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

The concept of ‘dual use products’ is not in line with the definition of recycling The definition of recycling enshrined in the EU Waste Framework Directive (Article 3 (17)) excludes energy recovery and conversion into materials intended for use as fuel.

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The Spanish Mineral Waters Association (ANEABE) wishes to contribute to the public consultation of the draft European Implementing Decision on the calculation, verification and reporting of data on recycled material content in single-use plastic beverage bottles for the implementation of Directive 2019/904 with the following contributions.

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REMONDIS welcomes the Commissions effort to establish a consistent and transparent methodology for calculating, verifying, and reporting the recycled content of plastics. We particularly appreciate the focus on using actual measured plant data and the explicit limitation of certain transitional provisions until a revision in 2030.

The methodology proposed for the consultation presents several aspects of concern: (1) the allocation rule for dual-use products represents a drift from the mass balance method that derogates from the definition of recycling within the European Union. This rule should be disregarded in favour of a proportional allocation.

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For a full version of our feedback, please refer to the attached file. RCI welcomes the draft Implementing Decision and supports the Commissions efforts to establish a methodology for MBA a key step to defossilise the chemical industry and promote sustainable carbon cycles.

Zero Waste France is particularly concerned about the content of the draft implementing decision, which aims, in particular, to enable chemical recycling, and more particularly products resulting from a process such as pyrolysis, to compete against the objectives of incorporating recycled material into beverage bottles.

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Our company has spent the past decade developing beverage bottles made from polylactic acid (PLA) as an alternative to PET. PLA offers substantial environmental and health-related benefits: it is derived from 100% renewable resources, is biodegradable, and does not generate persistent microplastics. PLA is based on lactic acid, a naturally occurring substance that can be safely metabolized by the human body.

Quantafuel welcomes the draft Implementing Decision and strongly supports the introduction of a methodology for chemical recycling. Quantafuel endorses the feedback submitted by Chemical Recycling Europe (CRE). To ensure the rules are fully implementable and support the scale-up of chemical recycling capacity in Europe, we propose a small number of targeted refinements: Allocation of recycled content should be based…

The "Versnellings Tafel Chemische Recycling" (VTCR) welcomes the European Commissions draft Implementing Act under the Single-Use Plastics Directive (EU 2019/904) as a vital step toward harmonising recycled content rules across the EU.

The Polish Chamber of Chemical Industry acknowledges the publication of the draft Implementing Decision establishing harmonised EU rules for calculating, verifying and reporting recycled content in single-use plastic beverage bottles.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) welcomes the opportunity to provide feedback on the draft Implementing Decision laying down the rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles.

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.

Created in 2022, More Climat in the media is a civic and independent association that promotes the preservation of natural resources and waste prevention, with a focus on reduction at source. We are concerned about the methodology for calculating the incorporation of recycled material in single-use plastic bottles proposed by the Commission.

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ESTER Biotech welcomes the initiative to establish a harmonized methodology for calculating, verifying, and reporting recycled plastic content. An unified framework is crucial to ensure comparability, regulatory clarity, and long-term investment certainty, which will support the deployment of novel recycling technologies. We strongly support excluding fuel use from the definition of recycled content.

Please find attached the contribution of the European Chemical Industry Council (CEFIC) into the stakeholder consultation for the Single Use Plastic Directive Implementing Act (SUPD IA). This contribution reflects the discussions and different positions of the Cefic members, who are engaged in different technologies.

TEPPFA welcomes the European Commissions public consultation regarding the draft Single-Use Plastics Directive (SUPD) Implementing Decision, which proposes a credit-based mass balance method for attributing chemically recycled content in plastic beverage bottles.

We acknowledge that attempts have been made to create more clarity, by introducing technical clarifications. It is also positive that all bottles placed on the market in the Member States must now be taken into account in the calculation. However, the fundamental problem remains: the legal basis is the SUPD, which has always had mechanical recycling as its goal.

Stakeholders feedback from EPRO and EXPRA. Submitted by EPRO on behalf of EPRO and EXPRA. EPRO and EXPRA support the effort of the European Commission to establishing credit-based mass balance as the method for calculating recycled content from chemical recycling processes. EPRO and EXPRA support a fuel-exempt allocation method and not proportional nor polymer only.

Valmet welcomes the European Commissions initiative to advance the circular economy and the proposal to define rules for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles, as planned in Directive (EU) 2019/904. One of the key elements in the draft is the inclusion of the mass balance accounting method for chemical recycling technologies.

The current draft does not effectively meet the goals of the SUPD, especially when it comes to environmental protection and promoting a circular economy. As Recital 13 states, [..] the objective of the targets is to promote the market uptake of recycled plastic, with the aim to ensure the circular use of plastics [..].

Eastman, a specialty material company seeking to further invest in Europe, welcomes the European Commissions proposed Implementing Act under the Single-Use Plastics Directive (SUPD), which outlines the methodology for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles.

We explicitly welcome and support the following provisions: - The recognition of the complementarity between mechanical and chemical recycling' and the need for calculation methodologies applicable for all recycling technologies - The aim to balance transparency with minimal administrative burden and differentiated verification requirements - A credit-based fuel-use exempt mass-balance methodology - Clarification…

Topsoe commends the European Commission for its commitment to advancing the EU's transition to circularity in waste management. The draft Implementing Decision laying down rules for the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles ("draft Implementing Decision") represents a significant step towards enabling chemical recycling in the EU.

The undersigned organisations, representing civil society, business organisations and companies active along the waste management value chain, highlight that rules for calculating recycled content in plastics using a mass balance approach under the Single Use Plastics Directive (SUPD) will in influence market dynamics and shape the industry for decades to come.

The establishment of an EU mass balance method for calculating recycled content in plastics is vital to enable scale-up of chemical recycling. However, the current draft proposal effectively excludes existing refineries from the chemical recycling value-chain for EU recycled content targets with several critical impacts.

We welcome the Commissions revised draft implementing decision and appreciate that it now explicitly recognises chemical recycling and establishes a framework for mass balance accounting. These are important steps that will allow the EU to take a more comprehensive approach to recycled content, while keeping the focus on post-consumer waste in line with the objectives of Directive (EU) 2019/904.

European Commission's proposed approach assumes proportional mass balance and prohibits the transfer of assigned recycled content (attributed amount) dual-use products. It poses a significant risk to the development of this technology by limiting its profitability. It will disable flexible transfer of recycling credits in non-fuel products between two neighboring production sites.

ALPLA is a global leader in the development and manufacturing of rigid plastic packaging solutions. The company operates 200 manufacturing plants across 46 countries, employing over 24,000 people worldwide. ALPLA specializes in innovative packaging systems, bottles, closures, and injection-molded parts for industries such as food & beverage, cosmetics and pharmaceuticals.

At Vopak, we welcome the European Commission's draft Implementing Decision laying down rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles. The proposal, in our view, rightfully includes and acknowledges the role of chemical recycling to contribute to Europes circular economy and climate targets and ambitions.

Although the implementing decision pursuant to Article 6(5) SUPD only concerns single-use beverage bottles, it is of landmark significance for the implementing act pursuant to Article 7(8) PPWR and therefore for the entire plastic packaging market in Europe.

As a global provider of food and beverage packaging systems and solutions, such as aseptic beverage cartons, spouted pouches and bag-in-box , SIG welcomes the EU Commissions proposal for harmonised rules to calculate, verify and report on the recycled plastic content targets introduced by Directive (EU) 2019/904 on Single-Use Plastics (SUPD).

PU Europe represents the European polyurethane (PUR/PIR) insulation industry, covering factory-produced and in-situ formed PU foam. With over 110 manufacturing sites and more than 20,000 direct jobs including raw material suppliers, the sector contributes significantly to reducing building-related CO emissions and supporting the EU economy.

Evonik, a European world leader in chemistry, welcomes the opportunity to provide feedback on the draft implementing decision establishing rules for calculating, verifying, and reporting of chemically recycled plastic content in single-use plastic beverage bottles.

Danish Industry (DI) would like to thank the EU Commission for the opportunity to comment on this proposal. DI represents 20.000 Danish companies across many different industries and sectors. >A level playing field and continued investment in technology DI welcomes harmonized rules to calculate, verify and report the share of recycled plastic in sin-gle-use plastic bottles.

The Federation for the Environment and Nature Conservation (BUND) welcomes the possibility to provide feedback on the draft Implementing Decision on the calculation, verification and reporting of the content of recycled plastic in single-use plastic beverage bottles. We represent more than 650.000 members and donors.

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Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland. Westenergys waste-to-energy plant located in the Vaasa region takes care of the residual waste management of more than 700 000 people by refining non-recyclable, source separated municipal waste into district heating, electricity and recovered materials.

ETCORE EUROPE welcomes the new draft Commission Implementing Decision laying down rules for the application of Directive (EU) 2019/904 as regards the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles and repealing Commission Implementing decision (EU) 2023/2683 which supports the use of other recycling technologies than mechanical recycling, such as…

The LEGO Group welcomes the opportunity to provide feedback on the proposed implementing decision under the Single-Use Plastics Directive. Our perspective on the current draft implementing decision is that it will set an important precedent as the first EU-level definition of the mass balance accounting methodology in relation to plastics.

Sekab BioFuels & Chemicals AB appreciates the opportunity to comment on the proposed Commission Implementing Decision concerning methodologies for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles. This initiative represents a crucial step towards establishing transparent, harmonized standards for the use of recycled plastics in packaging across the EU.

1) We positively welcome the explicit mention that data must come from operational production and not from an industry average. Similarly, maintaining the prohibition of negative credits and the prohibition of credit exchange between sites or companies is positive. 2) Generally, the formulation proposed in the draft implementing decision goes against the principles of proportional traceability.

Perstorp welcomes the proposed IMPLEMENTING DECISION of 08 July 2025 Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. The definition and implementation of mass balance will significantly influence most stakeholders in the value chain, including end-consumers, brand-owners, manufacturing industry in a broad sense, including mechanical recyclers and…

Dansk Retursystem welcomes this opportunity to provide feedback on the European Commissions draft Implementing Act on harmonised rules to calculate, verify, and report the share of recy-cled plastic in single-use plastic beverage bottles. Please, find our feedback in the document attached.

The Corporate Forum Chemical Recycling (CFCR) as a part of the Thinktank for Industrial Resource Strategies is an association of companies along the value chain of chemical recycling in Germany, which comments on this announcement by the European Commission, in particular on the extent to which this draft adequately protects the competitiveness of German industry compared with other Member States and with imports.

Feedback on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the Implementing Decision proposal for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles.

LyondellBasell (LYB) welcomes the proposed draft implementing decision of Directive (EU) 2019/904, establishing a recycled content calculation methodology for single-use plastic beverage bottles. We support a clear, transparent and credible approach that recognizes chemical recycling of plastics - as a complementary technology to mechanical recycling - through the application of a fuel-use-excluded methodology for…

Plastics Recyclers Europe (PRE) provides comments on the draft implementing decision laying down rules for calculating, verifying and reporting recycled plastic content in single-use beverage bottles. Mass balance accounting plays a key role in supporting the transition to a circular economy and the development of emerging recycling technologies.

ELIPSO (professional association representing plastic packaging manufacturers in France) welcomes the finalisation of a method for accounting for tonnes recycled through chemical recycling processes, which is essential for the development of a large-scale circular economy and meeting the needs of various applications using recycled plastic as a complement to mechanical recycling.

Established in 2024, the Advanced Packaging Association (APA) brings together key industry stakeholders who recognize polyamide (PA) as a sustainable, high-performance material for packaging applications. APAs mission is to foster collaboration across the flexible packaging value chain, actively support the transition to a circular economy and provide fact-based, science-driven guidance on the integration of…

Created in 2021, Zéro Déchet Crest is a civic and independent association which promotes the preservation of natural resources and waste prevention, with a focus on reduction at source. In particular, we are alerting to the health and environmental impacts of waste treatment facilities on our territory.

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CEWEP welcomes the opportunity to provide feedback on the draft delegated act establishing common rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles.

Nordic Ecolabelling believes that there is a need to harmonize calculation methods. Rules for mass balance should be implemented with high caution, and they should be simple to apply and verify and based on controlled blending (proportional allocation at product level), enabling credible sustainability claims.

Port of Antwerp-Bruges (POAB) welcomes the opportunity to contribute to the European Commissions public consultation on the draft Implementing Decision laying down the rules for the application of Directive (EU) 2019/904.

CEFLEX welcomes the publication and public consultation on a draft SUPD Implementing Act on rules for calculating, verifying and reporting on recycled content. Our key messages are summarised here; please see the attachment for our more detailed feedback.

PlasticsEurope Italia welcomes the publication of the draft Implementing Decision on EU harmonised rules for calculating, verifying, and reporting recycled content in single-use plastic beverage bottles, with particular reference to the Commission's recognition of chemical recycling as a complement to mechanical recycling, its endorsement of a credit-based fuel-use excluded mass-balance methodology, and the intent…

We welcome the fact that the calculation method also includes caps and sleeves, as well as the correction for exports. This ensures that only what is actually placed on the national market is taken into account. The current text places chemical recycling on the same level as mechanical recycling.

Eastman, a specialty material company seeking to further invest in Europe, welcomes the European Commissions proposed Implementing Act under the Single-Use Plastics Directive (SUPD), which outlines the methodology for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles.

Zero Waste Bordeaux, founded in 2018, is an independent citizens’ association committed to preserving natural resources and reducing waste, with a focus on prevention and reduction at source. Lassociation expresses concern about the methodology adopted by the European Commission to calculate the incorporation of recycled material in single-use plastic bottles, which it considers problematic in several respects.

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Finnish Food and Drink Industries Federation welcomes the opportunity to provide feedback to the European Commission on the draft implementing regulation setting out harmonized rules to calculate, verify, and report the share of recycled plastic in single-use plastic (SUP) beverage bottles. We support the Commissions draft, particularly the recognition of chemical recycling as a valid recycling method.

Feedback on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

Plastic Energy, a leading chemical recycling technology provider, welcomes the EU Commissions draft implementing act on the Single Use Plastics Directive (SUPD) and support for chemical recycling technologies, especially through establishing the pathway for fuel-use excluded mass balance accounting methodology. We also endorse the feedback submitted by Chemical Recycling Europe (CRE), of which we are a member.

Veolia is firmly opposed to the proposed fuel exempt accounting methodology, which jeopardizes the credibility of recycling industry The Single Use Plastics Directive (SUPD) is targeting the implementation of a circular economy for plastics, based on a robust traceability, driven by the effective implementation of circular polymers back in the PET and beverage bottles offered to the European consumers.

At Promeco SPA, we endorse the feedback submitted by Chemical Recycling Europe (CRE) and Systemiq. We welcome the revised mass balance framework, as it provides essential clarity for investment and promotes fair competition between different chemical recycling operations.

Unilever welcomes the European Commission's initiative to establish harmonized rules for calculating and verifying recycled plastic content, including chemically recycled materials. The company supports a technology-neutral approach that promotes innovation, environmental integrity, and transparency. The paper outlines Unilever's position on the proposed methodology and verification requirements.

We welcome the European Commissions initiative to establish harmonized, transparent rules for calculating, verifying, and reporting recycled plastic content in single-use beverage bottles. Importantly, this draft also lays down rules for the application of mass balance accountinga significant step toward ensuring traceability and integrity across diverse recycling technologies.

The VOEB - Association of Austrian Waste Management Companies - would like to express its gratitude for the opportunity to comment on the European Commission's new Draft Implementing Decision for the implementation of Directive (EU) 2019/904 (SUPD) - please find our Statement attached.

Mura Technology is pleased to respond to the above consultation on the Implementing Act. Mura Technology is an advanced recycler of waste plastics, primarily processing the unrecyclable soft flexible plastics that are currently sent to waste to energy plants. Muras produces circular recycled oils for the plastic and other value chains.

Circ welcomes the European Commissions proposal on mass balance accounting rules for single-use plastic beverage bottles and supports its goal of creating a harmonized and future-proof framework. Our feedback reflects our experience as a global textile-to-textile recycler, where similar regulatory debates are underway.

The Danish Plastics Federation welcomes the Commissions efforts to establish harmonized rules for calculating and reporting recycled plastic content in single-use beverage bottles. While supportive of the overall objectives, some of our members raise concerns about potential loopholes and ambiguities in the draft that could undermine transparency and create uneven competition.

The German Construction Chemicals Industry Association supports the EU Commission´s efforts to establish mass balance (MB) accounting rules by enabling chemical recycling pathways under the draft SUPD IA. However, we would like to draw your attention to the fact that not all industrial branches and value chains can currently benefit from dedicated (segregated) production systems to answer customer demand for…

The Seas At Risk marine NGO network is pleased to share feedback on the draft Implementing Decision laying down rules for the application of the EU Directive 2019/904 as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

EuRIC - the European Recycling Industries Confederation - believes that developing robust and fair calculation methods for the recycled content is of paramount importance to ensure a level playing field for all recycling technologies.

The proposal for an implementing decision (on rules for single-use PET bottles) is a landmark, legislative acknowledgement of the mass balance model which recognises its necessity for recycled content targets. The credit mass balance fuel-use excluded (FUE) approach is indispensable for gradually shifting from traditional fossil to circular feedstocks, while using our existing assets.

Dear Sir/ Madam, Please find attached EUROPEN's contribution on the proposed implementing decision. The document outlines our suggestions on the draft text and elaborates on its interaction with the secondary legislation to be adopted under the Packaging and Packaging Waste Regulation. Kind regards, [name removed] - EUROPEN

Werner & Mertz welcomes the Commissions effort to establish a consistent and transparent methodology for calculating, verifying, and reporting the recycled content of plastics. We particularly appreciate the focus on using actual measured plant data and the explicit limitation of certain transitional provisions until a revision in 2030.

PET EUROPE welcomes the new draft of the second Implementing Act of the Single Use Plastics Directive, which supports the use of recycling technologies beyond mechanical recycling, such as depolymerization, that will contribute to achieving the European Unions recycling targets.

For the chemical recycling of polyester, we suggest aligning the SUP rules as much as possible with the Regulation EU 2022/1616 for chemical recycling to facilitate a smooth implementation. Non-EU material should not be included in the calculations of recycled content, as it does not solve the EU-waste challenge.

The Fair Resource Foundation appreciates the chance to provide feedback on the draft Implementing Decision concerning Directive (EU) 2019/904, which sets out rules for calculating, verifying, and reporting on recycled plastic content in single-use plastic beverage bottles.

As a company operating in the chemical industry and a fast-moving consumer goods company, secondary raw materials both for formulas as well as for packaging are of high relevance for Henkel. We see a transition to circularity as a responsibility shared with suppliers, partners, customers and stakeholders worldwide.

BlueAlp is a chemical recycling pyrolysis technology player for plastics in Europe with the following commercial plants using its technology: - Renasci: 21 kta in Oostend, Belgium, operating since 2020. - Recupero Etico Sostenible (RES): 20 kta in Pettoranello del Molise, Italy, to start up in 2026.

The BVSE - Federal Association for Secondary Raw Materials and Waste Management would like to express their gratitude for the opportunity to comment on the European Commission's new draft im-plementing decision for the implementation of Directive (EU) 2019/904 (SUPD).

At Itero, we endorse the feedback submitted by Chemical Recycling Europe (CRE) and Systemiq. We welcome the revised mass balance framework, as it provides essential clarity for investment and promotes fair competition between different chemical recycling operations.

The Rethink Plastic Alliance welcomes the opportunity to provide feedback to the Commissions draft Implementing Decision. In the attached document, we outline a number of concerns with the draft that we believe would endanger the transition to a clean, non-toxic circular economy.

Founded in 2015, Zéro Déchet Lyon is a civic and independent association promoting the preservation of natural resources and the prevention of waste, with a focus on reduction at source. With more than 150 members, we are alerting in particular to the health and environmental impacts of waste treatment facilities on our territory.

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General statement with regard to the Commission draft implementing decision on plastic recycled content for plastic beverage bottles by the Greens/EFA in the European Parliament 18 August 2025 It is of great concern that the Commission has disregarded the various points of objection adopted by the Committee on the Environment, Public Health and Food Safety of the European Parliament in April 2024 to the Commission…

Pöppelmann is a family plastic processing company founded in 1949 with approximately 2500 employees. At our three sites in Germany, France and the USA, we are developing and producing innovative plastic solutions for the automotive, food, medical and diagnostic sectors, general industry and horticulture.

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MOL Group welcomes the publication of the Commissions draft methodology for mass balance accounting rules for chemical recycling technologies, and calls for the swift adoption of the implementing act (IA) to secure legal certainty for the industry regarding new investments in chemical recycling.

Founded in 2017, Zero Waste Paris is a citizens’ and independent association that promotes the preservation of natural resources and waste prevention, with a focus on reduction at source. With more than 200 members, we are alerting in particular to the health and environmental impacts of waste treatment facilities in France.

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The IKEA business welcomes the proposed implementing decision on the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles (Directive (EU) 2019/904) issued on 08 July 2025. In IKEA, we use plastic and chemicals in packaging and products across different applications.

Repsol welcomes the efforts of the European Commission to advance the transition to a circular economy in Europe through the development of the Implementing Act under the Single Use Plastics Directive (SUPD). We appreciate the acknowledgment of the complementary role of chemical recycling in enabling the EU to achieve its ambitious recycled content targets and support the European Green Deal's climate and…

Verpact welcomes the initiative to develop rules for the calculation of post-consumer recycled plastics (PCR) in beverage bottles, based on the Single Use Plastics Directive (SUPD). We welcome the proposal for a harmonised calculation methodology. This is necessary and urgent to provide clear direction, break the current impasse and ensure alignment at the European level.

At ARCUS Greencycling Technologies GmbH, we endorse the feedback submitted by Chemical Recycling Europe (CRE) and Systemiq. We welcome the revised mass balance framework, as it provides essential clarity for investment and promotes fair competition between different chemical recycling operations.

Chemical Recycling Europe (CRE) Feedback submission by CRE on behalf of a group of companies representing key technology providers in the chemical recycling space with operational plants and projects in development across Europe (List of members: Agylix, Arcus, BlueAlp, Freepoint, Itero, LBC, Plastic Energy, Promeco, Pryme, Quantafuel, Siemens, 2GCPR) The revised mass balance framework represents advancement in…

As President of Castalie, I advocate a clear and verifiable method to account for recycled plastic content in bottles. The Commission is consulting a draft implementing decision introducing a mass balance fuel excluded framework (diverted flows to fuels/energy do not count) and providing for an annual third-party verification for chemical recycling (reduced to every three years for SMEs).

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Greene Enterprise is a chemical recycler converting post-consumer PP/PE film waste into pyrolysis oil that is upgraded (refining steam cracking polymerisation) into polyolefins for beverage-bottle caps. We support the draft Implementing Decision and its recognition that recycled content in caps made from chemically recycled polyolefins should be calculated via mass balance when exact proportions are unknown.

Today we express our concern about the methodology for calculating the incorporation of recycled material in single-use plastic bottles proposed by the Commission, which in our view presents many pitfalls. We are concerned that this draft decision aims to allow chemical recycling technologies such as pyrolysis to compete with the targets for the incorporation of recycled material, in a context where it is estimated…

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ANARPLA, the Spanish National Association of Plastic Recyclers, founded in 1994 and representing over 75% of the recycled plastic produced in our country, continuously develops key studies and documents for the sector.

2G Chemical Plastic Recycling (2GCPR) welcomes the opportunity to contribute to the consultation on the draft Implementing decision regarding recycled content in single-use plastic beverage bottles. We fully support the European Commissions ambition to drive higher levels of recycled content and to establish a transparent, verifiable mass balance framework.

In the Annex, the complete comments of the Union of Czech and Moravian Consumer Cooperatives on the draft Commission Implementing Decision (EU) on the calculation of recycled content in PET bottles pursuant to Directive (EU) 2019/904. A brief extract of the attached material below: 1.

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SCHP ČR has consistently advocated for the material recovery of plastic waste through chemical recycling methods, which we consider essential for achieving a circular economy. Without chemical recycling, it is impossible to ensure sufficient substitution of fossil raw materials and to promote the responsible use of plastics within the packaging, automotive, and other sectors.

The Czech technology platform Plastics is focused on supporting the Czech plastics industry and, as one of its development goals, supports all material utilization of plastic waste. One of the truly important elements here is the use of chemical recycling methods, which we consider to be another essential tool for achieving a true circular economy in the Czech Republic.

The Ministry of Economic Affairs, Industry, Climate Action and Energy of the State of North Rhine-Westphalia welcomes the endeavour to implement rules on the recycling of single-use plastic bottles. We would like to highlight the dual challenge currently facing European industry: not only must we decarbonise our energy systems, but we must also reduce our dependency on fossil-based raw material supply chains and…

Since HEXPOL Group think that the definition of Mass Balance as outlined in this Directive will pose as a model for further Directives and Regulations we would like to take the opportunity to provide feedback on application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage…

Set up in 2010, Collective 3R is a civic and independent association which promotes the preservation of natural resources and the prevention of waste, with a focus on reduction at source. In particular, we are alerting to the health and environmental impacts of waste treatment facilities on our territory.

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BDE advocates the polymers only method, which the EU Commission had originally proposed as a mass balance method. It ensures that only the recycled input that is actually used for the production of plastics can be counted. The revision clause in Art.

Set up in 2015, HOP – Halte at planned obsolescence is an approved environmental protection association which advocates extending the lifespan of products. As our work is directly linked to the circular economy, recycling issues are an integral part of our expertise topics. In this context, we are sensitive to the health and environmental impacts of waste treatment facilities in our territory.

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NABU welcomes the opportunity to submit a statement as part of the consultation on the Implementing Decision for the application of Directive (EU) 2019/904. This Decision specifies the implementation of the product requirements of the SUPD (Article 6) on the minimum content of recycled plastic in beverage bottles.

The European Environmental Bureau welcomes this opportunity to share feedback on the draft Implementing Decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

Faerch welcomes the draft and strongly supports the proposed framework, particularly the recognition of mass balance accounting, which is a necessary methodology for transitioning to a circular economy and scaling up chemical recycling. We also welcome the clear requirement for using actual operational production data to calculate recycled content.

UNESDA Soft Drinks Europe welcomes the European Commissions draft Implementing Act setting out harmonised rules to calculate, verify, and report the share of recycled plastic in single-use plastic (SUP) beverage bottles and supports its speedy adoption by Q4 2025. This act provides a critical foundation for the proper enforcement of the recycled content targets, already scheduled for application in 2025.

The Polish Union of the Cosmetics Industry welcomes the approach presented by the European Commission in the draft decision to set legal rules for the chemical recycling, to enable including the recyclates obtained from chemical recycling in the legally binding targets and set methodologies for counting the chemical recyclates.

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050.

FoodDrinkEurope welcomes the European Commissions draft Implementing Act on harmonised rules to calculate, verify, and report the share of recycled plastic in single-use plastic (SUP) beverage bottles. We support its adoption by Q4 2025, as it will provide legal clarity, support investment, and scale up recycling technologies crucial for the food and drink sector.

Versalis, Enis chemical company, welcomes the European Commissions proposed Implementing Act under the Single-Use Plastics Directive (SUPD), which outlines the methodology for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles.

GreenDot very much welcomes the draft proposal. 1. It provides clear recognition of chemical recycling of plastics, a critical capability necessary to enable the delivery of recycled content targets and recycling rate targets in the Single Use Plastics Directive (SUPD) and the Packaging and Packaging Waste Regulation (PPWR). 2.

We welcome the proposal for harmonized rules on mass balancing for plastics. However, the proposal seem to significantly slow down the introduction of chemical recycling and makes it difficult for the commission to reach its recycled content targets by reducing eligible input, propose proportional allocation and using fuel use exempt methodology. In the attached document a more detailed comment is given.

Fecc acknowledges the consultation on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content and welcomes the opportunity to provide input. As the leading voice for the European chemical distribution sector, we represent companies that play a vital role in the supply chain of plastics, ensuring compliance with regulatory requirements and maintaining high…

While we welcome the harmonised approach and the fuel exemption principle established in the draft Implementing Act, we note that certain provisions may create unnecessary administrative burdens for economic operators. For instance, recital (3) could better reflect the inclusion of novel recycling technologies alongside mechanical PET recycling and closed-loop processes, as acknowledged elsewhere in the draft.

The coil company, a French industrial player specialising in advanced chemical recycling of polyolefins, welcomes the European Commission’s initiative to establish a harmonised methodology for the calculation, verification and reporting of recycled plastic content in single-use plastic bottles, in accordance with Directive (EU) 2019/904.

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Flexible Packaging Europe, the material-neutral European association representing the converters of flexible packaging, supports the implementing act for calculating, verifying and reporting on recycled plastic content and urges the European Commission to swiftly approve it to ensure legal clarity.

Citeo welcomes the publication of the methodology of calculating the integration of recycled content with mass balance approach, which is essential for the development of an EU secondary material markets. We underline the following points: Support for the prioritization of mechanical recycling where quality allows, while recognizing the complementary role of chemical recycling to improve overall recycling…

With regard to preventive health and environmental protection, WECF considers some points of the draft as critical. In the face of the worsening plastic crisis, human health and livelihoods are under acute threat. Microplastics and harmful additives of plastic are already found in soils, food, children, placenta, etc.

Filed in German · English published by the European Commission

The Volkswagen Group anticipates that the rules for calculation, verification and reporting of data on chemically-recycled plastic content in single-use plastic beverage bottles could serve as a blue print for future rules in other sectors. We are therefore participating in this consultation to ensure that automotive-specific considerations are appropriately reflected.

Support for the proposed calculation method under the condition that a level playing field for mechanical recycling is created by allowing credit trading according to the CRC dossier. See attachment with link to dossier. The dossier has been submitted to DG Env several moths ago .

We wish to provide the following observations on the draft implementing decision to ensure the regulation meets its environmental objectives while remaining technically feasible and scientifically robust. + Inclusion of the mass balance approach as a prerequisite Limiting compliance to physical segregation of recycled materials is incompatible with the realities of modern polymer production, which is characterised…

NRW.Energy4Climate welcomes the endeavour to implement rules on the recycling of single-use plastic bottles. In the attached file, we would like to provide feedback on the current draft and outline possible adjustments and recent debates on the North Rhine-Westphalian (NRW) level.

Please find herewith our input and commentary points for EU Single Use Plastics Directive Implementation: 1. Draft Fails Core Environmental Objectives Issue: The proposal allows recycled content claims without ensuring materials actually return to plastic production, contradicting the Directive's circular economy goals.

ECOS welcomes the opportunity to provide feedback to the European Commissions draft implementing decision overhauling the EU rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles and repealing the current decision (EU) 2023/2683.

MAIRE Group emphasizes the significance of the document's explicit acknowledgement of the pivotal role of chemical recycling. This plastic recycling process is particularly valued as it enables the management of plastic waste that cannot be recycled with currently available mechanical recycling technologies.

The European Chemical Regions Network (ECRN) welcomes the European Commissions draft Implementing Decision laying down rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles, in line with Directive (EU) 2019/904.

This document provides feedback from the DigitalTrade4.EU consortium to the European Commission on the digitalization of recycled plastic content reporting for single-use beverage bottles. It emphasizes the strategic importance of the Digital Product Passport (DPP) in enhancing transparency, traceability, and compliance across the EU Single Market.

Sustainable circular economy mechanically and chemically The circularity of packaging makes an important contribution to resource and climate protection. It reduces the demand for fossil raw materials and thus saves CO emissions. As packaging is produced in large quantities in households, commerce and industry, its recycling into the material cycle is a key area of action for a functioning circular economy.

Filed in German · English published by the European Commission

We welcome the draft Implementing Decision and its support for mass balance accounting and chemical recycling pathways. We would like to draw attention to the role of regenerated solvents and intermediates, such as monoethylene glycol (MEG) or monopropylene glycol (MPG), which are commonly used in glycolysis-based chemical recycling of PET.

We support the Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment, but we would like to give our feedback on the draft implementing decision. First, we would like to reinforce the fact that chemical recycling technologies (specifically depolymerization technologies that convert waste plastic into monomers, then back to virgin-quality polymer) should be included in…

Executive summary SUEZ welcomes the European Commissions proposal on the implementing decision on the recycled plastic content in single-use plastic beverage bottles. In this position paper SUEZ wants to highlight some remarks on the proposed legislation.

This is a submission on behalf of the NGO Coalition Exit Kunststoff. Members of the Coalition are: a tip: TAP e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., Heinrich-Böll-Stiftung, HEJSupport e.V., Küsten gegen Kunststoff e.V., Surfrider Foundation Germany e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. and Zero Waste Kiel e.V.

Filed in German · English published by the European Commission

Petcore Europe welcomes the European Commissions efforts to support the implementation of the Directive on Single-Use Plastics (Directive (EU) 2019/904, also known as SUP Directive). The SUP Directive remains the main instrument to encourage responsible consumer behaviour and to promote the transition to a circular economy with innovative and sustainable business models and products.

Filed in French · English published by the European Commission

The proposed act itself introduces separate reporting on the recycled content per component (bottle, cap and label) for the economic operator (packaging producer and/or user) and places the burden of data collection, coordination and supervision on the responsibility of the MS.

The delegated act on recycled content in PET includes elements that cause great concern for the level playing field, credibility and innovation regarding recycling of all plastics in the future. This delegated act may serve as a blueprint for other legislation and is therefore very worrying.

EXPRA is pleased to provide the following feedback on the draft. If a non-plastic (for example paper) label is a part of the bottle, the methodology requires that it is deducted from the weight of the plastic bottle.

We are a German nature conservation organisation and represent around 700.000 members. Together with other NGOs, we share feedback as an alliance Exit Plastic. At this point we want to once again, as an association, to criticise the concept of mass balancing as such. In our view, there is a risk to the protection of resources, so as to protect climate change and, in particular, to transparency for consumers.

Filed in German · English published by the European Commission

From ITENE (Institute of Technology for Packaging, Transport and Logistics) we have prepared and attached our comments and contributions to the Draft Decision on "Booking for single-use plastic drinks: EU rules for calculating, verifying and reporting recycled plastic content

Filed in Spanish · English published by the European Commission

Eastman believes the SUPD draft implementing act phase I, which is limited to mechanical recycling of PET beverage bottles, is a missed opportunity in reducing Europes plastic waste production and increasing plastic recycling across the bloc. When it comes to waste management and circularity, Eastman believes that mechanical recycling should be leveraged whenever possible.

PET Europe - feedback to the public consultation on the Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content initiative. PET EUROPE is a non-profit trade association that represents the European PET resin producers. PET EUROPE represents an industry with a capacity of 3.5 million tonnes of Virgin PET (vPET) per year.

ECOS welcomes the opportunity to provide feedback to the European Commission on the implementing decision laying down common rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles.

The Spanish Food and Drink Federation (FIAB) welcomes the European Commission methodology to calculate, verify and report the recycled content in single use plastic beverage bottles, and appreciates the opportunity to share its views through the ongoing public consultation. The main FIAB suggestions are summarized in the attached document.

Dear all, Please find attached UNESDA - Soft Drinks Europe's comments on the draft Decision laying out EU rules for calculating, verifying and reporting recycled plastic content in single-use plastic beverage bottles. Kind regards, [name removed] UNESDA Policy Manager [email removed]

ClientEarth welcomes the opportunity to respond to this consultation. Although the purpose of this implementing decision is to establish criteria for reporting data for the purposes of assessing whether Member State level obligations are met, this implementing decision will set a precedent with knock-on implications for decisions regarding how recycled content is to be assessed for other purposes, including those…

Citeo underlines the risk of misunderstanding and legal uncertainty with the existence of definitions of recycled plastic in two legal instruments. In order to calculate the weight of the beverage bottle, Citeo believes all the components should be taken into account and not only the plastic parts of the beverage bottles.

Cefic welcomes the Commissions ongoing effort in preparing the Implementing Act laying down rules regarding the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles under the Single Use Plastics Directive (SUPD).

This draft implementing decision concerns the target according to Article 6(5)(a) SUP Directive that Member States shall ensure that from 2025, PET bottles shall contain at least 25 % recycled plastic, calculated as an average for all PET bottles placed on the market on the territory of that Member State.

Zero Waste Europe welcomes the opportunity to provide feedback on the implementing decision laying down common rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles. Since the adopted methodology will be the first of this type, it will create a precedent for the upcoming legislative pieces.

This feedback is being submitted by the Malta Business Bureau as the EU business advisory organisation of The Malta Chamber of Commerce, Enterprise and Industry, and the Malta Hotels and Restaurants Association.

The European Sustainable Business Federation Ecopreneur.eu - welcomes the European Commissions initiative to define a common methodology for calculating, verifying and reporting recycled content in beverage bottles, as introduced by Directive (EU) 2019/904 on Single-Use Plastics (SUPD), and in other products and materials.

ANEC strongly calls for minimum recycled content requirements for plastic packaging to be aligned with the Chemicals Strategy for Sustainability and combined with: - objectives to minimize and phase out hazardous substances, and - requirements for information on content of hazardous substances to be included in the Packaging and Packaging Waste Regulation (PPWR).

The first relevant question for us is whether the provision to Member States of data on recycled plastic content in single-use plastic beverage bottles also applies to preforms, as the text only refers to PET bottles. The term placed on the market refers to a product that is included in Part F of Annex SUP D: beverage bottles, including their nuts and lids.

Filed in Polish · English published by the European Commission

The Danish AgriFish Agency has the following comments on the rules for calculating, verifying and reporting genaxible plastic content: Recital 10 It is essential that controlled blending and mass balance principles are included in a future review so that new technologies can come into play, such as non-mechanical recycling.

Filed in Danish · English published by the European Commission

Swedens comments on the proposed implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles Thank you for the possibility to comment on the new proposal.

Dear Members of the Commission, Perstorp is a chemical company with 140 years of experience, committed to the transformation to sustainable chemicals. In the draft act Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content a reference to the chain of custody standard ISO 22095 is included.

The first relevant question for us is whether the provision to Member States of data on recycled plastic content in single-use plastic beverage bottles also applies to preforms, as the text only refers to PET bottles. The term placed on the market refers to a product that is included in Part F of Annex SUP D: beverage bottles, including their nuts and lids.

Filed in Polish · English published by the European Commission

CEWEP welcomes this proposal by the Commission and would like to stress in the attached document the principles that should be followed when drafting rules to calculate recycled content: Any waste treatment operation should be regulated under EU waste legislation. Reprocessing of waste into fuels is an energy recovery operation.

Plastics Europe is the pan-European association representing plastics manufacturers with offices across Europe. With close to 100 members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable.

Sekab, as a chemical company with many years of experience in producing sustainable biobased chemicals based on ethanol, wants to provide feedback on the draft act titled "Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content".

Ladies and gentlemen, on behalf of the Polish Federation of Food Producers of the Association of Employers, we have objections to the draft decision and more precisely to the definition of beverage bottle (Article 1). According to that definition, bottles include caps and lids and labels and wrappers.

Filed in Polish · English published by the European Commission

Brussels for Human Rights and Developments (BHRD) welcomes the European Commission's draft act on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. We believe that the act is a significant step forward in the EU's efforts to reduce plastic waste and promote the circular economy.

EUROPEN - the European Organisation for Packaging and the Environment - supports the adoption of detailed rules for the calculation, verification and reporting of the recycled content targets introduced by Directive (EU) 2019/904 on Single-Use Plastics (SUPD) to ensure the harmonised transposition of its requirements across EU Member States. Please see in the enclosed document our detailed feedback.

SEAS AT RISK welcomes a consultation of this implementing act of the Single-use plastics' Directive. First, we would like to underline a problem in the calculation baseline between the proposal under consultation and the SUP Directive. In the articles 3.1 and 4.1 of the proposal, the weight of plastic is calculated based on the amount of plastic collected from economic operators.

Dear commission members, I turn to you after reading the draft act Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. In this act you refer to the ISO standard, ISO22095, as if this standard would define what mass balance is and how it should be used.

With more than 730 facilities generating an annual turnover of 8.7 B, offering an installed capacity of 11.3Mt and employing more than 30,000 persons, the EU plastic recycling industry is a key player on the global scale.

Good Morning I write from the company www.ypsicon.com With the following link video about the technology https://www.youtube.com/watch?v=ixDYGZ8jF1I I detail a possible use of UVC technology, which could be installed in modules on all supermarket shelves. And make companies not using packaging, but referring Bag in box for their products. And that that manufacturers can then fill each pet bootles.

Filed in Spanish · English published by the European Commission

Dear experts, I would like to draw your attention to the recycled content calculation contained in DIN SPEC 91446:2021-12, (now also as active Work Item WI 00249A5E at CEN / CENELEC TC249/WG11. In Section 6.2, it provides a detailed basis on calculating recycled content in a compound/at resin level, featuring 4 scenarios: - Polymer compound without fillers in the recyclate proportion - Polymer compound with fillers…

It should be noted and the Commission should be aware of that the EuroStat reporting tool does not allow to report mass balance related recycling rate and recycling goals. The entry into force of the implementing act or the reporting obligations cannot be hindered by a technical issue in the reporting system the Commission is using to track evidences of compliance.