Under the Packaging and Packaging Waste Regulation (PPWR), well-designed sustainability criteria for recycling technologies will play a central role in shaping how packaging waste is treated and how circular materials are brought back to the market. To be effective, these criteria must be technology-neutral and performance-based. This will ensure that all recycling technologies, including chemical recycling, can contribute to circularity and are assessed based on what they deliver in practice.
The PPWR foresees the development of sustainability criteria for recycling technologies as one of several mechanisms contributing to the achievement of its objectives.
For Cefic, it is key that these criteria are designed in a way that reflects how recycling systems operate in practice. This means recognising that different technologies address different waste streams and that their performance should be assessed in relation to the outputs they generate.
While mechanical recycling remains important, not all waste streams can be treated in this way. Complex plastic waste, such as mixed or multi-layer materials, requires alternative solutions, including chemical recycling. Ensuring that all relevant technologies can contribute is key to increasing overall recycling rates and improving material circularity.

Overly strict or narrowly defined criteria could risk distorting investment signals, undermining competitiveness of EU recyclers and excluding technologies needed to treat complex waste streams.
In this context, Cefic strongly supports a performance-based approach, whereby recycling technologies are assessed based on the quality, functionality and sustainability performance of their outputs, rather than the process through which they are produced. Such an approach ensures fair comparability across technologies and better reflects their contribution to circularity.
In its position paper, Cefic calls for sustainability criteria that:
- Follow a combined input- and end-use oriented approach, reflecting both the characteristics of the waste stream and the end-use based requirements for quality, functionality and performance of outputs placed on the market, with the objective to substitute virgin-based materials in high-quality applications;
- Ensure full technological neutrality, avoiding implicit preferences or exclusions across recycling pathways;
- Recognise the complementary roles of recycling technologies, including the contribution of chemical recycling in treating complex waste streams that would otherwise go to incineration or landfill;
- Incorporate broader circularity and resource efficiency indicators, beyond climate metrics alone, with performance primarily assessed against the virgin materials being substituted in line with PPWR high quality recycling objectives, while also recognising, where relevant, the avoidance of incineration and landfill for complex waste streams;
- Remain flexible and innovation-friendly, supporting the scale-up of emerging technologies and allowing for continuous improvement as data and processes evolve;
Cefic remains committed to supporting the European Commission in developing a robust, future-proof framework that enables all recycling technologies to contribute to Europe’s circular economy and climate objectives.

