Sustainability criteria for plastic recycling technologies
28 submissions from 28 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
25 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 12.5 industry submissions for every one from civil society.
Industry 25Civil society 2Public 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 del draft, Dec del.
Addora is a Shopify application used by independent e-commerce merchants to combine multiple purchases into a single shipment through pre-order and "Buy Now, Ship Later" functionality, rather than dispatching each order separately as it is placed. We welcome the opportunity to comment on the review of requirements for packaging and other measures to prevent packaging waste.
My micro business with 3 employees cannot survive this level of bureaucracy. There needs to be a unified system like the OSS system where we can register our packaging volumes per member state with a single report, and pay the fees for the waste generated in a single, combined payment.
Dear European Union I hope this message finds you well. My name is Christine Pereira. I have been a sole trader selling vintage and antique goods online for about 15 years through my Etsy shop, DreamGlean (formerly MeanGlean). I run every part of the business alonesourcing, photography, listings, customer service, packaging and shippingand it is my sole source of income. DreamGlean is also a zero-waste operation.
Until recently, I was a 'microentrepreneur', registered in France with customers in different parts of the EU. My activity was the production of bespoke miniature models and model parts. With this regulation, you have effectively killed my business, as I do not have the time, the money and the resources to follow up the different obligations -- obligations that vary from country to country, which is absurd in the…
We welcome the European Commission’s intention to establish sustainability criteria for plastic recycling technologies as part of the delegated act. These criteria can make an important contribution to transparency and to achieving the objectives of the circular economy. At the same time, they should be designed in a way that encourages innovation and does not unintentionally hinder it.
Filed in German · English published by the European Commission
Cefic considers it essential that these sustainability criteria are designed to be technology-neutral and aligned with the PPWR definition of high-quality recycling (Recital 30 and Article 3(41)), ensuring that all recycling technologies, including chemical recycling technologies, are assessed based on what they deliver in practice.
I am a micro-entrepreneur based in France, running a small artisan sewing workshop producing handmade household textiles such as tablecloths and table runners. I fully support the objectives of the PPWR and Extended Producer Responsibility.
Dear EU, why is it not possible for the cartonboard producer to pay the fees and I, as a small online mailing company, pay all this on the price of the cartonboard? How should everything always be so complicated and different in every country? EU means for me: rules are the same across Europe, but we are further away every day. It often seems to her that the regulations only make it for the big vs. the small.
Filed in German · English published by the European Commission
I agree that sustainability is important, and I can understand that a business needs to be responsible for the amount of waste it produces, but the cost of registration should never surpass the cost of the waste. Unfortunately, with the current legislation, this is exactly whats happening: as a board game webshop, I ship to multiple European countries.
I agree that there is need for minimizing waste. But the new set of rules are completely devoid of scale towards the amount of waste created by individual businesses. The completely over the top bureaucratic burden with associated costs can only be carried by the largest of companies and not by the many small companies that carry the EUs economy.
From a packaging development perspective, sustainability criteria should remain technology-neutral and focus on demonstrated environmental performance, material quality and traceability. Different recycling technologies may play complementary roles in increasing the availability of recycled materials needed to support circular packaging solutions.
The current packaging rules place a disproportionate burden on micro-enterprises and very small sellers across the EU. As EU citizens and consumers, I am concerned about the impact these rules will have on small European businesses and on consumers’ ability to buy their products cross-border. Many micro-enterprises are run by only one person and may receive only a few contracts per year from a given EU country.
Filed in German · English published by the European Commission
The EUs PPWR risks becoming a textbook example of well-intended regulation turning into a bureaucratic monster. For small and medium-sized businesses, the administrative burden of packaging documentation, reporting, compliance and data management is becoming increasingly disproportionate. Large corporations can absorb these costs with dedicated compliance departments and expensive IT systems.
As much as I agree with improving recycling regulations and pushing for more environmentally friendly decisions, this new PPWR regulation is completely unfair towards micro and small businesses. We all want to chip in to these environmental causes, but killing off the small businesses and giving the advantage to massive corporations, is not the way to go.
The establishment of a common methodology for the calculation and verification of recycled plastic content in packaging is necessary to make operators’ declarations comparable and to allow for homogeneous checks across the Union market. A central point concerns the relationship between declared data and material handled along the supply chain.
Filed in Italian · English published by the European Commission
I have long been very pro Europe idealises it too much. Sadly as time goes by i feel that it is all jut falling to pieces on one front or another... This PPWR and EPR regulations seem to just be confirming that Europe is dead and no longer cares for its small artisans, its creatives that bring joy and culture to the people.
Im a small independent creator from Slovakia, and I need to be direct: the current packaging laws and foreign registration rules are completely unfair to small businesses. Expecting a one-person shop to register in multiple EU countries, pay hundreds of euros in fixed annual fees, and hire foreign representatives just to send a few handmade parcels a year is absurd.
Hello, I am writing as the owner of a small business. This new law, while making a big step forward in environmental consciousness, negatively affects small business owners. I am unable to afford the fees I would need to pay to be able to sell to each individual EU country, while large scale companies will be able to do this with no issue.
Recycling technology should be verified by EU accredited systems such as the systems under the Polycert Europe umbrella or Recyclass. These systems are based on the EN 15343 standard which clearly states the way to calculate the recycled content with a distinction between PCR and PIR and and the ISO 22095 standard ensures the complete chain of custody.
Dear Members of the Commission, Finland joined the EU in 1995 with the aim of expanding free trade and not hindering it. We note that today, 17 August 2026, we have removed Oy Juho Jussila’s online shop from the customer countries of all EU Member States except our own. Oy Juho Jussila is a 103-year-old family company and we have been trading in exports since 1928.
Filed in Finnish · English published by the European Commission
Brussels breaks EU single market PPWR violates the EU's founding principle of free movement of goods, and small entrepreneurs will pay for it first From today, the EU Packaging and Packaging Waste Regulation (PPWR) applies across all 27 member states. EAS is warning that PPWR violates one of the EU's founding principles: the free movement of goods.
Feedback on the PPWR This regulation, despite its understandable environmental objective, risks having dramatic consequences for Europe’s smallest businesses. I am a craftsman and I sell small quantities of products in several countries of the European Union. Taken separately, each of these markets represents few sales.
Filed in French · English published by the European Commission
The fact is: It is clear that the European Union offices were unable to develop a unified structure similar to the VAT One Stop Shop for the PPWR regulation. It is equally clear that they were not able to create such an infrastructure within the last 18 months.
Ladies and gentlemen, as the operator of a small online shop, I would like to take this opportunity to draw attention to what I consider to be a particularly critical point in the planned implementation of the PPWR producer registers: the obligation to appoint an authorised representative for the extended producer responsibility in the case of cross-border sales.
Filed in German · English published by the European Commission
Dear EU, It is without exaggeration to say that the recent PPWR initiative, whilst having the best intention, will kill small business who rely on exporting to Europe. Instead of harming the real culprits ( Amazon, Temu, Shien etc), it has already in just 2 days started to destroy exports from small business to Europe.
Dear Members of the European Parliament, I'm writing as the owner of a small online shop for board games. I founded the shop in 2024, with the hope of eventually being able to live from its earnings. In the meantime, I have spent countless hours, besides my day job, bringing my shop to its current state and being able to ship within Europe and the UK.
I am a small business from the Netherlands. I have a shop with the goal to design and sell enviromental friendly clothing throughout Europe. We ship in 100% compostable packaging, not recycleble but compostable. Besides this we also ship in other packaging depending on the order. It's small amounts and it's mostly boxes that are recycled for new packaging.
Ladies and gentlemen, we run a small online shop for watches and jewellery in Austria and offer to send them to most EU countries. This is no longer possible for us as a result of the PPWR. The costs for authorised representatives and compliance agencies are higher than the achievable profit. Due to the PPWR, we had to stop selling in most EU countries.
Filed in German · English published by the European Commission
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.