Summary
The Packaging and Packaging Waste Regulation (PPWR) makes recycled-content requirements a condition for plastic packaging placed on the Union market. The rules adopted under Article 7(10) must therefore enable legitimate trade in recycled materials and packaging, while ensuring that imported recycled content is counted towards EU targets only if compliance with requirements equivalent to the applicable EU requirements has been demonstrated across the relevant stages of the value chain.
Recycled content placed on the Union market must meet equivalent level of EU defined requirements, irrespective of whether the relevant waste was collected or recycled inside or outside the EU. This principle should apply equally where recycled content enters the Union as a secondary raw material, polymer, packaging component or finished packaging.
Key takeways
Cefic calls on the Commission to:
- Apply a common set of outcome-based equivalence requirements to all recycled content placed on the Union market. These requirements should cover environmental and human-health protection, waste management, recycled-content calculation, chain of custody and verification—not only the numerical recycled-content claim. Equivalence should be assessed at the relevant levels of the value chain, including third country, recycling installations and economic operators. Third countries should not be required to reproduce an identical EU regulatory or administrative system, provided that equivalent outcomes are achieved. Compliance with the applicable equivalence requirements should be demonstrated through objective and auditable evidence, including certification under EU-recognised schemes where appropriate.
- Cover all relevant entry points, including secondary raw materials such as pyrolysis oil and circular naphtha, as well as monomers, polymers, converted components and finished packaging.
- Build on the verification architecture established by Commission Implementing Act (EU) 2026/1425 under the Single-Use Plastics Directive (SUPD), including batch declarations, facility-level verification, competent and independent verifiers, standardised certificates, certificate pass-through and recognition across Member States.
- Establish harmonised EU requirements for the recognition and supervision of certification schemes and certification bodies, building where appropriate on existing EU approaches, accreditation arrangements and harmonised standards. Certificates issued by appropriately accredited certification bodies should be accepted as evidence of compliance where they demonstrate conformity with the applicable PPWR requirements. Commission-recognised certification schemes could provide one recognised route for demonstrating such compliance.
- Use certificate-linked declarations to support customs controls. Recycled origin and attributed mass-balance claims cannot be established through physical inspection of the goods or represented through tariff classification alone.
This approach would ensure a level playing field, protect the integrity of EU recycled-content targets and provide a practical and enforceable framework for compliant imports. It would also support investment in European recycling capacity while maintaining access to verified recycled materials from third countries.