Rules for the calculation and verification of average loss rates for sorted waste

The attached paper sets out EXPRAs feedback on the draft delegated decision concerning average loss rates. EXPRA welcomes the development of this important piece of secondary legislation, which will contribute to a more harmonised approach to calculating recycling rates across the European Union.

VinylPlus® welcomes the Commission initiative to establish harmonised rules for the calculation and verification of average loss rates (ALRs) for sorted waste under Directive 2008/98/EC. As a European value-chain commitment promoting the circularity of PVC in general and, especially in construction applications, VinylPlus® supports robust and transparent methodologies for measuring recycling performance.

The attached paper provides EPRO's feedback on the draft delegated decision on average loss relates. EPRO supports the development of this important secondary legislation which will help ensure a more harmonised approach to calculating recycling rates across the Union. EPRO is an association focussing on plastics circularity.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to provide feedback on the draft Delegated Act establishing rules for the calculation and verification of average loss rates (ALR) for the sorting of waste under the Waste Framework Directive.

ACR+ welcomes efforts by the European Commission to ensure consistency among the calculation of recycling targets and supports any measures to improve the reliability of recycling rates across Europe, so that waste management is truly aligned with circular economy principles. Supporting the identification of effective policies and good practices is an important step toward high quality recycling.

CONAI welcomes the Commissions initiative and supports the objective of improving comparability and robustness of reported recycling figures across the EU. That said, the draft introduces ALR as an alternative to the effective point-of-measurement at the recycling plant (the calculation point).

The Spanish Association of Plastic Recyclers (ANARPLA) supports the Commissions objective of achieving harmonised reporting under the Waste Framework Directive (WFD). ANARPLA requests that ALRs: i. be used strictly as a last resort where certified and audited recycler mass balance data are not available, ii.

Plastics Recyclers Europe (PRE) supports the Commissions objective of harmonised reporting under the Waste Framework Directive (WFD). PRE calls for ALRs that (i) are used strictly as a last resort where certified, audited recycler mass-balance data are unavailable, (ii) capture all recycler-level losses up to the calculation point, including melt filtration and final purification rejects, and (iii) are kept…

Assoambiente supports the objective of improving the harmonisation and reliability of recycling rate calculations across the EU, but considers it necessary to introduce adjustments and clarifications to ensure that the methodology is consistent with the Waste Framework Directive (WFD), technically robust and applied uniformly across Member States. See attachment.

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 6208 municipalities covering 99 % of the Czech population. The full commentary on the drafted Delegated Decision is attached to this feedback.

Chemical Recycling Europe supports the Commissions objective to establish uniform and comparable rules for the calculation, verification, and reporting of average loss rates (ALRs) for sorted waste. Harmonisation is essential to strengthen the reliability of EU recycling statistics and to avoid diverging national approaches, including for plastic packaging, where non-recycled quantities can have important downstream…

The German Chemical Industry Association (VCI) rejects the regulatory proposal submitted for consultation on the introduction and application of Average Loss Rates (ALRs) in its current form. From the perspective of industry, the additional insight expected from the regulation is not proportionate to the significant additional administrative burden it would create.

The CDCNPA submits the attached comments on the draft Delegated Decision Ref. Ares(2026)1808904. The central concern is the treatment of batteries as a single aggregated entry in Table 2 of the Annex. Regulation (EU) 2023/1542 defines five distinct battery categories portable, LMT, SLI, EV, and industrial each with different technical characteristics, collection channels, and post-sorting loss profiles.

The Latvian Chamber of Commerce and Industry (hereinafter ‘the Latvian Chamber of Commerce and Industry’) has assessed the draft European Commission Delegated Decision on the calculation and verification of average loss rates for sorted waste.

Filed in Latvian · English published by the European Commission

FERVER is the association of European glass recyclers. In FERVER's opinion, some points of the draft might need to be clarified or further explored: Clearer definition on exactly when the Average Loss Rate (ALR) should be used also to avoid disadvantages for facilities reporting real data with higher losses than the ALR.

Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our approximately 200 members (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.

Czech Republic would like to point out that as a general principle, it is necessary not to raise administrative burden and not to raise excessive requirements to sorting and recycling facilities. The recycling industry is currently under pressure already in Europe and we must make sure that newly emerging rules will support its competitiveness and regrowth.

The Commission aims to establish uniform, simple and proportionate rules for the calculation, verification and reporting of the weight of materials or substances lost after a waste sorting operation, and which are not subsequently recycled, based on average loss rates for sorted waste. The uniform rules will ensure that data supporting the calculation of recycling rates are comparable and reliable.

Filed in Italian · English published by the European Commission

(1) The introduction of the ALR methodology is not justified for the Czech Republic, as the Czech registration system (ISPOP) already works on the principle of digital traceability of specific material flows up to the final processor, thus meeting the objective to which the ALR is only theoretically heading in countries with insufficient data.

Filed in Czech · English published by the European Commission

Section V Circular Economy, Chemicals and Radiation Protection Department V/6 Waste Prevention, Recovery and Assessment/Austria Miss Diana Fritz stated: Thank you very much for your remarkable commitment and for the dedicated efforts of the Vienna Nature Watch.

The Association of Municipal Services of the Czech Republic (SKS ČR) took note of the draft rules for calculating and verifying the average loss rate for sorted waste (Average Loss Rate ALR). We understand the Commission’s efforts to harmonise the methodology and make recycling reporting more transparent.

Filed in Czech · English published by the European Commission