EU consultation
118 submissions from 117 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 130 submissions on this file. Shown here: the 118 from organizations. Not shown: 8 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 4 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
101 submissions from industry (companies and their trade associations) against 13 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.8 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 16 Sept 2026; it ran from 14 Aug 2026.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Dec impl draft, Dec impl.
Showing 25 of 118 submissions.
· · filed 16 Sept 2026 · source
The Federation of the Food and Drink Industries of the Czech Republic (FFDI CZ) welcomes the opportunity to comment on the implementing and delegated acts under Article 7 of the Packaging and Packaging Waste Regulation (PPWR). We support the objective of increasing the use of high-quality recycled plastic in packaging and developing a strong EU market for secondary raw materials.
· · filed 16 Sept 2026 · source
Clarify the evidence required when waste collection, sorting, recycling, packaging manufacture and food export occur in different countries. Assess equivalence against environmental and human-health outcomes rather than requiring identical regulatory structures.
Key recommendation: 1. Apply a clear geographical scope. Only plastic waste collected, sorted and recycled within the EU27, EFTA and the United Kingdom should count towards mandatory recycled-content targets for packaging produced or filled in Europe. 2. Adopt the Implementing Act without delay. Timely adoption is essential to provide investment certainty and make the 2030 recycled-content targets operational.
· · filed 16 Sept 2026 · source
EURAMET, the European Association of National Metrology Institutes, and the European Metrology Network for Safe and Sustainable Food (EMN Food) welcome the European Commissions initiative to develop implementing and delegated acts supporting Regulation (EU) 2025/40 on packaging and packaging waste.
We support the development of clear and reliable conditions for the import of recycled plastics and products containing recycled plastic from third countries. For European industry, it is essential that imported recycled materials are subject to requirements that provide a genuine level playing field with recycled materials produced in the EU. Our recommendations 1.
Eurochambres continues to raise concerns regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR), as smaller businesses in particular are struggling with the regulations complex requirements and the absence of key secondary legislation.
The Association of Plastic Recyclers (APR) appreciates the opportunity to comment on the European Commissions Call for Evidence regarding implementing and delegated acts under Article 7.10 of Regulation (EU) 2025/40. APR is a U.S.-based, international non-profit association and the largest North American organization focused exclusively on improving the recycling of plastics.
CLEPA, the European Association of Automotive Suppliers, representing over 3.000 companies, from multi-nationals to SMEs, supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, directly employing 1.7 million people in the EU, welcomes this initiative and the opportunity to submit its comments in the file attached.
The transition to a more circular economy for plastics must remain economically viable. The Packaging and Packaging Waste (PPWR) secondary legislation should ensure that recycled content targets are implemented in an economically viable manner.
Aliplast welcomes the opportunity to provide input to this call for evidence on Article 7 implementing acts under the Packaging and Packaging Waste Regulation (PPWR). Aliplast is a member of the growing European Plastics Circularity Coalition (EPC coalition) and co-signatory to the EPC coalition input, which is submitted independently.
· · filed 16 Sept 2026 · source
Treating these 3 implementing acts provided for in the PPWR in the same initiative is relevant in order to have an overview of the issues at stake here. Recycling of plastic is essential to promote increased circularity of plastic material in Europe and can also contribute to minimising the footprint associated with plastic waste management.
Filed in Portuguese · English published by the European Commission
Eastman welcomes the opportunity to provide input to this call for evidence on Article 7 implementing acts under the Packaging and Packaging Waste Regulation (PPWR). Eastman is a member of the growing European Plastics Circularity Coalition (EPC coalition) and co-signatory to the EPC coalition input, which is submitted independently.
Defining equivalence rules for recycling Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Promeco welcomes the opportunity to respond to the Call for Evidence on sustainability criteria for recycling technologies under Article 7(10). Promeco is a leading Italian waste-to-value technology provider, with chemical recycling technology as a key portfolio focus. Please find our feedback attached.
Reloop welcomes the opportunity to submit feedback to this important consultation as a part of the European Plastics Circularity (EPC) Coalition. The EPC Coalition is an informal, issue-driven coalition of companies and associations from across the plastic packaging value chain: mechanical and chemical recyclers, waste management operators, polymer producers, converters and producer responsibility organisations.
· · filed 16 Sept 2026 · source
The Advisory Board for Finnish PROs appreciates the opportunity to provide comments on the European Commission's initiative to establish conditions for the import of recycled materials into the EU for use in packaging.
Versalis, Enis chemical company, welcomes and supports the European Commissions ongoing work on the PPWR implementing act concerning the assessment and verification of the equivalence of recycled plastics originating from third countries. The implementing act should establish a robust, predictable and enforceable equivalence framework.
ANFAC, the Spanish Association of Automobile and Truck Manufacturers, considers that the future provisions establish clear, harmonised and verifiable requirements to demonstrate the equivalence of recycled materials from third countries.
Filed in Spanish · English published by the European Commission
EuPC welcomes the opportunity to contribute to the Call for Evidence on the forthcoming implementing measures under Article 7(8), (9) and (10) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Our position paper enclosed sets out industry priorities for a calculation and verification framework: an inclusive, fair and transparent calculation methodology and a credible, proportionate certification and…
Avenue des Gaulois 9 B-1040 Brussels Belgium Tel: [phone removed] TR: 107438267901 AIM FEEDBACK www.aim.be European Commission’s call for evidence on secondary legislation implementing Article 7 of the Packaging and Packaging Waste Regulation September 2026 AIM, the European Brands Association, represents manufacturers of branded consumer goods across the food and beverage, personal and homecare, apparel…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Inter IKEA Group welcomes the opportunity to provide input to the European Commissions Call for Evidence related to the two upcoming implementing acts related to Article 7 of the Packaging and Packaging Waste Regulation (PPWR). For nearly 80 years, packaging has been a cornerstone of the IKEA business model.
Bariq contribution to the European Commission call for evidence Article 7(10) of Regulation (EU) 2025/40 on packaging and packaging waste 15 September 2026 1 Our position Bariq supports the Commission’s objective of ensuring that recycled content supplied to the European market meets robust standards of environmental protection and human health.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
TOMRA welcomes the opportunity to provide input to the European Commissions work on the Article 7 implementing acts under the Packaging and Packaging Waste Regulation (PPWR). TOMRA is a co-signatory to the position paper prepared by the European Plastics Circularity Coalition (EPCC), which will also be submitted independently.
The EU implementing act for assessing, verifying and certifying equivalence should strictly align the definition of recycling with EU legislation by excluding fuel, and ensuring imported post-consumer recycled plastic meets identical recycling, environmental, and non-fuel processing criteria.
The European Plastics Circularity (EPC) Coalition is an informal, issue-driven coalition of companies and associations from across the plastic packaging value chain: mechanical and chemical recyclers, waste management operators, polymer producers, converters and producer responsibility organisations. It is not an industry association and does not intend to become one.
NMWE sets out the following sector-specific recommendations on Equivalence for recycled content originating outside the EU: - The implementing act should focus on clarifying how recycled content is calculated and verified, without adding requirements beyond those already set out in Article 7.
SCC-Industries GmbH imports post-consumer rPET flakes from non-OECD origins in North, West and East Africa, supplying EU converters subject to the Article 7 targets. We support strict and verifiable equivalence; our submission concerns only the level at which it is assessed under Article 7(10). A fuller version is attached. 1. Installation, not country.
Confapi, the Italian Confederation of Small and Medium-Sized Private Industry, which represents 118.00 small and medium-sized industrial enterprises with more than 1.3 million employees, intends to submit its contribution, with particular reference to the implementing act referred to in Article 7(10), in view of the adoption, planned for the fourth quarter of 2026, of implementing acts pursuant to Article 7 of…
Filed in Italian · English published by the European Commission
LyondellBasell, as part of a coalition EPC (European Plastics Circularity) would like to submit our position on the Packaging and packaging waste conditions for importing recycled materials into the EU for use in packaging call for evidence. please find attached our contribution.
· · filed 16 Sept 2026 · source
OCTAL Position OCTAL SAOC FZC / Alpek Polyester Middle East supports robust and verifiable criteria to ensure that recycled plastic materials originating from third countries provide levels of environmental protection, human-health protection, traceability and quality equivalent to those applicable in the European Union.
· · filed 16 Sept 2026 · source
The requirements established under PPWR should apply equally to recycled materials produced within the European Union and to recycled materials imported from third countries. Imported materials intended to contribute to PPWR compliance should be subject to equivalent standards regarding traceability, mass balance accounting, calculation methodologies, independent auditing and verification procedures.
The Packaging and Packaging Waste Regulation (PPWR)1 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…
The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.
This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries.
FEAD, the European Waste Management Association, call for the Implementing Act on the mirror clause to include a European prioritisation with the introduction of a clear Made in Europe preference for plastic recycled content (RC) targets. FEAD calls on the European Commission to ensure that the future Implementing Act is built around the following three key principles: 1.
· · filed 16 Sept 2026 · source
As a consumer goods manufacturer with operations in multiple global markets, we are particularly concerned about the feasibility of incorporating PCR into our packaging if access to non-EU sourced PCR is restricted. We would appreciate the Commission addressing our concerns through the forthcoming implementing acts.
Elipso supports the development of a European circular plastics economy, provided that the PPWR targets for the incorporation of recycled materials do not in any way compromise health safety or existing sectoral regulations.
Filed in French · English published by the European Commission
· · filed 16 Sept 2026 · source
Thailand PPWR consortium is a platform where government, academic, private, and NGO sectors are collaboratively discussed and agreed to recommend all relevant feedbacks submitted into the EU system regarding Article 7(8), 7(9), and 7(10) of PPWR by the key consortium representatives.
Plastové obaly a recyklované materiály – pravidla pro recyklaci, dovoz a obsah recyklovaného materiálu Stanovisko HK ČR Hospodářská komora České republiky (HK ČR) vítá možnost vyjádřit se k připravovaným prováděcím pravidlům v návaznosti na nařízení PPWR. HK ČR podporuje cíle směřující k rozvoji oběhového hospodářství a efektivnímu využívání recyklovaných materiálů.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As the European association representing manufacturers of self-care products, including non-prescription medicines, medical devices, and food supplements, AESGP supports the main objectives of the Packaging and Packaging Waste Regulation (PPWR) to promote circularity and contribute to a more resource-efficient packaging system across the European Union.
Call for Evidence on the Implementation of PPWR Article 7 Amcor Submission Ensuring sufficient, high-quality recycled content for packaging Amcor supports the objectives of the Packaging and Packaging Waste Regulation (PPWR) to accelerate packaging circularity, strengthen markets for secondary raw materials and drive investment in European recycling infrastructure.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Position Stockholm, 2026-09-16 Henrik Oxfall IKEM:s position om Villkor för import från tredje land av återvunnen plast eller artiklar som innehåller återvunnet plastmaterial Inledning EU:s förordning om förpackningar och förpackningsavfall (PPWR) innebär att återvunnet innehåll blir en central del av den europeiska omställningen till en cirkulär ekonomi.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 16 Sept 2026 · source
We support the PPWR objectives to increase the use of safe, high-quality post-consumer recycled plastic. For recycled plastic produced outside the EU, we recommend that the EU recognise equivalent systems of control and verification, even where the third country does not have the same legislation as the EU.
Detergents Europe, representing the cleaning and hygiene products industry in Europe, fully supports the objectives of the Packaging and Packaging Waste Regulation (PPWR) to enable a circular packaging economy. Our goal is to increase the use of post-consumer recycled (PCR) content in plastic packaging, thereby supporting the transition to more circular and sustainable packaging solutions within our sector.
The Thailand PPWR Consortium welcomes the opportunity to provide feedback on the development of the implementing rules under Article 7(10) of Regulation (EU) 2025/40. Thailand is an important manufacturing and supply-chain partner for the European market, including for plastics, packaging, converted products, parts, components and recycled materials.
Please find attached joint EPRO and EXPRA feedback to the consultation on the following topics: Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging (implementing act under article 7(8)). Packaging and packaging waste sustainability criteria for plastic recycling technologies (delegated act under article 7(9)).
FEDIAF, the European Pet Food Industry Federation, welcomes the opportunity to respond to this call for evidence. Our central point is this: meeting the 2030 targets will depend in part on recyclate sourced outside the EU, so the equivalence methodology directly shapes the availability and cost of compliant material for pet food packaging.
PPWR CALL FOR EVIDENCE SK Chemicals' Position on Secondary Legislation for Recycled Content under the PPWR Regulation (EU) 2025/40 on packaging and packaging waste SK Chemicals produces chemically recycled PET (CR PET) and chemically recycled copolyesters through a chemical recycling process in which waste PET is depolymerised to monomer-level intermediates and purified.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Repsol PPWR Article 7(10): Equivalence and verification requirements for recycled content from third countries Executive Summary and Priority Policy Asks Repsol welcomes the opportunity to contribute to the public consultation on equivalence and verification requirements for recycled content imported from third countries under Article 7(10) of Regulation (EU) 2025/40 on packaging and packaging waste.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Joint proposal for an effective mirror clause under Article 7(10) of PPWR INTRODUCTION FEAD, PRE and Recycling Europe recommend introducing under Article 7(10) of the Packaging and Packaging Waste Regulation (PPWR) a clear Made in Europe preference for plastic recycled content (RC) targets: ➢ For packaging produced or filled in the EU: compliance with recycled content targets should rely on recycled plastics…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
LG Energy Solution Wrocław sp. z o.o. adres korespondencyjny: ul. LG 1 A, Biskupice Podgórne, 55-040 Kobierzyce, Dolnośląskie, Poland NIP: 8961550941, REGON: 364187232, KRS: 0000614214, Kapitał Zakładowy: 4 648 372 000,00 PLN Sąd Rejonowy dla Wrocławia-Fabrycznej we Wrocławiu, VI Wydział Gospodarczy Krajowego Rejestru Sądowego OL/2026/C/001/ Biskupice Podgórne, 15 September 2026 Call for Evidence: Packaging and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 16 Sept 2026 · source
In the view of the SCHP ČR, the implementing act should establish a legally predictable, non-discriminatory and practically enforceable system for recognising recycled content originating in third countries. The assessment must be based on the level of protection and quality actually achieved, rather than on the formal identity of legal provisions, while maintaining independent verification and effective safeguards…
Suzuki Motor Corporation welcomes the European Commissions Call for Evidence on recycled content under Articles 7(8), 7(9) and 7(10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback. We support the objective of promoting the use of recycled materials while ensuring a high level of environmental protection and protection of human health.
· · filed 16 Sept 2026 · source
Henkel supports the objective of increasing recycled plastic content in packaging and establishing harmonized EU rules that are practical, enforceable, and supportive of a circular economy. Henkel supports clear and proportionate equivalence rules that recognize established international certification and chain-of-custody schemes.
We are an industrial operator being set up in Kinshasa, Democratic Republic of the Congo. Our plant will process 25,056 tonnes of mixed and contaminated post-consumer plastic per year into recycled pellets, substitute fuel and paving materials. Alongside it we are building TakaCircular, a system that records where each tonne came from. We are not yet in production.
· · filed 16 Sept 2026 · source
ANFACO-CYTMA considers that future conditions applicable to the import of recycled materials should simultaneously contribute to ensuring the reliability and traceability of the materials used and to ensuring a sufficient supply of recycled materials suitable to meet the mandatory recycled content targets set by PPWR.
Filed in Spanish · English published by the European Commission
Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and users of recycled materials. DI welcomes the opportunity to provide input on the conditions for importing recycled materials into the EU for use in packaging.
EDANA, the international association representing the nonwovens industry and its value chain, would like to thank the European Commission for the opportunity to provide input on the following initiatives related to the Packaging and Packaging Waste Regulation (PPWR): Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging; Conditions for importing recycled…
Agbiz makes this submission on behalf of the South African agri-food export sector, focusing on the conditions for using recyclate from third countries (Article 7(10)) and the sustainability criteria for recycling technologies (Article 7(9)), where the risk to agri-food trade is greatest and on which the Commission has expressly invited evidence. What is at stake.
Please find our formatted comments in the attachment. The Food Packaging Forum Foundation (FPF) welcomes the opportunity to provide evidence to develop conditions for importing recycled materials into the European Union for use in packaging.
PCEP welcomes the Commission's efforts to define conditions for recognising recycled materials imported into the EU for use in packaging. Clear and enforceable rules are necessary to ensure a level playing field while maintaining confidence in recycled content claims under the PPWR.
Medicines for Europe, representing generic, biosimilar, and value-added medicines manufacturers across Europe, welcomes the opportunity to contribute to the call for evidence on the Packaging and packaging waste conditions for importing recycled materials into the EU for use in packaging. Please find our submission attached.
Consultation response PPWR reporting and registration Position Paper: Comments on Harmonized Registration and Reporting Requirements The Norwegian Packaging Association is Norway's only interest organization for packaging and wrapping.
Consultation feedback: Packaging and packaging waste – conditions for importing recycled materials into the EU for use in packaging Mainz, September 2026 Within the context of the European Commission’s call for evidence on conditions for importing recycled materials into the EU for use in packaging under the Packaging and Packaging Waste Regulation (PPWR), Landbell Group company European Recycling Platform (ERP) is…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Recycling Europe recommends that the future Implementing Act under Article 7(10) PPWR is built around the following three key principles (for more details, see the attached FEAD-Plastic Recyclers Europe-Recycling Europe Joint Proposal for a Mirror Clause under PPWR): 1) Require Made in Europe recyclates for packaging produced or filled in the EU: In that case, compliance with recycled content (RC) targets should…
The Baden-Württemberg Cooperative Association (BWGV) is grateful for the opportunity to provide feedback from the practice of cooperative companies in Baden-Württemberg on the implementation of the EU Packaging Regulation (PPWR) in the context of Have Your Say.
Filed in German · English published by the European Commission
· · filed 16 Sept 2026 · source
Current Situation in China Basic Conditions: A relatively complete legal framework together with internationally used standards, certification and chain-of-custody schemes are available. Industrial Pain Points: The recycling and collection segment is highly fragmented, posing great practical challenges and high costs for on-site audits across the full value chain.
Fonterra supports the objective of increasing recycled content in plastic packaging. However, Article 7 must be implemented in a way that protects food safety and product performance, works for global and seasonal food supply chains, and does not create a de facto barrier to trade for third-country exporters.
ALPLA welcomes the call for evidence on the PPWR implementing act under Article 7(10) as a key opportunity to establish a robust, risk-based and proportionate framework for recognising recycled plastics from third countries towards PPWR recycled-content targets.
The Meat Industry Association of New Zealand (MIA) supports the objectives of the EU Packaging and Packaging Waste Regulation (PPWR) to reduce packaging waste, improve recyclability, and strengthen the circular economy. However, implementation must recognise the realities of global food supply chains and the essential role packaging plays in food safety, shelf life, product integrity, and food waste reduction.
Plastic Energy Technology Ltd (Plastic Energy) welcomes the opportunity to respond to the European Commissions Call for Evidence on the implementing act under Article 7(10) of the PPWR, concerning the equivalence of recycled content originating outside the European Union.
Encina submits these comments from the perspective of a developer of advanced recycling technology and a prospective supplier of circular feedstocks. Please see the attachment for Encinas complete feedback. Encina is a United States-based technology developer working to produce circular chemicals and decarbonize the global chemicals industry.
We strongly support the principle that recycled plastic from third countries must meet standards equivalent to those applied within the EU. Our attached response sets out practical evidence from existing EU food-contact regulation, third-country recycling facilities and the Prevented Ocean Plastic programme, and explains why a clear facility- and supply-chain-level route to equivalence is essential.
The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish a framework for assessing third-country equivalence for recycled content under the Packaging and Packaging Waste Regulation (PPWR).
Plastics Europe supports a mirror clause that ensures all recycled content counting towards PPWR targets is subject to equivalent requirements, whether it originates in the EU or in a third country. To achieve this, the focus should be on defining equivalence criteria and strengthening the verification and enforcement of those requirements in a fit-for-purpose and implementable manner across the value chain through…
Kolmar Group AG EXTERNAL USE Ref. Ares(2026)8755695 Page 1 of 3 - 15/09/2026 Kolmar Group AG’s response to Call for Evidence on the Implementing Act on Article 7(10) of the Regulation (EU) 2025/40 (PPWR) “Import equivalence” INTRODUCTION Kolmar Group AG welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(10) of the Regulation (EU) 2025/40 (PPWR), which requires that…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BLUEALP welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(10 ) of the Regulation (EU) 2025/40 (PPWR), which requires that recycled content originating outside the European Union be recognised only where it can be demonstrated as equivalent to material collected and recycled under EU rules.
· · filed 15 Sept 2026 · source
CONAI and COREPLA welcome the contribution to the consultation of the European Commission on the implementing acts provided for in Article 7(10) of Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR).
Filed in Italian · English published by the European Commission
The EU market for recycled plastics is part of a global value chain. We support the objective of ensuring robust traceability, verification, and environmental standards for post-consumer recycled (PCR) plastics used to meet the recycled content requirements under the PPWR.
EFPIA, representing the innovative, research-based pharmaceutical industry in Europe, welcomes the European Commissions efforts to establish a clear and harmonised methodology for assessing, verifying and certifying the equivalence of recycled materials collected or recycled in third countries under the Packaging and Packaging Waste Regulation (PPWR).
1. Core principles for recycled content eligibility for packaging (i) For packaging produced or filled in the EU, only European (EU, EFTA,UK) recyclates shall count toward the recycled content targets. (ii) For packaging filled outside the EU, the mirror clause mechanism applies and recycled plastics can count towards the targets if originating from EU or from third countries and facilities where equivalent EU…
The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.
Call for Evidence on upcoming implementing and delegated acts relating to recycling and recycled content/materials under the Packaging and Packaging Waste Regulation (PPWR) Ref. Ares(2026)8748860 - 15/09/2026 IBMA, the International Biocontrol Manufacturers Association represents the biocontrol industry, with over 200 member companies globally.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 15 Sept 2026 · source
Comments of the Czech Republic on the Proposed Delegated Act under Article 7(10) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic considers it important that the requirements for the verification of recycled content in materials and products imported from third countries ensure a high level of credibility of declared information while maintaining a level playing field within the EU…
· · filed 15 Sept 2026 · source
Feedback of Bioeksen Ar-Ge Teknolojileri A.Ş. (Türkiye) manufacturer of CE-marked in vitro diagnostic medical devices (Regulation (EU) 2017/746) placed on the EU market. Our packaging is manufactured by converters in Türkiye; any recycled content it will contain from 2030 will originate from post-consumer plastic waste collected and recycled in Türkiye.
PHOENIX remains supportive of the overall objectives of PPWR and welcomes further dialogue on practical implementation requirements. Against this background, we call for: 1. Clear Allocation of Responsibilities Responsibilities should be clearly defined across recyclers, converters, packaging suppliers, producers, importers, and private label owners.
CONAI welcomes the opportunity to join this consultation. In a nutshell, CONAI and COREPLA consider it appropriate to suggest: 1. Provide for a dual legal basis in the TFEU, Article 114 internal market and Article 191 environment 2. Reconsider an impact assessment to support the 3 Executive Act. Establish a European verification system, equivalent 4.
Filed in Italian · English published by the European Commission
· · filed 15 Sept 2026 · source
We support the establishment of a robust framework that safeguards the credibility of the PPWR recycled-content targets while enabling high-quality recycled materials produced both within and outside the EU to contribute to the circular economy under fair conditions.
The Malta Business Bureau (MBB) welcomes the opportunity to provide feedback on the upcoming implementing and delegated acts under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). A central challenge highlighted by our business community is that the PPWR framework remains largely tailored to generic, high-volume packaging formats (e.g., standard carton boxes, beverage cans, PET water bottles).
Clean Planet Energy (CPE) is a UK technology developer converting hard-to-recycle post-consumer plastic waste into purified pyrolysis oil (PPO) and circular hydrocarbon feedstocks. UK-produced PPO may be physically supplied to EU petrochemical facilities for conversion into new plastic. Whether such material can count under the PPWR is therefore a direct determinant of investment and offtake decisions.
· · filed 15 Sept 2026 · source
Futerro is a European producer and recycler of PLA, a bio-based polymer. Futerro firmly believes that the credibility and effectiveness of the PPWR will greatly depend on the ability to demonstrate that requirements applicable to materials and packaging placed on the EU market follow the same standards, verification and enforcement, regardless of whether they are fulfilled within or outside the European Union.
- The methodology should provide a robust and credible framework for assessing equivalence while remaining practical, internationally operable and supportive of investments in European circular economy solutions.
The Finnish Meat Industry (Atria Suomi Oyj, HKFoods Oyj and Snellmanin Lihanjalostus Oy) welcomes the opportunity to provide feedback on the implementing act (IA) regarding PPWRs article 7 point 10, establishing the conditions for importing recycled materials into the EU for use in packaging. The companies account for the great majority of meat production in Finland.
· · filed 15 Sept 2026 · source
The act will lay down methodological rules to ensure that plastic materials collected or recycled in non-EU countries are assessed, verified and certified in an equivalent way to the system in place in the EU for the same materials so that they are composed only of single components.
Filed in Italian · English published by the European Commission
· · filed 15 Sept 2026 · source
The Japan Clean Ocean Material Alliance (CLOMA) welcomes the opportunity to provide feedback on the European Commissions initiative concerning the conditions applicable to recycled plastics originating from third countries. CLOMA is a multi-stakeholder platform in Japan that brings together more than 450 companies and organisations across the entire plastics value chain (https://cloma.net/english/).
· · filed 14 Sept 2026 · source
1. In the preparation of the three acts, the Commission would like to collect evidence on the following in particular, data on imports of plastic recyclates: What is the estimated annual volume of recycled content imported into the EU from third countries? (estimates by polymer type where available). What proportion of plastic packaging placed on the EU market originates from third countries?
· · filed 14 Sept 2026 · source
Our core belief at Faerch is that a truly circular economy for food packaging can only be achieved when the entire value chain, including industry, waste management, customers and regulators, works together. Only through this alignment can food packaging remain in a closed loop, where used materials are continuously transformed into new, food-grade packaging.
· · filed 14 Sept 2026 · source
Brussels, September 2026 EUROPEN’s response to calls for evidence on Article 7 of the Packaging and Packaging Waste Regulation (PPWR) Introduction In August 2026, the EU Commission launched three calls for evidence in relation to Article 7 of the PPWR, which establishes recycled content targets in plastic packaging.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Import conditions and third country verification (Article 7(10)) The lack of effective import controls, coupled with increasingly tighter conditions for the European market, pose a risk of declaratory fraud (mixing of primary plastic declared as recyclate due to price difference).
Filed in Czech · English published by the European Commission
· · filed 14 Sept 2026 · source
In the Implementing Act on the conditions for the import of recycled plastic materials or articles with recycled plastic content from third countries: establish the need for sampling and analysis of recycled content for all imported plastics, setting a minimum percentage of sampling on customs entries.
Filed in Spanish · English published by the European Commission
Brussels, September 2026 EUROPEN’s response to calls for evidence on Article 7 of the Packaging and Packaging Waste Regulation (PPWR) Introduction In August 2026, the EU Commission launched three calls for evidence in relation to Article 7 of the PPWR, which establishes recycled content targets in plastic packaging.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 14 Sept 2026 · source
JEITA supports the objectives of the PPWR to promote a circular economy, increase the use of recycled plastics, and ensure a high level of protection of the environment and human health. At the same time, supply chains for electronic components and their packaging are highly globalized and multi-tiered.
CRRA Position on PPWR Article 7(10) Equivalence Recognition Position and Demands on the Equivalence Recognition of Recycled Materials from Third Countries under the EU PPWR Submitted by: China National Resource Recycling Association (CRRA) Introduction On 14 August 2026, the European Commission launched a call for evidence on the implementing acts related to recycled content under Article 7 of the Packaging and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 11 Sept 2026 · source
Japan Cosmetic Industry Association (JCIA) submits these comments from the perspective of cosmetic companies placing on the EU market finished products using packaging containing recycled materials recovered, sorted or recycled outside the EU, rather than from the perspective of companies importing recycled materials as such.
· · filed 10 Sept 2026 · source
We are concerned about the practical impact of the PPWR requirements on importers like us. We do not manufacture products or packaging and have no control over the packaging materials or recycled content used. In many cases, we do not purchase directly from manufacturers, but through wholesalers, distributors and brokers.
· · filed 10 Sept 2026 · source
Article 7(3) explicitly permits the use of recycled content from third-countries subject to the specific conditions mandated in Article 7(10). As a consequence, the Implementing Act should strive to be fundamentally permissive in nature, rather than a construct that effectively prohibits international trade in post-consumer recyclate.
Confcommercio welcomes the possibility of providing input to the public consultation on the conditions for importing recycled materials into the EU for use in packaging under the Packaging and Packaging Waste Regulation. Please refer to the attached document.
Filed in Italian · English published by the European Commission
CRE welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(10 ) of the Regulation (EU) 2025/40 (PPWR), which requires that recycled content originating outside the European Union be recognised only where it can be demonstrated as equivalent to material collected and recycled under EU rules.
· · filed 10 Sept 2026 · source
I am writing to you as owner of a small micro enterprise in Denmark that operates a webshop and a brick-and-mortar shop. I fully support the objective of reducing packaging waste. In fact, for a very long time I have been actively working on this particular issue in my own company. As far as possible, all cardboard, paper and packaging fillings I receive from suppliers are reused in new shipments.
Filed in Danish · English published by the European Commission
Helix Projects BV welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(10 ) of the Regulation (EU) 2025/40 (PPWR), which requires that recycled content originating outside the European Union be recognised only where it can be demonstrated as equivalent to material collected and recycled under EU rules.
Association of Czech Traditional Shop Association brings together traditional Czech retail networks, defends the interests of Czech traders, protects and develops the tradition of Czech shops, supports Czech producers as well as regional products.
Filed in Czech · English published by the European Commission
GS1 is a neutral, not-for-profit standards organisation that develops and maintains global standards for identification, data capture and data sharing. GS1 standards are used across sectors and jurisdictions to support supply-chain efficiency, traceability, regulatory compliance and interoperability.
FEDIMA represents European manufacturers and suppliers of ingredients to the bakery, confectionery and patisserie industries. FEDIMA welcomes the opportunity to provide feedback on this initiative and supports the development of clear and harmonised EU rules for recycled plastic materials imported into the EU for use in packaging.
Fecc welcomes the opportunity to provide feedback on the proposed conditions for importing recycled materials into the EU for use in packaging. Representing the European chemical distribution sector, Fecc supports the objective of ensuring that imported recycled materials meet conditions equivalent to those applicable in the EU.
· · filed 25 Aug 2026 · source
We welcome the European Commission’s objective of establishing a robust and comprehensible framework for the recognition of plastic recyclates from third countries. The future rules must ensure that requirements for environmental, health and quality standards along global supply chains are credible and verifiable.
Filed in German · English published by the European Commission
· · filed 18 Aug 2026 · source
A European brand owner/importer may source finished packaging through converters in Asia rather than directly from recyclers. The final economic operator may therefore have limited visibility several tiers upstream.
· · filed 18 Aug 2026 · source
Non-EU recycled material should be certified according to EU accredited systems (Recyclass - Polycert Europe - GRS - ..) These systems clearly take into consideration the REACH compliancy of the material. Polycert Europe is a system which is based on controlled blending which guarantees the recycled content on product level.
· · filed 15 Aug 2026 · source
I am a sole artist who has been making and selling handmade prints for over 20 years. I have sold and shipped my work to customers in many EU countries over the years, although the countries and volumes vary from year to year. EU sales were around £1,000 last year, but in some years they have been as high as £8000. For a small independent artist like me, this income is important to keeping my business viable.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.