EU-wide end-of-waste criteria for plastic waste

The proposed draft implementing regulation constitutes a very important step towards increasing plastics recycling rates in the European Union; however, from the perspective of facilities processing waste electrical and electronic equipment, it unfortunately limits the ability to properly process plastics generated during recovery operations.

The Portuguese Plastics Industry Association (APIP) supports the European Commissions objective of establishing harmonised EU-wide End-of-Waste (EoW) criteria for plastics, recognising their key role in advancing the circular economy, industrial competitiveness and the uptake of secondary raw materials within the internal market.

This feedback submission by Systemiq Ltd is on behalf of 7 companies and associations representing the value-chain for packaging manufacturing and recycling in Europe, including, Multinational petrochemical companies: Borealis, LyondellBasell, MOL Group, Versalis Multinational technology providers: Axens Trade association for chemical recycling: Chemical Recycling Europe Multinational plastic waste management…

Amcor supports clear, workable and EU-harmonised end-of-waste criteria for plastics that strengthen the Single Market for recycled plastic outputs and support investments in circular packaging. However, as drafted, several elements of the proposed criteria are unclear or unfeasible in practice and risk significantly reducing recycling rates and recycled content availability for polyolefin-based flexible packaging…

CRE welcomes the Commissions initiative to establish harmonised EU-wide EoW criteria for plastic waste. Clear and consistent rules are essential to support the functioning of the internal market, reduce administrative burdens and facilitate investment in circular solutions for plastics.

Consultation response on the draft Commission Implementing Regulation on End-of-Waste criteria for plastics Verpact welcomes the initiative to establish harmonised EU-wide end-of-waste criteria for plastic waste, as this is an important step towards strengthening the internal market for recycled plastics and facilitating the circular economy.

Axens positively acknowledge the significant effort undertaken by the European Commission in preparing the draft Implementing Act establishing EU wide end of waste criteria for plastic waste. This initiative represents an important step toward creating legal certainty, enhancing cross border harmonisation, and supporting the development of a competitive circular plastics value chain in Europe.

VinylPlus welcomes the EUs initiative to develop and harmonise recyclate-specific EoW criteria at EU level and supports the contributions made by Plastics Europe, European Plastics Converters (EuPC) and Plastics Recycling Europe (PRE). As a complement, we would like to stress in particular the following points: 1.

ANARPLA welcomes the European Commissions initiative to establish harmonised end-of-waste (EoW) criteria for plastic waste. A single EU-wide framework would improve the functioning of the internal market for secondary raw materials, reduce administrative burdens, provide legal certainty and strengthen the circular economy, while ensuring a high level of environmental and human health protection.

Irish Manufacturing Research (IMR), in its capacity as the secretariat of CIRCULÉIRE and on behalf of its members, welcomes the draft EU End-of-Waste (EoW) Plastics Regulation as a necessary step towards a more coherent, transparent, and reliable market for circular plastics.

In response to the European Commissions public consultation on the EU-wide End-of-Waste (EoW) criteria for plastic waste, this statement outlines the Climate Leadership Coalitions (CLC) position on the proposed initiative.

The Rethink Plastic Alliance welcomes the opportunity to provide feedback on the Commission's draft Implementing Regulation to set harmonised End-of-Waste (EoW) criteria for plastics in the EU. Overall, we welcome the proposed EoW criteria for plastics but we urge the EU to strengthen the criteria for eligible inputs and control mechanisms to ensure genuine circularity.

EU regulations that promote harmonisation and the reduction of bureaucracy are explicitly supported by The Corporate Forum Chemical Recycling (CFCR), an association of companies along the value chain of chemical recycling in Germany. However, the current draft fails to meet this objective in key areas and thereby jeopardises investment, innovation, and Europes competitiveness in the circular economy.

The Italian supply chain, the association that supports and enhances the 100 % Italian agri-food chain, welcomes the European Commission’s initiative to gather opinions on the topic of plastic waste in relation to end-of-waste criteria across the EU. Please see attached the detailed position paper.

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Coldiretti, the largest farmer representative organisation in Italy and Europe, with its 1.6 million members, welcomes the European Commission’s initiative to gather views on the topic of plastic waste in relation to end-of-waste criteria across the EU. Please see attached the detailed position paper.

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BlueAlp is a leading European chemical recycling technology provider and recycler, converting mixed plastic waste through pyrolysis into high-quality circular oil feedstock (pyrolysis oil) for the petrochemicals industry to produce new high-quality plastics. BlueAlps operations and partnerships span multiple Member States.

Dear Director General Mamer: The U.S. Chamber of Commerce appreciates the opportunity to provide comments on the European Commissions initiative to harmonize end-of-waste criteria for plastics. The U.S. Chamber is the worlds largest business organization, with members that range from small businesses and local chambers of commerce to leading industry associations and global corporations, to emerging and fast-growing…

Federation of Slovak Industry and Transport Associations welcomes the EU Commissions objective to develop harmonized end-of-waste (EoW) criteria for plastics(-related) waste, which is essential to foster circular economy, ensure a stable supply of high-quality recycled materials across various value chains, provide regulatory and investment certainty, and reduce administrative burden, shipment and feedstock costs.

The European plastic recycling market continues to struggle, as recycled polymer demand remains weak with no signs of improvement. The recent package announced by the European Commission on 23 December, aimed at accelerating the EUs transition to a circular plastics economy, marks an important first step toward strengthening plastic recycling in Europe.

IE welcomes the publication of the Commissions proposal for EU-wide End-of-Waste criteria for plastic waste. A harmonised approach to End-of-Waste for plastic is important to deliver circular economy ambitions and will help Member States attain targets across several pieces of legislation, including PPWR.

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the implementing regulation establishing EU-wide End-of-Waste (EoW) criteria for plastic waste. The introduction of an EU-wide EoW framework for plastics is a positive and necessary step towards the development of a market for plastic recyclates in the EU.

VCI welcomes the opportunity to contribute to the public consultation on the draft Commission Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for plastics derived from mechanical and solvent-based recycling.

The Versnellingstafel Chemische Recycling (VTCR) supports the EUs move to harmonised endofwaste (EoW) criteria for plastics from mechanical and solventbased recycling. To deliver Europes circularity and recycledcontent goals, we urge the Commission to develop in parallel a dedicated EoW framework for chemical recycling.

To ensure a level playing field across all recycling technologies and to support the EUs circularity and climate objectives, we urge the European Commission to promptly initiate work in parallel on an implementing regulation covering additional recycling technologies and to clarify key elements of the current proposal. 1.

EUROPEN believes that the timely publication of harmonised end-of-waste (EoW) criteria is essential to ensure a consistent approach across all Member States, foster a level playing field, provide legal certainty for economic operators, and support the scaling-up of recycling in Europe.

Flexible Packaging Europe (FPE) supports and fully aligns with the position submitted by CEFLEX on the draft Implementing Act establishing EUwide endofwaste criteria for plastics. As the association representing converters of flexible packaging, FPE is particularly concerned about the downstream impacts of the proposal on converters ability to source and use recycled polyolefin pellets.

The Association of Austrian Waste Management Companies (VOEB) welcomes the European Commission’s initiative to establish harmonised EU-wide end-of-waste criteria for plastics on the basis of the Waste Framework Directive. These are essential for the creation of a strong internal market for recyclates.

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Borealis welcomes this initial proposal for an implementing regulation to lay down rules as regards criteria to determine when plastic waste ceases to be waste. Noting that the Commission has taken the approach of establishing this point at the output of the recycling operation, which is the correct approach to boost a European market for secondary raw materials made from plastic waste.

La FNADE fédération française des activités de gestion des déchets et des services à lenvironnement, soutient lobjectif de la Commission visant à établir des critères européens harmonisés de sortie du statut de déchet (SSD) pour les plastiques recyclés, afin de renforcer le marché intérieur des matières plastiques recyclées et la confiance dans les recyclats européens.

The Environment – Recovery of Plastic Materials, S.A. parabenises the European Commission for the proposal in question, which is of key importance in the current context. The citations for End-of-waste converge with the end of the waste status in force in Portugal, governed by Ministerial Implementing Order No 245/2017, as a result of the transposition of Directive 2008/98/EC of the European Parliament and of the…

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Inter IKEA Group welcomes the European Commissions initiative to establish EU-wide end-of-waste (EoW) criteria for plastic waste. A harmonised, fact, and risk-based framework is essential to strengthen the internal market for plastic recyclates, reducing administrative burdens, and providing legal certainty for recyclers operating across borders.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the Commissions efforts to establish EU-wide end-of-waste (EoW) criteria for plastic waste under Article 6 of the Waste Framework Directive.

Plastics Recyclers Europe (PRE) welcomes the European Commissions initiative to establish EU-wide end-of-waste (EoW) criteria for plastic waste. PRE has long supported harmonised EoW criteria as a key tool to strengthen the internal market for plastic recyclates, reduce administrative burden, and provide legal certainty for recyclers operating across borders.

The Food and Beverage Carton Alliance (FBCA) welcomes the opportunity to contribute to the EU Commissions public request for feedback on the Draft Implementing Act that aims to establish criteria to determine when plastic waste ceases to be waste.

Given the ambitious and mandatory plastic waste recycling targets set by European legislation, as well as the significant challenges currently facing the polymer recycling sector at EU level, MAIRE Group expresses its support for the European Commission's public consultation on the draft implementing regulation that proposes harmonized end-of-waste (EoW) criteria for plastic waste.

The feedback available in the attached document. EUMEPS remains committed to constructive engagement with the Commission and stands ready to contribute further to the development and implementation of a workable and future-proof End-of-Waste framework for plastics.

The Volkswagen Group fully supports advancing the European Union into a modern, resource-efficient and competitive economy. Therefore, we welcome the Commissions proposal to define criteria for when plastic waste ceases to be waste on the basis of the already existing regulation for steel scrap ((EU) 333/201199).

LyondellBasell (LYB), a leader in the global chemical and plastics industry aiming to be at the forefront of Circular and Low-Carbon solutions, welcomes the European Commission initiative to develop EU-wide end-of-waste (EoW) criteria for plastic waste.

Valmet considers it important that the European Commission is advancing EU-wide, harmonised end-of- waste (EoW) criteria for plastics. Such criteria are essential for creating a functioning single market for recycled plastics, and for providing the predictability and clarity companies need to confidently commit to new investments in Europes circular plastics value chains.

Versalis, Enis chemical company, welcomes the European Commissions intention to propose an Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for mechanically and solvent based recycled plastics.

ELIPSO is the professional association representing French manufacturers of rigid and flexible plastic packaging. We support and advocate for our 125 members - primarily small and medium-sized enterprises - on key transformation issues, particularly the ecological transition toward a circular economy, in an increasingly complex regulatory landscape.

The European Resilient Flooring Manufacturers Institute (ERFMI) is pleased to provide feedback on the European Commissions Call for Evidence on EU End-of-Waste criteria for plastics. The attached submission focuses on sector-specific considerations relevant to resilient flooring. For all other aspects not explicitly addressed, ERFMI aligns with the positions of European Plastics Converters (EUPC) and VinylPlus.

EuPC welcomes the EC initiative to adopt End of Waste for plastics recyclates obtained through mechanical and solvent based recycling at European level since it should reduce administrative burden and inefficiencies (including but not limited to storage cost, limitations for placing product on the market, hindrance to access to raw materials) due to divergent National/regional interpretations and implementation of…

ANEC has long emphasised that a safe and genuine circular economy must be founded on strong rules for the elimination of hazardous substances throughout the entire product lifecycle. In particular, legacy hazardous substances present in existing waste streams shall not re-enter the economy through recycling (https://tinyurl.com/j3svhj8z).

BASF welcomes EU Commissions aim to develop EU-wide end-of-waste (EoW) criteria for plastics waste which is essential to foster circular economy. Herewith, we would like to provide input to the public consultation on the draft Commission Implementing Regulation. In the short term, it is essential to set EU-wide EoW criteria for various waste streams entering various recycling routes.

The suggested directive aligns with the vision of the Innovation action MICROORC (Grant Agreement N° 101136248 ) which aims to increase the use of food packaging materials that are easy to recycle, with highest-quality recyclate, and most compatible with food-contact recycling.

Municipal waste management is an essential pillar of a functioning circular economy and, through the collection and sorting of waste, enables the provision of secondary raw materials or their precursors. The objective of creating a sustainable and permanently established European circular economy is expressly welcomed by the Austrian municipal waste management sector.

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The Port of Rotterdam and Port of Antwerp-Bruges fully support the EUs ambition to strengthen Europe's strategic autonomy and accelerate the shift toward a circular economy. We welcome the Commissions initiative to establish End of Waste criteria for mechanical and solvent-based recycling of plastics that can drive decarbonisation, job creation and a competitive internal market for circular products.

With regard to the European Commission’s draft regulation on End of Waste criteria for plastics, published on 23 December 2025, the Polish Recycling Association makes the following comments: 1. Outcome-based approach We stress that compliance with the EOW criteria should be assessed on the basis of the characteristics of the final product and not limited upfront by the type and quality of the input stream.

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The Port of Antwerp-Bruges and the Port of Rotterdam fully support the EUs ambition to strengthen Europes strategic autonomy and accelerate the shift toward a circular economy. We welcome the Commissions initiative to establish End of Waste criteria for mechanical and solvent-based recycling of plastics that can drive decarbonisation, job creation and a competitive internal market for circular products.

We support the Commissions objective to harmonize end of waste criteria for plastics to strengthen the Single Market for high quality recyclates, lower administrative burdens and enhance traceability and safety.

EPRO and EXPRA members support the development of harmonised end of waste legislation across the Union. The two Associations have prepared a joint Position Paper on the draft Implementing Regulation to develop end of waste criteria (EoW) for plastic, with input from members of both Associations.

France Chimie welcomes the opportunity to provide input to the public consultation on the draft Commission Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for plastics from mechanical and solvent-based recycling.

(1) uniform European end-of-waste criteria for plastics are a very good idea: with our European branches, we see large differences in interpretation between countries, leading to unnecessary administrative burdens and legal uncertainty. 2) this will immediately create a number of conditions for implementation a. The proposal should provide legal certainty.

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The European Commissions initiative to introduce harmonised End-of-Waste (EoW) criteria for plastics is welcomed as an important step towards strengthening the internal market for secondary raw materials and improving legal certainty for operators.

EXPRA and EPRO members support the development of harmonised end of waste legislation across the Union. The two Associations have prepared a joint Position Paper on the draft Implementing Regulation to develop end of waste criteria (EoW) for plastic, with input from members of both Associations.

BEWI welcomes the EU-wide end-of-waste (EoW) criteria initiative. As a producer of 100% recyclable plastic products and an active user of recycled raw materials, BEWI sees a strong need for harmonised regulations and criteria across the European market.

We support the European Unions objective of creating a robust, transparent and environmentally sound framework for plastic recycling. We recognise the importance of end-of-waste criteria in safeguarding human health, protecting the environment and enabling a functioning market for secondary raw materials.

ACN feedback on the draft Implementing Regulation on end-of-waste criteria for plastic waste The Amsterdam Chemistry Network (ACN) welcomes the Commissions initiative to establish EU-wide end-of-waste (EoW) criteria for plastics. This is a key step to strengthen the single market for recyclates, reduce administrative burdensespecially for SMEsand unlock investment in Europes circular plastics value chains.

ACEA supports the development of clear, robust and harmonised End-of-Waste (EoW) criteria to ensure that recycled plastics re-enter the economy safely and in full compliance with EU legislation on substances of concern, including legacy substances present in certain waste streams.

Mura Technology is pleased to respond to the above consultation on the Implementing Regulation. 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. Our full response is attached.

The draft implementing regulation, which proposes EU-wide end-of-waste criteria for plastic waste, explicitly refers to physical recycling (i.e., mechanical and solvent-based recycling). This restriction makes sense in relation to chemical recycling. Chemical recycling follows different process steps than physical recycling and initially produces intermediates rather than polymers directly.

AVR is an innovative Waste-to-Energy (WtE) treatment facility based in Rotterdam and Duiven (NL). With its post-separation installation, AVR was able to retrieve secondary raw materials such as minerals, metals and plastics from the incoming waste. In 2024, AVR was able to retrieve 19,1 tonnes of plastics alone from the residual waste, contributing its part to support the European circular economy.

Position paper on the draft criteria for EU-wide end-of-waste status for plastic waste (Implementing regulation laying down rules for the application of Directive 2008/98/EC in regards of the criteria determinin the end-of-waste status for plastic waste) A. Remark The bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V.

CEFLEX supports clear, workable and EU-harmonised end-of-waste criteria for plastics that strengthen the Single Market for recycled plastic outputs. Please see our detailed submission attached. Key points: As drafted, several elements of the proposed criteria are unclear or unfeasible in practice and risk significantly reducing recycling rates for polyolefin-based flexible packaging.

1. Reusable Plastic We welcome the European Commissions initiative to introduce EU-wide End-of-Waste criteria for plastics. Where materials can be REUSED directly (for example, surplus rolls), the criteria should be simple and practical, even if such materials are transported as multilayer waste.

The draft act on end-of-waste criteria for plastic waste, published on 23.12.2025, aims to establish EU-wide end-of-waste criteria for plastic waste. The draft is adopted as an implementing act under Article 6(2) of the Waste Framework Directive (2008/98) and specifies the uniform application of the end-of-waste conditions to certain types of waste.

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The Association of Municipal Enterprises (VKU) welcomes the European Commission’s objective of setting harmonised EU-wide end-of-waste (EoW) criteria for thermoplastics for the first time with this draft implementing regulation. A single regulatory framework offers opportunities for reliable source streams, higher recyclate quality and compliance safety.

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This submission is made on behalf of SynPet Technologies, a developer of circular chemical feedstocks. SynPet is progressing its planned Antwerp facility at the Port of Antwerp, targeted for deployment in 2028. SynPet Technologies welcomes the European Commissions initiative to establish harmonised EUwide EndofWaste (EoW) criteria for plastic waste.

Motor Oil Group operating as a diversified energy enterprise integrating waste management operations throughout its subsidiary portfolio, welcomes EUs public consultation and given opportunity to comment on the Draft Act to establish EU-wide end-of-waste (EoW) criteria for plastic waste as for the application of Directive 2008/98/EC.

The Danish Plastics Federation welcomes the Commission's initiative to develop end-of-waste criteria for plastic waste and offers our feedback. The Danish Plastics Federation supports the objective of establishing harmonized end-of-waste criteria for plastics as clear differentiation between waste and recycled plastics is essential for the functioning of the internal market and for promoting a circular plastics…

Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our 200 members, both private and public companies, handle materials across all waste streams. We have over 30 years of industry-specific expertise in promoting and developing responsible waste management and circular economy policies.

The Austrian Federal Economic Chamber welcomes the European Commission's initiative to establish harmonized, EU-wide end-of-waste (EoW) criteria for plastic waste in accordance with Article 6(2) of the Waste Framework Directive and appreciate the opportunity to provide feedback aimed at further enhancing their clarity, practicality, and harmonised implementation in the EU.

Cefic welcomes the opportunity to provide input to the public consultation on the draft Commission Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for plastics from mechanical and solvent-based recycling . We recognise this as a positive step towards harmonisation, regulatory certainty, and the development of a well-functioning internal market for recycled plastics.

VTT Technical Research Centre of Finland welcomes the European Commissions draft End of Waste (EoW) regulation for recycled plastics. The regulations objectives strengthening market demand, reducing costs in the value chain, and ensuring protection of the environment and human health are essential for the growth of plastic recycling in Europe.

The draft Implementing Regulation on the End of Waste (EoW) criteria for plastic waste, which is due to enter into force on 1 July 2026 and is currently subject to public consultation, falls within the scope of Article 6 of Directive 2008/98/EC (Waste Framework Directive WFD). The main objective of the Regulation is to promote the single market for secondary raw materials and promote the circularity of plastics.

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UBQ Position: Strengthening the EU Plastics Pilot (COM/2025/805) UBQ Materials welcomes the European Commissions commitment to reinforcing the circular economy and the single market for secondary raw materials. We support strengthening the single market for waste and secondary raw materials using a broad definition of secondary materialsexplicitly including thermoplastic compositesand extending beyond conventional…

Federchimica welcomes the Commision initiative to establish EU-wide end-of-waste (EoW) criteria for plastics from mechanical and solvent-based recycling as a positive step towards harmonisation and development of a well-functioning internal market for recycled materials.

Kolmar Group AG Position on the Draft Implementing Regulation on End-of-Waste Criteria for Plastic Waste Date: 26 January 2026 This submission is made on behalf of Kolmar Group AG who is an investor in SynPet Technologies, and the marketer of circular chemical feedstocks from the SynPet Technologies asset Antwerp, to be deployed at the Port of Antwerp in 2028.

IFPEN's Feedback on the Proposal for End Of Waste Status Regulation The establishment of a regulation that clarifies and standardizes the conditions for exiting waste status across Europe is an essential and structuring step for the realization of industrial projects and the emergence of a circular plastics economy.

Bifa Umweltinstitut GmbH welcomes the plan to set uniform requirements across Europe for the loss of the waste status of plastic waste. Bifa is an application-oriented research, development and advisory institution that provides tailored, wide-ranging environmental services and conducts research for practice. Among other things, we deal with the processing of waste, e.g.

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In the context of the ongoing public consultation, ExxonMobil hereby submits its response regarding the criteria to determine when plastic waste ceases to be waste. This contribution aims to support the development of clear, harmonised, and evidencebased endofwaste criteria that enhance legal certainty, promote highquality recycling, and foster a wellfunctioning internal market for secondary plastics across the…

We recognise End of Waste" (EoW) regulation is strategic for the proper management of post-consumer plastic packaging. However, some points in the current proposal need to be considered to remove limitations, specifically the removal of restrictions on recovery operations and scope, in line with Article 6 of the WFD.

Feedback on the European Commission proposal on criteria for an EU-wide end-of-waste status for plastic waste KRAIBURG TPE welcomes and supports the work towards a harmonized framework for recycled plastics in the European Union. Especially a clear definition of end-of-waste (EoW) criteria is crucial for further progress in circular economy and to ensure steady and high quality streams of secondary raw materials.

The SRP (Syndicat national des Régénérateurs de matières Plastiques ), the French representative organisation of companies operating plastic waste regeneration units in France welcomes the draft Implementing Regulation on EU-wide end-of-waste criteria for plastic waste but calls for the text to be amended on the following points: 1/ PE, PP, PS and PET are cited as examples in recital 3 of the act, but it is not…

Key messages (executive summary): We support the objective of harmonised EU-wide end-of-waste (EoW) criteria to strengthen the Single Market for secondary raw materials and reduce administrative burden. We welcome the clarity introduced for mechanical and solvent-based recycling. However, the draft explicitly excludes advanced / chemical recycling and conversion routes, including plastic-to-fuel pathways.

The main objective of the harmonization of end-of-waste criteria at EU level is to facilitate the circulation of recyclates and boost the market of secondary raw materials. While I.Blu understands the reasons behind the decision to regulate at EU level only recycling operations and utilization fields that are more mature and diffuse across European countries (e.g.

Ladies and Gentlemen, Please find attached our opinion on the EU Winter Package on End-of-waste plastic waste. Yours sincerely, Mag [name removed] [name removed], LL.M. (WU) (Lawyers/Attorneys at law) ___ Moser-Marzi Rechtsanwälte [address removed] Tel: [phone removed] GSM: [phone removed] (Mag.

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From Spanish Federation of Recovery and Recycling (FER) we included below our opinion about several matters regarding with these draft regulation: 1. The frequency of verification of output of plastic shall be defined in accordance with the characteristics of the plastic waste stream treated (Section 3-Requirements on product quality 3.2. Annex I) 2.

We welcome and support the Commission’s initiative to create EU-wide harmonised end-of-waste criteria for plastic waste. In order to achieve the overall objective of the highest possible quality recycling of plastic waste and to strengthen the internal market, end-of-waste status should also be made possible for recycled materials, such as pyrolysis oils or synthesis gases, obtained from plastic waste through…

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Is welcomed the harmonization of end-of-waste criteria at EU level, with the aim to facilitate the circulation of recyclates and boost the market of secondary raw materials. However, it is important to ensure that the harmonization does not negatively impact on the consolidated recycling activities and on the industries that already use secondary raw materials produced by recovery processes authorized in accordance…

We recognise this as a positive step towards harmonisation, regulatory certainty, and the development of a well-functioning internal market for recycled plastics. However, the implementation should not guide reflections on EoW criteria for chemical recycling. Mechanical and chemical recycling differ fundamentally in terms of technologies, value chains, and outputs.

While agreeing with the objective of harmonising at EU level the end-of-waste criteria for plastics, CNA considers it necessary to highlight significant problems that risk disproportionately affecting micro, small and medium-sized enterprises, in a context of serious crisis in the market for recycled plastics.

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The Hungarian Waste Management Federation (HOSZ) supports the draft Implementing Regulation on EU-wide end-of-waste criteria for plastic waste, with the exception of allowing end-of-waste for solvent-based recycling, on which we would not like to take a position, since our member companies have diverging opinions on the matter.

We, the Japan Automobile Manufacturers Association (JAMA), support the concept of End-of-Waste (EoW) criteria to ensure that recycled plastics derived from waste plastics are properly returned to society. In particular, we recognize the importance of strictly complying with regulations on substances of concern, as end-of-life vehicle plastics may contain legacy substances.

Consideration should be given to including polyolefins (in particular PE and PP) in the end-of-waste status provided for in the relevant legislation. Where polyolefins are recycled in the same recycling process as PET, recycled polyolefins have stable technical properties and meet quality requirements (e.g. REACH), enabling their safe and effective use as secondary raw materials in various industrial applications.

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NRK Recycling welcomes the proposed EU-wide end of waste criteria for plastic waste and sees harmonisation as essential for a well-functioning market for plastic recyclate. Recyclers operating in several Member States currently experience diverging interpretations and national differences, leading to unnecessary administrative burden and legal uncertainty.

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Lober suggest several changes in particular regarding the definiton of "solvent based recycling" to be changed to "dissolution recycling". All other recommandations added in the attached file. 1. Adopt Dissolution Recycling as the official technical term for physical solvent-based separation and purification methods that preserve polymer chains. 2.

Feedback on the draft Implementing Regulation on end-of-waste criteria for plastic waste. We support EU-wide end-of-waste criteria as a key enabler of a functioning recyclate market. To maximise impact, we recommend formally integrating harmonised self-assessment-based material declarations (with verification), anchored in EU standards, and pairing this regulation with strong demand-side measures.

We are concerned that the draft approach appears to exclude EoW eligibility for outputs from chemical recycling, including pyrolysis-derived feedstocks that are intended to be further processed into plastics. If these outputs remain classified as waste despite meeting defined specifications, this will create disproportionate administrative and logistical burdens (including for intra-EU shipments), complicate offtake…

EKO-KOM, a.s. is the sole Packaging Recovery Organization (PRO) in the Czech Republic providing EPR services to over 21 thousand enterprises placing packaging on Czech market and assuring its separate collection and recycling within 6189 municipalities covering 99 % of the Czech population. The full commentary on the drafted Regulation is attached to this feedback.

A harmonised EU end-of-waste framework is crucial if circular innovation is meant to leave the lab and reach industrial scale. Today, many plastic fractions are economically non-recyclable not because technology is missing, but because regulatory uncertainty blocks real-world deployment. Systems that turn mixed or contaminated plastics into durable, long-life products need clarity on when waste becomes a resource.

The proposed legislation overlooks one key issue the status of the statement of conformity issued under proposed Article 4 for the purposes of international trade and export. Is an importing member state required to recognise as no longer waste a product which is presented for import accompanied by a statement of conformity meeting the requirements of the legislation?

We support the establishment of EU-wide harmonised end-of-waste (EoW) criteria for plastic waste as a necessary instrument to ensure legal certainty, mutual recognition and the proper functioning of the internal market for secondary raw materials. Harmonised EoW criteria should facilitate the cross-border circulation of secondary plastics without the need for repeated national assessments.

Dear Ladies and Gentlemen, we welcome the intent to include definitions of physical recycling operations, which do not intentionally alter polymer chains, for the rules for the application of Directive 2008/98/EC. In order to prevent mis-understanding we propose the following 3 upgrades: 1. Use of the term Dissolution Recycling instead of solvent-based recycling 2.

The draft implementing regulation establishing the criteria under which plastic waste ceases to be waste and becomes a secondary raw material defines End of Waste (EoW) criteria (input material, processes, product quality), thereby supporting a unified market for recyclates.

The proposal for an EC implementing regulation to end the waste regime for plastics is conceptually beneficial, but currently excessively administratively and procedurally burdensome. The scope of the documentation, certification and monitoring obligations does not correspond to the principle of proportionality and may lead to end-of-waste status being used in practice only by a limited number of large plants.

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The SRE GmbH thanks the European Commission for the opportunity to comment on the draft act of the Commission Implementing Regulation laying down rules for the application of Directive 2008/98/EC of the European Parliament and of the Council as regards criteria to determine when plastic waste ceases to be waste published for public consultation on December 23rd, 2025.

ReVentas welcomes definitions proposed by the European Commission, however notes a few areas where changes would be beneficial. In particular, ReVentas is supportive of the following definition; (7) plastic recyclate shall mean the output plastic which has achieved end-of-waste status, and can be used as a secondary raw material to produce new plastic products or articles containing plastic parts; However, ReVentas…

Ragn-Sells welcomes the EU-wide end-of-waste criteria for plastics. It will open the market to new actors that do not trade waste, create a more level playing field for recyclers, and address unfair competition from virgin materials. We are, however, concerned that these measures are too complex to enforce and take too long to implement. This applies in particular to the Quality Management System (QMS) in Article 5.

Chemelot welcomes the Commission's initiative to harmonise EU-wide end-of-waste (EoW) criteria for plastics. Legal certainty and predictable cross-border rules are essential to scale circular value chains and industrial symbiosis.

We support the objective of EU-wide, harmonised end-of-waste (EoW) criteria for plastic waste, as it directly addresses the current uneven playing field and differing interpretations that slow down investment and scale-up. Our key feedback (aligned with our position papers): A. Ensure real legal certainty and mutual recognition across the entire value chain.

I am writing to express serious concerns about this draft regulation's impact on Europe's chemical recycling industry. This regulation excludes chemical recycling from end-of-waste status by limiting recognition to processes that do "not intentionally alter the polymeric chains" (Article 1), while Recital 4 explicitly excludes output used "as input material for chemical or fuel production." According to Fraunhofer…

Dear European Comission, As a market participant, the initiative to harmonize the end-of-waste criteria is very welcomed. We do think that the main improvement needed is the inclusion of chemical recycling in this initiative. The current wording seems to suggest that the output from chemical recycling (i.e. pyrolysis oil) will not reach the 'end-of-waste'.

To whom it may concern, I am concerned that products derived from chemical recycling are not considered for end-of-waste status in the current draft. Policy Context (What) It is widely acknowledged that achieving the objectives of the Packaging and Packaging Waste Regulation (PPWR) will be challenging without the timely deployment of chemical recycling technologies (Source: Conversio (2025): Status quo und Prognose…

We support the Commissions initiative to harmonise EU-wide end-of-waste criteria for plastic waste to strengthen the Single Market and reduce administrative burdens. We request two targeted improvements to avoid unintended negative impacts on advanced (chemical) recycling pathways that deliver polymer-to-polymer outcomes.

PROPOSED AMENDMENTS Article 5(4) The quality management system shall be certified by one of the following bodies: (a) a conformity assessment body established in the Union, accredited by a national accreditation body in accordance with Regulation (EC) No 765/2008, operating under an appropriate conformity assessment standard such as EN ISO/IEC 17065, EN ISO/IEC 17021-1 or EN ISO/IEC 17020, and applying…

The determination of what should be considered "end-of-waste" under (4) does not make sense. If oil has been produced from waste plastic and sold, it is a product and therefore by definition has ceased to be waste.

Positive opinion from the Réunion/Indian Ocean perspective This draft regulation is a structural step forward for the recycled plastics sector, providing a clear, harmonised and secure framework for end-of-waste status, which is essential for the consolidation of a genuine market for high-quality recycled plastics.

Filed in French · English published by the European Commission