Cefic calls for EU-wide harmonised End-of-Waste criteria for chemical recycling

To unlock circular plastics and enable all recycling routes, the EU must urgently establish harmonised End-of-Waste criteria for chemical recycling, building on existing efforts for other recycling routes and ensuring a coherent framework across Europe. With an Implementing Act already under development for other recycling routes, now is the time to ensure the chemical recycling route is not left behind.

The EU’s circular economy framework is evolving, but a critical gap remains. While the Commission has already developed draft End-of-Waste criteria for plastics from mechanical and solvent-based recycling, a dedicated framework for chemical recycling is still missing.

The Commission’s recent draft Implementing Act establishing EU-wide End-of-Waste criteria for plastics from mechanical and solvent-based recycling represents a welcome step towards harmonisation. However, its scope is limited to specific recycling routes and does not reflect the specific characteristics of chemical recycling technologies, value chains and outputs.

In the absence of harmonised EU-wide criteria for chemical recycling, Member States continue to apply different interpretations of when waste ceases to be waste. This fragmentation creates uncertainty for operators and barriers to investment and cross-border trade.

As a result, the current approach risks leaving a key recycling route without the regulatory clarity needed to scale.

Chemical recycling plays a distinct and complementary role to mechanical and solvent-based recycling. It enables the treatment of complex and mixed plastic waste streams that cannot be recycled by these technologies, converting them into secondary raw materials that re-enter industrial value chains. Scaling up these technologies will be key to meet EU circularity and recycled content objectives and reduce emissions across value chains.

In its position paper, Cefic calls on the European Commission to establish harmonised End-of-Waste criteria for chemical recycling and act without delay to:

1. Base End-of-Waste criteria for chemical recycling on the conditions of Article 6(1) of the Waste Framework Directive, ensuring a consistent and technology-neutral application across all chemical recycling routes. 
2. Ensure that, once waste ceases to be waste, the resulting materials are subject to applicable product and chemicals legislation, which inherently provide robust quality assurance and traceability systems, thereby maintaining a high level of protection for human health and the environment without the need for additional control mechanism. 
3. Recognise that End-of-Waste may be achieved at different stages of the chemical recycling route, where specification-controlled secondary raw material intermediates meeting Article 6(1) conditions are produced. 
4. Adopt an output- and intended use approach grounded in Article 6(1) of the Waste Framework Directive. 
5. Establish harmonised EU-wide End-of-Waste criteria for chemical recycling technologies to ensure the functioning of the internal market and provide regulatory certainty for investment. 

Without a dedicated and harmonised framework, regulatory fragmentation will continue to slow down innovation, disrupt cross-border value chains and delay investments in chemical recycling capacity in Europe. Providing legal certainty and a level playing field across the EU is essential to unlock investment, scale up circular solutions and accelerate industrial transition.