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Polyolefin Circular Economy Platform

PCEP

The Polyolefin Circular Economy Platform (PCEP) is a forum for all organisations and stakeholders in the polyolefin value chain to exchange ideas, showcase projects and work together to maximise innovation and value, so advancing the circular economy.

Lobbying Activity

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.

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

19 Aug 2025

The Polyolefin Circular Economy Platform (PCEP) represents stakeholders across the polyolefin value chain, working to advance circularity in the most widely used plastics family. Polyolefins constitute 71.4% of Europes plastic packaging and 71% of plastic waste collected for recycling. They contribute to 84.7% of post-consumer recycled polymer used in European products across sectors, including construction, packaging, agriculture, automotive, and electronics. PCEP welcomes the European Commissions initiative to establish harmonised rules for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles. This is a critical step to support the Single-Use Plastics Directive (SUPD) recycled content targets. Moreover, as the Packaging & Packaging Waste Regulation (PPWR) extends mandatory recycled content requirements to all plastic packaging, the method developed under the SUPD will be widely relevant across the packaging sector. Key messages from PCEP include: - Clear and harmonised rules: Establishment of a consistent, legally certain calculation method, including recognition of chemical recycling via mass balance, is vital to scaling polyolefin recycling. - Complementary recycling technologies: Mechanical and chemical recycling are both essential and complementary for meeting growing demand for high-quality recycled polyolefins. - Market-driven allocation: Market dynamics and Extended Producer Responsibility (EPR) schemes will ensure feedstock flows to the most efficient and cost-effective recycling pathways. - Urgency of adoption: Rapid implementation of the legal framework is necessary to remove barriers to investment, accelerate chemical recycling scale-up, and support EU recycled content targets. Support for legal certainty and mass balance: PCEP endorses the draft Implementing Act clarifying how recycled content from chemical recycling in SUP bottles should be calculated, specifically through a mass balance approach excluding fuel consumption. Since chemical recycling outputs cannot be physically traced to inputs, this approach provides the necessary clarity and certainty. Regulatory certainty is essential for investment and for scaling chemical recycling capacity in Europe. PCEP urges Member States to issue a positive opinion and for the Commission to adopt the Act swiftly. Market dynamics between recycling technologies: While concerns exist that chemical recycling might compete with mechanical recycling by commanding higher prices for recycled content, PCEP stresses that feedstock allocation will be determined by market forces and EPR mechanisms. Feedstock will naturally flow first to the most cost-efficient recycling solutions needed to meet targets. Only when mechanical recycling capacity and markets are saturated will material shift towards chemical recycling. This dynamic ensures complementarity and maximises circularity. Complementary role of chemical recycling in polyolefin circularity: Mechanical recycling remains at the centre of processing polyolefin waste, but a multi-technology approach, including chemical recycling, is required to deliver the necessary high-quality recycled polyolefins. Call for timely adoption: Scaling chemical recycling will take several years. Therefore, immediate legal clarity on recycled content calculation is essential to enable investment decisions. PCEP calls on the Commission and Member States to adopt the Implementing Act before the end of 2025 to ensure timely progress towards achieving EU ambitions for recycled content in plastic packaging.
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

The Polyolefin Circular Economy Platform (PCEP), representing the full polyolefin value chain, welcomes the Commissions initiative to advance innovation and maintain the EU's leadership in the bioeconomy. To be effective, any measures under the Bioeconomy Strategy must recognise the strategic role of bio-based feedstock alongside recycling and carbon capture as enablers of a climate-neutral and circular economy. This recognition should be further reinforced by separate targets, ensuring that each market has a clear understanding of future opportunities. Polyolefins used in packaging, automotive, construction, and more are the most widely produced plastics in Europe. While recycling is essential, material losses and technical limits mean virgin feedstock will always be needed. Using sustainably sourced bio-based feedstock can replace fossil carbon in virgin polyolefins while fitting seamlessly into existing infrastructure. We, therefore, strongly encourage the Commission to: Complement recycled content targets with separate bio-based content targets, especially in sectors such as packaging, vehicles, and construction. This dual approach reflects the need for multiple circular carbon pathways. Acknowledge the role of sustainably sourced bio-based feedstock in industrial decarbonisation. There are mature technologies readily available to replace finite fossil feedstocks with biobased feedstocks within the existing circular infrastructure for polyolefins. That means a perfect fit for the circular economy, as products can be designed from renewable sources to be reusable and recyclable. Bio-based polyolefins reduce dependence on fossil resources, having the potential of similar properties to virgin fossil, with significant carbon footprint reduction, to carbon sequestration and storage during the product lifecycle. Support feedstock diversification by enabling co-feeding in current production processes and recognising the mass balance chain-of-custody model (ISO 22095:2020) as a transparent and scalable tracking method. Ensure that any LCA methodologies used fully reflect biogenic carbon benefits in the product. The current Product Environmental Footprint (PEF) approach underestimates the climate advantage of bio-based inputs. Third-party verified LCA tools allowing biogenic carbon accounting must be accepted. To operationalise these principles, we recommend: Bio-based targets should be forward-looking, aligned with policy goals and industrial potential, not just current usage. Sustainability criteria for bio-based feedstock must be urgently defined at the EU level, building on the existing criteria for fuels in the Renewable Energy Directive and supported by voluntary third-party audited certification schemes (e.g., ISCC+, RSB, FSC). Mass balance models must be legally recognised under EU law to reflect bio-based contributions across complex value chains. Claims and labels on bio-based content must be harmonised and transparent, in line with the proposed Green Claims Directive and standards such as EN 16848 and EN 16935. Decarbonising industry requires unlocking all sustainable carbon sources. Bio-based polyolefins are technologically mature, scalable, and aligned with the EUs circularity goals. Including them fully in the Bioeconomy Strategy framework is essential to reduce emissions, strengthen European resilience, and promote innovation across EU manufacturing. For more information about PCEP and our position on the role of Biobased Polyolefins in a Circular Economy, please visit www.pcep.eu.
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Response to Revision of EU legislation on end-of-life vehicles

4 Dec 2023

PCEP (the Polyolefin Circular Economy Platform), brings together actors from across the polyolefin value chain, united in our common mission to drive the transition to a circular economy for polyolefins - the most commonly used family of plastics. 71.4% of plastics packaging in Europe is made of polyolefins, accounting for 71% of collected plastic waste. This collected material goes on to be transformed into 84.7% of post-consumer recycled polyolefins, used today in European products across building and construction, packaging, agriculture, automotive, electronics, and other sectors. According to PCEPs data, out of 25 MT of polyolefins demand in Europe in 2021, packaging is the biggest market with 14 MT, followed by construction and then automotive with 1.5 MT. See table below. Therefore, with polyolefins widely used in the manufacture of vehicles, PCEP welcomes the proposed regulation on circularity requirements for vehicle design and on the management of end-of life vehicles. The automotive sector is already a major user of recycled polyolefins, and this regulation should drive improved circularity by increasing the recyclability of plastics components and the recycling rate of plastics from end-of-life vehicles. In addition, the plastic recycled content target will support polyolefin circularity and give the clear demand signals needed to speed up industrys investments in the circular economy. Over the last decade, the automotive sector has made notable progress both in the recycling of plastics from end-of-life vehicles and the use of recycled content in plastics components used in new vehicles. This has been driven by the high general recycling targets in the current ELV Directive, which necessitate the recycling of plastic as well as metallic parts of end-of-life vehicles, and also voluntary commitments by manufacturers on the use of recycled plastic in new vehicles. However, the sector faces a multitude of challenges in increasing plastics circularity including the wide range of different polymers used and the long-time lag between improvements being made in new vehicle design and these having an impact on end-of-life recovery and recycling. PCEP welcomes the target of recycling 30% of the plastic in vehicles delivered to waste management operators which we hope will increase investment in processing equipment to recover plastics from shredder residues. This in turn will stimulate plastics circularity in the automotive sector specifically and support attainment of the 25% of the plastic recycled content target that must be met from ELV plastic. Currently there is a significant lack of processing capacity of this type in the EU as a whole and it is key to diverting waste plastics to recycling routes. Increased supply of this mixed waste plastic feedstock should in turn drive investment in the additional specialist plastic recycling capacity needed to meet the target. We believe a 60-month period to put the necessary infrastructure in place is realistic. PCEP also supports the landfill ban on non-inert waste that has not passed through post shredder treatment plants will also support the 30% target. As a recommendation, PCEPs suggests that the legislation is more precise on which waste management operator is obligated to meet the 30% target and at what point in the supply chain. Due to the challenging nature of some of the plastics used vehicles, PCEPs supports the use of different recycling technologies in meeting these targets, both mechanical / physical and chemical. As such, we call for legal clarity around their use and recycled content accounting methodologies to support the required investment. PCEP supports the use of mandatory recycled content targets set at levels that will drive demand and maximise environmental benefits. Plastics used in the automotive sector must meet high technical, and often also aesthetic, standards and so a target of 25% is challenging but we believe achievable.
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Meeting with Patrizia Toia (Member of the European Parliament)

3 Apr 2023 · Packaging and Packaging Waste Regulation (meeting taken by the assistant responsible)

Meeting with Camilla Laureti (Member of the European Parliament)

21 Mar 2023 · Dossier 2023

Meeting with Francisco Guerreiro (Member of the European Parliament)

14 Feb 2023 · Circular economy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

11 Jan 2023 · To discuss the upcoming revision of the packaging and packaging waste regulation

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

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

22 Feb 2022

The Polyolefin Circular Economy Platform (PCEP) welcomes the European Commission’s commitment to “simplify waste management for citizens and ensure cleaner secondary materials for businesses”, along with the overarching commitment to reduce waste. PCEP brings together actors from all across the circular polyolefin value chain united in our common mission to drive the transition to a circular economy for polyolefins (polypropylene and polyethylene) - the most commonly used family of plastics. Our vision of a circular polyolefin economy reflects a use of these versatile and valuable materials that stays firmly in the top two levels of the waste hierarchy – reuse and recycling. PCEP is working towards a circular polyolefin economy where: • All polyolefin products are designed for circularity, delivering the needed functionality, enabling collection and sorting, optimizing recycling to match quality demand. • All polyolefin products use the maximum renewable and recycled content for the application • The use phase of all polyolefin products is extended, where possible, and the material is always collected and recycled to a quality that displaces virgin resource • All polyolefins placed on the market contribute to carbon-neutrality and have an established end of life pathway • No polyolefins are lost into the environment, incinerated or landfilled. In response to the European Commission's Call For Evidence on the review of the Waste Framework Directive, PCEP is elaborating on the following important points to consider during the further development of this policy. Please find enclosed our detailed submission. 1. Improve recovery of materials to optimize recycling rates 2. Coherence of waste policies 3. Strengthen general requirements for Extended Producer Responsibility 4. Investment in infrastructure 5. Recognition of all recycling technologies 6. Stop landfill and incineration of polyolefins 7. The role of the product in preventing waste We are happy to answer any questions from the European Commission, or other stakeholders, on this position. Please contact us at secretariat@pcep.eu
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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

The Polyolefin Circular Economy Platform (PCEP) welcomes the European Commission’s future proof approach to food contact recycled plastics that allows for innovation in recycling technologies. As we noted in previous consultations there is an urgent need to update Regulation 282/2008 to enable the safe use of recycled polyolefins in food contact materials and thereby accelerate the circular polyolefin economy. PCEP welcomes the Commission’s confirmation that feedstock recycling which produces recycled polyolefin identical to virgin 10/2011 compliant material, does not require any additional regulatory approvals. Article 1 of the new proposal will ensure legal certainty and support continued investment in these forms of polyolefin recycling. We are also pleased to see that the existing positive EFSA opinions for recycling of polyolefins in business-to-business closed loops have been authorised as approved food contact recycling. This will further encourage the industry to establish recycling schemes of this nature. In the endeavour to ensure a regulation which covers all possibilities for the future there is some complexity, particularly arising from the use of existing language in new ways. In particular, there do appear to be some administrative aspects which are overly burdensome and could be simplified without impacting health and safety standards. We have identified a few areas in the proposed new regulation which we believe could be improved or where we are asking for further clarification as we found the text raises potential confusion. We hope these aspects will be taken on board in the next draft of the regulation and in discussion with member state competent authorities. Key aspects include avoiding confusion from the new terminology, ensuring definitions account for all forms of recycling within scope of the regulation, allowing the use of food grade manufacturing waste as a default input material, clarifying the transition from a novel to a suitable technology, the need for guidance and appropriate flexibility on the amounts of data and how it is gathered for novel technologies, keeping data on novel technologies for experts in the Authorities only and not the general public, removing unnecessary administrative burden and ensuring that recycling schemes are effective and efficiently approved. The attachment to this submission provides the explanation and proposed changes for the following points: 1. Use of definitions 2. Inclusion of plastic input originating from pre-consumer waste 3. Recycling of plastic originating from mixed waste 4. Continuity of derogations when transitioning from novel to suitable technology 5. Publication of data of novel technologies 6. Guidance on batch testing and sampling strategy 7. Estimated residual incidental contamination 8. Meaning of ‘sufficient data’ 9. Certification of quality assurance schemes 10. Compliance monitoring summary sheet 11. Declaration of Compliance 12. Clarifying the “recycling schemes” 13. Marking of materials and articles in a recycling scheme 14. Use of recycled material behind functional barrier 15. Safeguard clause 16. Guidelines 17. General editorial corrections We are happy to answer any questions from the European Commission, or other stakeholders, on this position. Please contact us at secretariat@pcep.eu
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Response to Revision of EU rules on food contact materials

29 Jan 2021

Highlights from the PCEP submission: The Polyolefin Circular Economy Platform (PCEP) welcomes the European Commission’s commitment to review the regulation for food contact materials (FCM) and recycled plastics, and we look forward to working with all authorities to safely close the loop for polyolefins in food contact applications. PCEP believes that the current EU legal framework for plastic food contact materials provides a high level of consumer safety, which is paramount in these applications. Aspects to also deliver the circular economy can be established within the current framework, and we welcome the planned improvements to create a level playing field for all food contact materials. On average food contact packaging is believed to represent around 70% of the plastic packaging market, and polyolefins represent 70% of the total demand for plastic packaging in Europe. Polyolefins are used to deliver high quality products and packaging in the food contact materials market where consumer safety and hygiene is paramount. Polyolefin products play a critical role in several applications that drive a reduction of the carbon footprint and increase the sustainability of the food supply chain; from growing crops to protecting food for maximum shelf-life, and reducing transport emissions throughout the logistics thanks to the light-weight and versatility in packaging formats. In this respect the sustainability of food contact materials should be considered holistically with the sustainability of the food supply chain. However the use of recycled materials in this market is severely hampered by the lack of legal certainty and the resulting lack of appropriately evaluated and authorised recycling processes or recycled materials, when many technologies are technically available today. Waste management policy, circularity of materials and revision of food contact materials needs to be coordinated and implemented to enable food manufacturers using both flexible and rigid polyolefins to play their full role in the green economy. The many benefits of polyolefins mean we expect to see future reuse and refill systems also chose our materials and the framework for establishing safety of such systems with regard to food contact applications should be developed with harmonised guidance for topics such as washing etc. As we noted in our submission to the public consultation in May 2020, to deliver the circular economy there is an urgent need to deliver updates to Regulation 282/2008 on the requirements for food contact materials from recycled plastics. Action is urgent to meet our collective ambition for a carbon neutral circular economy, let alone to meet existing legal requirements for mandatory recycled content in beverage bottles by 2030 as set in the Single Use Plastics Directive. In addition, increased harmonisation, transparency and communication of information along the value chain and increased resourcing for enforcement are needed for virgin and recycled plastics. Please see attached our position paper for our full contribution to this consultation including an outline of PCEP activities we are currently undertaking to drive the circularity of polyolefins in food contact applications. For more information about PCEP please visit our website www.pcep.eu or contact us directly.
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