Rules for the calculation and verification of recycled content in plastic packaging
4 submissions from 4 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
Who showed up
2 submissions from industry — companies and their trade associations — against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2 industry submissions for every one from civil society.
Industry 2Civil society 1Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation is open — 17 days leftto submit. It closes on 16 Sept 2026.
Responding? PolicySpeak drafts consultation responses grounded in your organization’s own positions. Request access.
Policy area
Sustainability (DG ENV)
Where it stands
In planning
Adoption expected
31 Dec 2026 · in 123 days
How it got here
Call for evidence16 Sept 2026 · upcoming
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Dec impl draft, Dec impl.
The introduction of harmonised rules for the calculation and verification of recycled content in plastic packaging is strongly welcomed. An EU-wide uniform approach is essential for legal certainty, transparency and a level playing field in the Single Market.
Filed in German · English published by the European Commission
The RecyClass - https://recyclass.eu/ - certification provides a solid baseline for the verification of the michanically recycled content. This certification is now used worldwide by both machine recyclers (Recycling Process) and processors and producers who use machine recyclates for packaging production (Recycled Plastics Traceability).
Filed in Dutch · English published by the European Commission
You are killing small businesses with these new rules. Micro businesses that sells in and out of the EU cannot afford the same as the huge corporations, they shouldn't be in the same bracket. Every time you put new rules in it's another nail in the coffin for small businesses. It's not fair to bring in these new rules without exemptions for those of us who are trying our best to make a living on our own.
The calculation of the recycled content should be based on the EN 15343 standard which clearly states the way to calculate the recycled content with a distinction between PCR and PIR and the ISO 22095 standard ensures the complete chain of custody. These certification systems also take REACH compliancy into consideration.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.