and harmonized end-of-waste rules to enable cross-border trade. They argue current market distortions and regulatory fragmentation threaten the sector's viability.123
Why — This would protect them from low-cost imports and stabilize demand for their products.456
Impact — Non-EU recyclate producers lose market access through stricter import standards and tariffs.78
Read full response

Meeting with Jessika Roswall (Commissioner) and

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

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

16 Oct 2025 · EU-Plastics Recyclers Europe on safeguarding Europe’s plastic recycling sector

Meeting with Jeannette Baljeu (Member of the European Parliament)

16 Oct 2025 · Recycling

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

8 Oct 2025 · ELVR

Meeting with Paul Speight (Head of Unit Environment)

3 Oct 2025 · Reach Revision

Meeting with Ana Vasconcelos (Member of the European Parliament)

30 Sept 2025 · Plastic recycling

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.

Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

4 Sept 2025 · Market outlook and challenges facing the plastics recycling industry in Europe.

Plastics Recyclers Europe urges stricter rules for recycled content

19 Aug 2025
Topic — The consultation establishes rules for reporting recycled plastic content in beverage bottles.
Message — PRE calls for EU-based auditors and protecting European waste markets. They also want to eliminate administrative duplication and prioritize mechanical recycling.12
Why — These measures would protect European recyclers from unfair competition and lower administrative burdens.3
Impact — Chemical recycling firms lose out as waste is prioritized for mechanical recycling processes.4
Read full response

Meeting with Eric Mamer (Director-General Environment) and

22 Jul 2025 · Exchange of views on the future of the European Plastic Recycling Sector: actions towards circularity

Plastics Recyclers Europe seeks inclusion in industrial decarbonisation act

8 Jul 2025
Topic — The initiative aims to stimulate industrial investments and accelerate European decarbonisation.
Message — The group requests extending the scope of the act to include plastics recycling. They call for streamlined permitting and public procurement that prioritises EU-made recycled plastics.123
Why — These measures would lower energy costs and eliminate permitting bottlenecks for infrastructure deployment.45
Impact — Foreign exporters lose out because their products must meet equivalent sustainability standards.6
Read full response

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Vita Jukne (Cabinet of Commissioner Jessika Roswall)

23 Jun 2025 · The upcoming Circular Economy Act, enforcement of environmental legislation; simplification (together with Cab Ribera)

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 Cristina-Adriana Vasile (Head of Unit Trade)

20 May 2025 · Situation of the EU plastics recycling industry; Packaging and Packaging Waste Regulation (PPWR)

Meeting with Jessika Roswall (Commissioner) and

15 May 2025 · State of European plastics recycling market

Response to Shipments of waste - systems interoperation for electronic submission and exchange of information and documents

28 Mar 2025

Plastics Recyclers Europe (PRE) welcomes the European Commissions draft Implementing Regulation under the Waste Shipment Regulation (Regulation (EU) 2024/1157), which sets out technical and organisational requirements for the electronic submission and exchange of information and documents related to waste shipments. This initiative holds high and much-needed potential to modernise waste shipment procedures, enhance traceability, and reduce administrative burdens across the EU. The plastics recycling industry depends on an efficient, reliable and transparent regulatory framework for the shipment of waste and secondary raw materials. As the sector operates across borders and in a highly regulated environment, a harmonised digital system is a logical and important step forward. PRE supports the Commissions objectives to reduce fragmentation, improve compliance, and facilitate enforcement through a centralised platform that is fully interoperable with national systems. However, the success of this system will depend on the practicality of its implementation. The regulation must consider the varying levels of digital maturity across Member States, the diversity of systems in use today, and the operational capacities of recyclers. Ensuring smooth interoperability between the EU central system and national/local systems is critical. Without full compatibility, operators may face duplicative data entry, inconsistent requirements, or processing delaysoutcomes that would undermine the regulations objectives. It is equally important that the system is accessible and user-friendly. While larger operators may have in-house compliance and IT resources, many recyclers, especially small and medium-sized enterprises, rely on simpler, manual processes. These users will require a clear, intuitive interface, backed by guidance, training materials, and dedicated support during rollout. A balance must be found between digital ambition and operational reality to ensure all recyclers can comply without disproportionate effort or cost. The implementation should also reflect the need for flexibility and responsiveness. Waste shipments, particularly in plastics recycling, often involve frequent updates or changes to planned movements. The system should accommodate modifications and corrections without requiring full resubmission or creating bottlenecks. Similarly, timely responses from competent authoritieswithin clear and predictable timeframeswill be essential to prevent delays in the shipment process. Finally, PRE underlines the importance of data protection and confidentiality. The system will handle a wide range of commercial and operational information. Strong safeguards must be in place to prevent misuse or unauthorised access, and users should be able to flag sensitive information where appropriate. Clarity is also needed on who can access which data, and under what conditions, including authorities, carriers, and downstream actors. In conclusion, PRE supports the overall direction of the implementing act and recognises its potential to support the circular economy by improving the functionality and efficiency of waste shipments in Europe. PRE remains available to contribute further as implementation progresses.
Read full response

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union)

27 Mar 2025 · Role of the CN codes under the Packaging and Packaging Waste Regulation (PPWR)

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Plastics Recyclers Europe (PRE), the voice of the European plastics recycling industry - a growing sector with over 9.1 billion in turnover and 13.2 million tonnes of installed recycling capacity - supports the Net Zero Industry Act (NZIA) as a pivotal legislative framework designed to expedite the transition towards a climate-neutral economy by promoting strategic clean technologies. While the act emphasizes renewable energy, hydrogen, carbon capture, and energy storage, it currently omits plastic recycling as a recognized net-zero technology. Given that plastic recycling significantly reduces CO emissions, bolsters circular economy initiatives, and decreases reliance on fossil-based virgin plastics, it is imperative to include it in the Annex of NZIA. Positive impacts of inclusion of recycling technologies in NZIA: Incorporating plastic recycling into the NZIA aligns with the European Union's broader objectives under the Circular Economy Action Plan, which emphasizes waste reduction and resource efficiency while strengthening Europes industrial resilience. The inclusion of plastic recycling into the Annex of the Regulation will: · Create Green Jobs: The recycling sector is labour-intensive and has the potential to generate thousands of jobs in waste collection, processing, and secondary material markets. · Enhance Industrial Competitiveness: By supporting European recyclers, the EU can reduce reliance on imported raw materials, fostering self-sufficiency in manufacturing supply chains. · Encourage Innovation: The speed at which technological innovation or advancement is occurring is mainly dependent on the availability of capital. In that regard, will allow recycling companies to easily apply for projects and have access to more funds, which will further promote innovation in the recycling sector, which is already at the heart of the Circular Economy. Addressing Current Market Challenges: The plastic recycling industry faces significant challenges that threaten its development and capacity to meet recycling targets: · Influx of Imported Recyclates: Non-EU countries, benefiting from lower environmental, labour, and energy costs, create unfair competition. · Decline in Demand: Low virgin plastic prices and reduced EU industrial production have destabilized the market. · High Energy Costs: Price volatility further weakens the competitiveness of EU recyclers. The industry invested 1 billion in 2022, however, these investments were halved in 2023 due to current market conditions. Further innovation and investments are crucial to improve the quality and volumes of recycled materials needed for the transition towards a circular economy and achieving the EU targets. Allowing Member States to set up regulatory sandboxes to test innovative recycling technologies under flexible regulatory conditions would be a significant step for the EUs circular economy. Conclusion: To fully leverage the benefits of plastic recycling, the European Commission should explicitly recognize plastic recycling as a strategic net-zero industry to encourage investments in new recycling facilities and scaling up the existing recycling capacity. Plastic recycling is a vital component of the EUs net-zero and circular economy ambitions. By including it in the NZIA annex, the European Union can drive significant emissions reductions, reduce fossil fuel dependency, and bolster economic resilience. Strategic support for recycling technologies will not only strengthen Europes climate commitments but also create economic opportunities and sustainable industrial practices.
Read full response

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

20 Feb 2025 · Plastpellets

Meeting with Aurel Ciobanu-Dordea (Director Environment) and European Recycling Industries' Confederation and FEAD

13 Feb 2025 · Exchange of views on increasing the competitiveness of EU plastic recycling industry

Plastics Recyclers Europe Urges Harmonised Waste Management Rules

30 Jan 2025
Topic — This initiative seeks to deepen the single market for services and goods across Europe.
Message — The organization requests EU-wide end-of-waste criteria to remove legal uncertainty. They seek standardised documentation and digitised authorisations to streamline cross-border procedures.12
Why — Unified rules would ensure the competitiveness of the sector and reduce administrative burdens.34
Impact — Exporters from non-EU countries would lose competitive advantages from their lower environmental costs.5
Read full response

Meeting with Michele Piergiovanni (Acting Director Competition)

30 Jan 2025 · Discuss an industry call for Safeguarding the Competitiveness of the European Plastic Value Chain

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

30 Jan 2025 · End-of-Life Vehicles

Meeting with Jonas Sjöstedt (Member of the European Parliament, Shadow rapporteur) and Halte à l'obsolescence programmée (HOP)

29 Jan 2025 · End of Life Vehicles

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

Plastics Recyclers Europe (PRE), the organization representing European plastics recyclers, supports the Digital Product Passport (DPP) as a critical tool to enhance transparency in product sustainability under the ESPR. However, to ensure that plastics circularity can effectively benefit from the DPP, PRE would like to highlight key issues that need to be addressed during the design of the secondary legislation. Plastic recyclers typically process batches of sorted plastic waste, containing a wide variety of articles from diverse waste streams. By the time these materials reach recycling facilities, they are often compressed, shredded, or otherwise damaged. In most cases, individual items are not identifiable or separable within the batch. The high-speed sorting processes used in recycling facilities, which handle several tons of material per hour, rely on automated technologies that separate plastics based on properties like polymer type, density, or size. Therefore, it is not possible to look at and scan each items digital passport code, since this step is not compatible with the recycling processes separating plastics from contaminants and different polymers, since these processes occur very rapidly, with throughputs of several tons per hour. In this context, the provision in Article 7(5)(c), which requires that the information included in the DPP encompass the concentration, maximum concentration, or concentration range of the substances of concern, at the level of the product, its main components, or spare parts presents a challenge for recycling. While the availability of chemical information is highly relevant, this data is unlikely to be accessible or applicable at the recycling stage in a manner compatible with existing processes. The challenges arise from the aggregated nature of waste streams and the pace of operations, which make it impractical to access detailed chemical composition information for individual items or components. Similarly, Article 9 which outlines the general requirements for the DPP, specifies that the information included must refer either the product, model, batch, or item. While this framework provides flexibility in theory, it does not adequately address the practical realities faced by recyclers. Given the diverse range of articles contained in a single batch of plastic waste and the limitations of current recycling processes, it is impossible to individually scan or identify each article. If the DPP is to serve as a meaningful tool for recyclers, it must be designed to accommodate the complexities of batch-level processing and provide data in a format that can be utilized without requiring individual article scanning. PRE would also like to raise concerns about the feasibility of implementing a DPP that can be applied uniformly across the industry without creating competitive disparities between different stakeholders. Smaller recyclers may face significant resource constraints in meeting the technical and administrative requirements compared to larger recyclers with more capacity to invest in compliance systems. Similarly, differences in technological infrastructure and expertise between EU Member States could lead to a fragmented implementation. To ensure a level playing field, it is essential that the DPP framework is designed to minimize administrative burdens, provide scalable solutions, and include support mechanisms. To address these concerns, it is crucial to ensure that the DPP is designed in a way that aligns with the operational reality of plastic recycling. Information on chemicals and materials must be provided in formats compatible with automated technologies and accessible at the batch level rather than for individual items. Moreover, the implementation of the DPP should include measures to ensure fairness and inclusivity, such as streamlined requirements for smaller companies and equitable support for all Member States.
Read full response

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

19 Nov 2024 · Plastpellets

Meeting with César Luena (Member of the European Parliament, Rapporteur)

23 Oct 2024 · Pellets Regulation

Meeting with Giorgio Gori (Member of the European Parliament) and Euroheat and Power and

18 Sept 2024 · Presentation of priorities

Meeting with András Tivadar Kulja (Member of the European Parliament)

17 Sept 2024 · Plastic recycling

Meeting with Pietro Fiocchi (Member of the European Parliament)

17 Sept 2024 · Recyclage des plastiques

Plastics Recyclers Europe urges higher chemical trace limit

21 Aug 2024
Topic — The initiative sets limit values for the persistent organic pollutant UV-328 in plastics.
Message — They advocate setting the unintentional trace limit for UV-328 at 0.01%. They also request a verified scientific testing methodology for all substances.12
Why — Higher limits allow recyclers to continue operations using current testing technology.34
Read full response

Plastics Recyclers Europe backs carbon capture rules and ETS expansion

15 Jul 2024
Topic — This consultation defines how carbon captured in products counts as permanently stored.
Message — PRE supports rules ensuring captured emissions stay bound in products during use and disposal. They call for prioritizing recycling over carbon-intensive waste management to reduce emissions. Finally, they advocate for expanding the EU ETS to include under-contributing sectors.123
Why — Prioritizing recycling over disposal helps the industry maintain the value of plastic materials.4
Impact — Carbon-intensive waste management operations may lose business to recyclers or face new regulations.5
Read full response

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Plastics Recyclers Europe (PRE) is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high quality material destined for production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy. PRE welcomes the EU's decision to incorporate the Basel Convention's Decision BC-15/18, which amends electrical and electronic waste (e-waste) entries in the Annexes of the Basel Convention. In particular, PRE fully endorsed the Commission's draft Delegated Regulation which would result in a ban on the export of all (e-waste) from EU to non-OECD countries. This measure represents a significant opportunity for the European Union to enhance its strategic autonomy, strengthen the competitiveness of its recycling industry, ensure consistency with the EU legislation and comply with environmentally responsible waste management practices. Please find attached PRE's full feedback to the Commission's Public Consultation on draft amendments to Regulation (EC) No 1013/2006 and Regulation (EU) 2024/1157 on changes on shipments of electrical and electronic waste agreed under the Basel Convention.
Read full response

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

Plastics Recyclers Europe (PRE) is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high quality material destined for production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy. PRE welcomes the EU's decision to incorporate the Basel Convention's Decision BC-15/18, which amends electrical and electronic waste (e-waste) entries in the Annexes of the Basel Convention. In particular, PRE fully endorsed the Commission's draft Delegated Regulation which would result in a ban on the export of all (e-waste) from EU to non-OECD countries. This measure represents a significant opportunity for the European Union to enhance its strategic autonomy, strengthen the competitiveness of its recycling industry, ensure consistency with the EU legislation and comply with environmentally responsible waste management practices. Please find attached PRE's full feedback to the Commission's Public Consultation on draft amendments to Regulation (EC) No 1013/2006 and Regulation (EU) 2024/1157 on changes on shipments of electrical and electronic waste agreed under the Basel Convention.
Read full response

Response to Waste shipments - information on certificates on interim recovery and disposals and non-interim recovery and disposals

24 May 2024

Plastics Recyclers Europe is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high quality material destined for production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy. Plastics Recyclers Europe (PRE) fully endorses the Regulation on waste shipments and the proposed detailed information in certificates for subsequent recovery and disposal operations. We believe this will significantly enhance the transparency, accountability, and sustainability of waste management practices in the EU and beyond. Please find attached PRE's full feedback to the Commission's Public Consultation on the information to be included in certificates on subsequent (non-)interim recovery & disposal operations under the Waste Shipment Regulation.
Read full response

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

15 Apr 2024

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the proposal amending Regulation (EU) No 10/2011 and Regulation (EC) No 2023/2006. The overall aim to align these two legislations with Regulation (EU) No 2022/1616 is greatly beneficial for recyclers to avoid conflicts between legislative requirements. However, the current draft lacks clarity which complexify the interpretation of certain provisions. Overall, PRE agrees with the attempt to align the Regulation (EU) No 10/2011 and Regulation (EC) 2023/2006 with the Regulation (EU) No 2022/1616. Nevertheless, some definitions should be added to clarify the scope of applicability and further improvements of the text should be implemented to clearly distinct what is applicable to recycled plastics in the Regulation (EU) No 10/2011. More information can be found in the attached contribution.
Read full response

Plastics Recyclers Europe Welcomes Proactive BPA Waste Regulation

7 Mar 2024
Topic — EU regulation restricting bisphenol A in materials intended for food contact.
Message — The organization welcomes the proposal as a proactive measure to manage chemicals. They want to address the presence of bisphenols in their waste streams.1
Why — This would improve the quality of recyclers' input waste streams.2
Read full response

Meeting with João Albuquerque (Member of the European Parliament, Rapporteur) and Minderoo Foundation Limited ATF The Minderoo Foundation Trust

15 Jan 2024 · Preventing plastic pellet losses to reduce microplastic pollution

Response to Measures to reduce microplastic pollution

10 Jan 2024

We welcome the European Commission (EC) proposal for a Regulation on preventing plastic pellet losses to reduce microplastics pollution as an opportunity to develop a comprehensive EU framework to tackle microplastics. In the context of the Zero Pollution Ambition, the Circular Economy Action Plan and the EU Plastics Strategy, increasing the capture of microplastics during all relevant stages of plastic products lifecycle is key to achieving the circularity of plastics. Overall, we support the proposal and would like to outline that tackling the pellet losses is a key concern for recyclers, which are committed to further develop and implement measures to prevent microplastics pollution. Harmonised measures throughout the plastics recycling value chain combined with third-party certification is key to control pellet losses and ensure an effective handling by the relevant actors.
Read full response

Response to Persistent organic pollutants - hexabromocyclododecane (HBCDD)

22 Dec 2023

We welcome the proposal to maintain the UTC limit for recycled polystyrene in the production of EPS and XPS insulation material for use in building or civil engineering works. We support this proposal as an example for further ongoing revision of POPs. Taking the recycling approach is finding the best balance between the CO2 savings from the recycling of plastic materials whilst ensuring the protection of the environment and human health.
Read full response

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament, Shadow rapporteur) and Federation of the European Sporting Goods Industry

20 Oct 2023 · Waste Framework Directive revision

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur) and REWE ZENTRALFINANZ eG

13 Sept 2023 · Green Claims Directive

Meeting with Patrizia Toia (Member of the European Parliament, Rapporteur for opinion) and Eastman Chemical Company

14 Jun 2023 · PPWR (meeting held by the APA responsible)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

13 Jun 2023 · Waste Shipment Regulation

Plastics Recyclers Europe demands third-party verification for recycling targets

24 May 2023
Topic — This consultation establishes rules for measuring recycled content in plastic beverage bottles.
Message — The group demands mandatory third-party checks and annual auditing to ensure reporting reliability. They also call for calculation methods that create a level playing field across technologies.123
Why — Mandatory auditing would protect the market position of established high-quality European recyclers.45
Impact — Firms using self-declaration systems would face increased administrative burdens and stricter compliance costs.6
Read full response

Plastics Recyclers Europe supports electricity reform to lower costs

17 May 2023
Topic — The EU is revising electricity market rules to lower prices and increase resilience.
Message — The group supports a legal framework that prevents market failure for energy-intensive industries. They specifically favor measures that reduce costs for distributing energy across Europe.12
Why — Reduced distribution costs would help European plastic recyclers stay competitive in global markets.3
Read full response

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

10 May 2023 · Packaging and packagingwaste

Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur) and The European Federation of Corrugated Board Manufacturers

12 Apr 2023 · Packaging and packaging waste

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

27 Mar 2023 · Construction Products Regulation

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

27 Mar 2023 · Waste Shipment Regulation

Meeting with Ville Niinistö (Member of the European Parliament)

14 Mar 2023 · CRCF (staff level)

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and spiritsEUROPE and

2 Mar 2023 · PPWR

Meeting with Malte Gallée (Member of the European Parliament)

23 Feb 2023 · Plastic recycling in the context of PPWR

Meeting with Patrizia Toia (Member of the European Parliament) and Reusable Packaging Europe

21 Feb 2023 · Packaging and Packaging Waste Regulation (meeting held by the APA responsible)

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Tetra Pak Group and

20 Feb 2023 · PPWR

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Metal Packaging Europe External Affairs ASBL

15 Feb 2023 · Packaging waste

Meeting with Martin Hojsík (Member of the European Parliament)

15 Feb 2023 · PPWR, plastics

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

8 Dec 2022 · Construction Products Directive

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL

7 Dec 2022 · Ecodesign regulation

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur)

10 May 2022 · Waste Shipment Regulation

Meeting with Deirdre Clune (Member of the European Parliament)

22 Feb 2022 · Persistant Organic Pollutants (POPs)

Response to Waste Framework review to reduce waste and the environmental impact of waste management

8 Feb 2022

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the initiative’s objective to harmonise separate waste collection rules at EU level. Our association supports the revision of the Waste Framework Directive (WFD)1 as an opportunity to introduce measures that lead to a clear harmonised distinction between waste as a resource from waste to be disposed of. In this sense, waste reduction measures should be directed towards maximizing re-usability and recyclability while reducing the amount of waste destined to disposal. Please find attached our position paper on the call for evidence for a revision of EU waste framework. Best regards,
Read full response

Response to Measures to reduce microplastic pollution

18 Jan 2022

Please find enclosed the contribution of Plastics Recyclers Europe to the consultation on Microplastics pollution. Best regards,
Read full response

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

14 Jan 2022

We welcome the new Regulation’s scope extension to cover a broad range of recycled plastics and the structural changes that lead to a well-defined approval path for novel recycling processes. The fast-track authorisation process for the suitable technology represents a significant improvement, which would allow the PET industry to reach the recycling targets by further developing the Union’s recycling capacities. Nevertheless, we would like to note that the establishment of a clear framework to demonstrate the suitability of other plastic food contact materials and articles with the authorisation process for novel technologies will also be key to extend the EU recycling capacity. The attached position paper gives comments on the overall document. We remain available to discuss the elements tackled in this position paper with the relevant team at the EC.
Read full response

Response to Update of concentration limit values of persistent organic pollutants in waste

17 Dec 2021

The plastics recycling industry has made vast progress to treat complex waste streams. The processes implemented at the recycler facilities successfully manage to produce recyclates below 500 mg/kg of the sum of the PBDEs. The remaining fraction, containing the concentrate of PBDEs, is to be sent, today, to the disposal route for destruction. PRE truly believes that the mechanical recycling of WEEE and ELV plastics is the best route to ensure that the plastics containing PBDEs are sorted and destroyed accordingly. Consequently, the limit set in Annexes I and IV should facilitate the mechanical recycling route as a solution for the management of plastics containing PBDEs, and in line with the transition to a circular economy. PRE supports the Commission proposal of a limit of 500 mg/kg in Annex IV for the sum of the PBDEs and an alignment with the concentration set out in Annex I, five years after entry into force. However, lowering the threshold below 500mg/kg in Annex I and subsequently in Annex IV is premature. PRE outlines the necessity to maintain the 500mg/kg threshold for a substantial period (e.g., minimum five years) to support the recycler’s activities to further develop processes to treat WEEE and ELV plastics and to encourage the treatment of such plastics within the EU.
Read full response

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Please find attached Plastics Recyclers Europe's feedback to the proposal for a Carbon Border Adjustment Mechanism. Best regards, Soizic Larcher
Read full response

Response to Revision of the Energy Tax Directive

18 Nov 2021

Please find attached Plastics Recyclers Europe's feedback to the revision of the Energy Taxation Directive. Best regards, Soizic Larcher
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

Dear, Please find enclosed the feedback from Plastics Recyclers Europe to the revision of the Effort Sharing Regulation. We remain available to further discuss the elements tackled in our position paper with the relevant team at the European Commission. Best regards,
Read full response

Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Dear, Please find attached the position paper of Plastics Recyclers Europe on the Policy framework on biobased, biodegradable and compostable plastics. Best regards, Soizic Larcher
Read full response

Response to Environmental Implementation Review 2022

18 Oct 2021

PRE participates to this public consultation by underlying how a suboptimal implementation of the EU environmental law led to unharmonized legislations at national level, characterized by different terminologies, which resulted in a fragmented legislative framework, affecting the industry and the market. The below aspects should be addressed by the third EIR package, in line with its objective to improve implementation of the environmental legislation.
Read full response

Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

16 Jun 2021

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the drafted implementing decision laying down rules for the application of Directive (EU) 2019/904 (SUPD) as regards the calculation, verification, and reporting of data on the separate collection of waste single-use plastic beverage bottles. PRE has been continuously advocating for an increased separate collection of plastic waste across EU Member States (MS), as an essential prerequisite to achieve high-quality plastic recycling which is key to the transition to a circular economy. The ambitious targets for separate collection for recycling of waste single-use beverage bottles specified in Article 9 of the SUPD will inevitably require an upgrade of the current collection systems in the EU as well as require clear and harmonized rules on their reporting. Therefore, establishing a common system at the MS level of the calculation and verification on the progress of this target is critical to ensure the same methods are applied across the EU.
Read full response

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Plastics Recyclers Europe (PRE) welcomes the opportunity to give a feedback to the Inception Impact assessment on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals. As an industry association representing plastic recyclers, we are supportive to update the CLP Regulation given more than a decade of scientific and technological progress.
Read full response

Response to Ecodesign and energy labelling working plan 2020-2024

1 Jun 2021

Please refer to attached position paper.
Read full response

Response to Revision of EU rules on food contact materials

29 Jan 2021

Please find enclosed our feedbacks regarding the Revision of EU rules on food contact materials.
Read full response

Response to EU strategy for sustainable textiles

29 Jan 2021

Please find enclosed our feedbacks as regards the EU Strategy for Sustainable textiles.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Plastics Recyclers Europe (PRE) welcomes the publication of the draft delegated act to the EU Taxonomy Regulation as a push towards the development of sustainable industrial practices and the shift to a circular economy. PRE supports the classification of mechanical recycling as part of the technical screening criteria for the manufacture of plastics in the primary form (pellets and flakes), thus being considered as a sustainable industrial practice. Mechanical recycling of plastics is a sustainable economic activity that contributes to climate change mitigation. Valuable plastics materials are recovered and can be used in new secondary products and thereby lead to a decrease in the use of virgin materials. PRE welcomes any further assessment of sustainable industrial practices placing on the market plastics from waste based on key concepts of traceability of waste, replicability of economic/waste management models throughout the Union and based on sustainability principles backed up by third party audited LCAs. PRE is available to further discuss the elements tackled in this position paper with the relevant team. With best regards, The PRE Advocacy Team
Read full response

Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

Plastics Recyclers Europe (PRE) represents the interest of the plastics recycling industry. Several of PRE members are specialized in treating the shredder light fraction resulting from the ELV treatment to produce plastics recyclate for use in the traditional plastics compounding and converting industries. A fraction of this material is already being used in the automotive supply chain. It is with great interest that we read the inception impact assessment. In our response we will provide suggestions on how to improve collection of ELV, and why this would be beneficial to increase the recycling activity, we will provide suggestions for improvements in ELV treatment, comment on recycling targets, and suggestions for a system to define recycled content targets. These comments are a start, and we would be available to provide more in later stages. Furthermore, we would be happy to facilitate contact between any desk officers and/or consultants to our members for the impact assessment. In summary: • A reimbursement should be provided to last holder of a vehicle, to address the proper end-of-life treatment of vehicles and to remedy the “missing vehicle” issue. • Delegated power should be given to the European Commission to amend the provisions on treatment to ensure separate collection of certain parts for recycling. • Recycling targets should be set for thermoplastic material • Overall vehicle recycled content levels may be set, but this must be complemented by a procedure whereby the European Commission is given delegated power to set recycled content requirements per specific vehicle components. Please find attached paper for greater detail.
Read full response

Response to Sustainable Products Initiative

12 Nov 2020

Please see enclosed file.
Read full response

Response to EU rules on transboundary waste shipments – update concerning plastic wastes

22 Jul 2020

Plastics Recyclers Europe (PRE) is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high quality material destined for production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy. Plastics recycling in Europe is a rapidly growing sector representing €3bn in turnover. PRE wishes to welcome the delegated act amending the waste shipment regulation and commends the preciseness of entries in continuation of the current routine for plastics waste shipments inside of the EU. Linear adoption of the Basel Convention entries into the WSR, would cause a massive increase in the administrative burden for both recyclers and governments, while within the EU there is a broadly equivalent high level of environmentally sound management in the member states. With regards to the shipments to and from the EU of plastics waste we are understanding of the fact that this needs to be more restrictive than the status quo in light of the severe negative environmental impact observed in developing countries that continue to be burdened by the export of poorly sorted plastics waste into their territories.
Read full response

Meeting with Virginijus Sinkevičius (Commissioner) and

22 Jul 2020 · To discuss Circular Economy Action Plan, in particular issues and future initiatives related to plastic recycling.

Response to EU Standard for Green Bond

14 Jul 2020

Plastics Recyclers Europe (PRE), the Brussels-based leading association representing the plastic recycling industry, welcomes the proposal to constitute an EU Green Bond Standard as a key element to address and deliver the goal of the Green Deal, the targets of the Circular Economy Action Plan and the objectives of the Strategy for Plastics in the Circular Economy. To be successful and a leading example for other economies, the EU Taxonomy Regulation, as it is already planned, should be read as defining those industry and economic sectors that can benefit from such Green Bonds. The Green Deal objective, to cut CO2 emissions by 2050 making the EU economy carbon neutral, and the global climate ambitions to cut GHG emissions, can be achieved thanks to these economic and financial aids in support of industries playing a relevant role in the transition from a linear to a circular economy. The economic and industrial activities that were investigated by the TEG Report in support to the EU Taxonomy Regulation, should become the pillars for green investments. For each of these activities, CO2 emissions savings should be evidence-based assessed and scored according to the most valuable impacts. This methodology, if applied and harmonised at Union level first, and then absorbed in the functioning of economies third to the EU, could play a relevant role in the future of circularity of plastics and green transition.
Read full response

Response to Chemicals strategy for sustainability

16 Jun 2020

Plastics Recyclers Europe is an association representing the interests of plastics recyclers in the broadest sense. In the context of chemicals legislation our members are on the edge of the waste-product framework by purchasing waste and placing a product compliant with the product legislative framework on the market. As such we welcome especially the due attention for the interface between the chemical, product and waste legislation. We remain available to public authorities to provide our knowledge and expertise on this matter and would welcome being consulted on this.
Read full response

Response to RoHS exemption for cadmium and lead in electrical and electronic windows and doors containing recovered PVC

27 Sept 2019

Plastics Recyclers Europe (PRE) fully supports the proposed alignment of the RoHS Directive with the proposed REACH Restriction on Lead and the existing REACH Restriction on Cadmium. It has indeed been shown in the REACH restriction process and through numerous studies that the reintroduction of recycled PVC into the applications in scope has a substantial environmental benefit. The RAC/SEAC Opinion recommend a level of 2% of lead to be allowed in recycled PVC going into the applications in scope, harmonisation with the RoHS directive should maintain this limit to maintain the maximum environmental benefit of the exemption. Especially considering the broader trends of electrification of previously non-electrified articles to achieve the principles of the Internet of Things, meaning that more and more windows and doors will fall within the scope of RoHS in the future. The duration of the exemption should however be set at 15 years to align with the REACH restriction text.
Read full response

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

1 Jun 2018

Plastics Recyclers Europe' feedback can be found in the enclosed file.
Read full response

Response to EMAS SRD in the Electric and Electronic Equipment manufacturing Sector

17 Apr 2018

Plastics Recyclers Europe (PRE) welcomes the proposal for a Commission Decision on ‘a sectoral reference document on best environmental management practices, sector environmental performance indicators and benchmarks of excellence for the electrical and electronic equipment manufacturing sector’ (Ares(2018)1566098). Reusability, reparability, recyclability and a circular design of products, are all elements linked to the sustainability of the life-cycle of EEE products. Better environmental practices must be included in all stages of the manufacturing process and involve the entire value chain. The inclusion of performance indicators on waste recycling rates to evaluate the waste management strategy are welcomed. Nonetheless, the proposed benchmarks for excellence lack in providing a clear differentiation between the recycling of pre and post-consumer waste. BEMPs under 3.3.1. and 3.3.4, promoting the Circular Economy and the use of recyclates at EU level contrast with the environmental performance indicator ‘i33’ under 3.1.10, the waste disposal diversion rate. At PRE, we advocate a satisfactory recycling rate that report with a transparent methodology pre from post-consumer waste. In fact, we advise to differentiate between pre and post-consumer waste in providing for recycled plastic contents in the production of EEE products. This is true also for the environmental performance indicators included under 3.3.4, the calculation of the share for recycled plastics, which should take into consideration the different characteristics between pre and post-consumer waste.
Read full response

Response to Revision of Directive 2000/59/EC on port reception facilities

9 Mar 2018

Plastics Recyclers Europe (PRE) welcomes the Commission proposal to stop littering at sea by including the revision of the Directive on Port Reception Facilities together with the Strategy for Plastics in the Circular Economy. Our feedback is specifically focused on the way to improve the efficacy of the Directive with measures that have been adopted in other legislative instruments of the Waste Package. 1. Targets The circularity of plastics must be understood as the best practice to curb marine pollution, we believe that European ports should make of their waste an inexhaustible resource. Plastic waste collected at sea by fishing and recreational vessels, returned by ships, and recycled in the harbor, provides for a secondary raw material that port authorities could have for free. This could incentivize the developing of new recycled plastic products such as buoys, ropes, fishing nets, floating piers, protecting barriers, and plastic boatyard’s covers, benches and tables, and many other items currently found in ports and marinas. Therefore, the Directive shall incentivize the adoption by European harbors of collection, sorting and recycling facilities. For example, introducing a deposit-return schemes for fishing nets and other plastic items could boost recycling and reuse of these products directly at the port. To this end, deposit-return schemes shall be included in the wordings of the Directive, especially in relation to an exemption from indirect fees. A growing trend for some of the major port authorities in Europe is to qualify their infrastructures, or commission to third parties, the recycling of their waste. We believe that this trend should be incentivized at Union level, by including in the Directive specific targets on recycling: a. Targets on the recycling of waste collected at sea b. Targets on the recyclability of fishing nets. Fishing nets shall all be made by recyclable materials c. Targets on the recycling of fishing nets. Fishing nets shall all become part of a circular, closed-loop, system 2. Green Ship We believe that the Directive should provide a definition of ‘green ship’ by extending such quality to the crew operating the vessel, because technical characteristics alone do not prevent waste entering the sea environment. The definition of ‘green ship’, commonly referred as a vessel that can demonstrate a sustainable waste management on board, should be applied also to vessels that operate in a sustainable manner. In line with Article 9, an additional proof for exemption could be the issuing by the port authority of a ‘green behavior’ certificate for those fishing and recreational vessels engaged in scheduled and frequent traffic. The same provision should be included under Article 8(5), to incentivize the collection of waste at sea through lowered fees and/or exemptions for reiterated good practices. Ex. a fishing vessel that constantly returns waste found at sea to the port reception facilities. 3. Wording in the Directive Whereas the Directive generally includes the principles of the circular economy in its recital, we believe that efforts should be make on weighting the articles and the annexes on recycling and waste hierarchy. In Recital 11, ports shall be obliged to handle waste under Directive 2008/98/EC: “These obligations also apply to the management of waste from ships and handled in port reception facilities”. In Annex I, “The procedure for reception, collection, storage, treatment, preparing for re-use, recycling, and disposal should conform in all respects to an environmental management scheme that follows the principles of the Circular Economy and of the waste hierarchy and is therefore suitable for the progressive reduction of the environmental impact of these activities. […] The procedures for port reception facilities to handle waste should follow the waste hierarchy as by Article 4(1) of Directive 2008/98/EC of the European parliament and of the Council on waste.
Read full response

Response to Review of ecodesign requirements for computers and computer servers

6 Mar 2018

Plastic Recyclers Europe (PRE) welcomes the inception impact assessment on Eco-design and Energy labelling requirements for computers. We are enthusiastic that the improvements of the current legislation and the set initiatives would stimulate economic developments and innovation, as well as strengthen the sustainable society. Considering the wide use of computer devices, the improvement of Ecodesign and Energy-labelling requirements is a key step to reach EU energy efficiency targets. There is a great need for the EU legislation to adapt to the fast-changing technologies of the electronical sector and to tackle the issue of waste accumulation. This can be done by improved legislation on Ecodesign and Energy-labelling that would not only promote energy-efficiency and durability but also reusability and recyclability. Accordingly, PRE is supportive of the third policy option proposing to undertake a combined revision of the Ecodesign and a new Energy labelling regulation; introducing an Energy-label for computers. The revision of the Ecodesign regulation for computers must adapt to current technological advancements while furthering the durability, reparability, reusability, and recyclability requirements. We suggest for recyclability requirements to be enhanced in order to promote (1) design for recyclability and (2) use of recycled materials in computer devices. Recyclability of plastics present in computer devices is of particular importance. While plastic is a material of great utility for many different sectors, its improper end-of-life management and waste accumulation is problematic. Thus, promoting recycling and use of recycled plastics in computer devices can contribute to efficient waste management. The addition of a new Energy-label for computers is welcome since it will allow consumers to make informed choices when purchasing computers devices. Furthermore, the Energy-label has great potential to contribute to the achievement of the Circular Economy, if it would come to include ambitious criteria on recyclability and the use of recycled material in new computers, hence driving demand for recycled materials. This new Energy-label for computers could take inspiration from other eco-labelling schemes, such as the criteria for the Eco-label covering industrial and institutional laundry detergents. Those include a specific ‘design for recycling criteria’ and provisions on recycled content. PRE would also like to draw attention to the proposition to remove tablets and servers from the scope of the regulation. If the intention of the initiative is to thrive for a more efficient energy scheme, completely excluding tablets and servers appears counter-productive as it is likely to limit incentives for the development of more eco-performant devices. Rather, the legislation could differentiate between computers and tablets since they consume less-energy. Finally, it is our association’s desire to contribute to the improvement of the legislation by providing expertise on plastic recycling. European plastic recycling companies that we represent have their own opinions and views on the recyclability of plastic originating from computers. Together, we can participate to the drafting of options for the improvement of end-of life use of computer devices. Thus, Plastic Recyclers Europe wishes to be part of further developments on this topic.
Read full response

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

25 Feb 2015 · Introductory meeting

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

25 Feb 2015 · Circular Economy package

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Feb 2015 · Circular Economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and European Plastics Converters Association

25 Feb 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

25 Feb 2015 · Circular Economy

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

24 Feb 2015 · Meeting with Antonino Furfari - Plastics recyclers Europe on Circular Economy Plastics Recycling

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

12 Jan 2015 · Circular Economy