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EU consultation

Sustainability criteria for plastic recycling technologies

166 submissions from 159 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission received 211 submissions on this file. Shown here: the 166 from organizations. Not shown: 42 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 3 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →

Who showed up

144 submissions from industry (companies and their trade associations) against 11 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 13.1 industry submissions for every one from civil society.

Industry 144Civil society 11Public authorities, academia, other 11

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.

What the room declares

73 of 159
in the EU Register
244
full-time lobbying staff
€43.9M+
declared costs a year
151
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 14 Oct 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 16 Sept 2026; it ran from 14 Aug 2026.

Policy area
Sustainability (DG ENV)
Where it stands
In planning
Adoption expected
31 Dec 2026

How it got here

  1. Call for evidence16 Sept 2026

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Dec del draft, Dec del.

Showing 25 of 166 submissions.

MO

Ministry of Foreign Affairs

· · filed 16 Sept 2026 · source

Regarding the public consultation launched by the European Commission under Article 7 of Regulation (EU) 2025/40, related to methodologies for calculating and verifying recycled content, sustainability criteria for plastic recycling, and conditions for recognizing recycled materials originating from third countries, the initiative is highly relevant.

LinkedInX
SR

Synova Renewable Technology B.V.

· · filed 16 Sept 2026 · source

PDF

Also see attached file. SYNOVA is a Netherlands-based advanced recycling technology company. Our processes convert contaminated, plastic-rich waste into light olefins and one-ring aromatics (BTX) for the production of virgin-quality polymers.`We raise three points on the Article 7(8) implementing act (calculation and verification of recycled content) and the Article 7(9) delegated act (sustainability criteria for…

LinkedInX
AN

Agência Brasileira de Desenvolvimento Industrial

· · filed 16 Sept 2026 · source

PDF

Contribution by the Brazilian Agency for Industrial Development Public Consultation of the European Commission Regulation (EU) 2025/40: methodologies for verifying recycled content, sustainability criteria for plastic recycling and conditions for recognising recycled materials from third countries The Brazilian Industrial Development Agency (ABDI) is grateful for the opportunity to contribute to this public…

Filed in Portuguese · English published by the European Commission

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FO

Federation of Food and Drink Industries of the Czech Republic

· · filed 16 Sept 2026 · source

The Federation of the Food and Drink Industries of the Czech Republic (FFDI CZ) welcomes the opportunity to comment on the implementing and delegated acts under Article 7 of the Packaging and Packaging Waste Regulation (PPWR). We support the objective of increasing the use of high-quality recycled plastic in packaging and developing a strong EU market for secondary raw materials.

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UP

USA Pulses

· · filed 16 Sept 2026 · source

Assess technologies using transparent and comparable criteria, including energy use, greenhouse-gas emissions, resource efficiency, output quality and usable yield. Consider food-packaging performance, including food-contact suitability, moisture protection, seal integrity and durability during storage and transport.

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FS

Forum STEM

· · filed 16 Sept 2026 · source

PDF

Forum STEM, a nationwide initiative created by young people passionate about science and technology, submits this position paper on the three acts being prepared by the European Commission under Article 7 of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): the methodology for calculating and verifying recycled content (Article 7(8)), sustainability criteria for plastic recycling technologies (Article…

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PH

Perstorp Holding AB

· · filed 16 Sept 2026 · source

Perstorp welcomes the opportunity to provide input to the European Commissions Call for Evidence related to Packaging-and-packaging-waste-sustainability-criteria-for-plastic-recycling-technologies Sustainability criteria should support the PPWRs objectives by ensuring that recycling is performed in an environmentally sound manner, in line with Recital 48.

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PH

Perstorp Holding AB

· · filed 16 Sept 2026 · source

Perstorp welcomes the opportunity to provide input to the European Commissions Call for Evidence related to the two upcoming implementing acts related to Article 7 of the Packaging and Packaging Waste Regulation (PPWR) Credible and trustworthy methodologies for calculating and verifying recycled content derived from post-consumer plastic waste as well as plastics made from bio-based sources are of outmost…

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VE

VDMA e. V.

· · filed 16 Sept 2026 · source

PDF

We welcome the development of sustainability criteria for plastic recycling technologies. The machinery and equipment manufacturing industry provides the technologies and equipment that enable efficient plastics recycling and processing. The regulatory framework should therefore support technological innovation and investment rather than prescribe specific recycling processes. Our recommendations 1.

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CE

CLEPA European Association of Automotive Suppliers

· · filed 16 Sept 2026 · source

PDF

CLEPA, the European Association of Automotive Suppliers, representing over 3.000 companies, from multi-nationals to SMEs, supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, directly employing 1.7 million people in the EU, welcomes this initiative and the opportunity to submit its comments in the file attached.

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E

ExxonMobil

· · filed 16 Sept 2026 · source

PDF

The transition to a more circular economy for plastics must remain economically viable. The Packaging and Packaging Waste (PPWR) secondary legislation should ensure that recycled content targets are implemented in an economically viable manner.

LinkedInX

Treating these 3 implementing acts provided for in the PPWR in the same initiative is relevant in order to have an overview of the issues at stake here. Recycling of plastic is essential to promote increased circularity of plastic material in Europe and can also contribute to minimising the footprint associated with plastic waste management.

Filed in Portuguese · English published by the European Commission

LinkedInX
CT

CEFLEX - The Circular Economy for Flexible Packaging initiative

· · filed 16 Sept 2026 · source

PDF

CEFLEX--the Circular Economy for Flexible Packaging initiative--welcomes the opportunity to respond to this call for evidence. We invite the Commission to take into account the supply-side and investment implications of the three PPWR Article 7 secondary legislative acts when designing the rules.

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ES

European Semiconductor Industry Association

· · filed 16 Sept 2026 · source

PDF

The European Semiconductor Industry Association (ESIA), representing the European leadership in semiconductor research, design, and manufacturing, welcomes the opportunity to provide feedback on the upcoming implementing and delegated acts under Article 7(8), (9) and (10) of Regulation (EU) 2025/40 concerning recycled plastic content, recycling technologies, and recycled content originating from third countries.

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TP

The Polish Union of the Cosmetics Industry

· · filed 16 Sept 2026 · source

PDF

We welcome the Commissions intention to establish sustainability criteria for plastic recycling technologies. These criteria must ensure access to high-quality recycled materials and allow chemical recycling to complement mechanical recycling, especially where mechanically recycled material of the required purity, consistency or technical performance is not sufficiently available.

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DG

DHL Group

· · filed 16 Sept 2026 · source

PDF

DHL Group Call for Evidence submission on sustainability criteria for plastic recycling technologies in packaging and packaging waste DHL Group welcome the opportunity to contribute to the Call for Evidence exercise relating to sustainability criteria for plastic recycling technologies in packaging and packaging waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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ZW

Zero Waste Europe

· · filed 16 Sept 2026 · source

PDF

Sustainability criteria for recycling Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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SC

Schwarz Corporate Affairs GmbH & Co. KG

· · filed 16 Sept 2026 · source

1. Verification of Recycled Content Targets Article 7(1) PPWR provides that the recycled content share shall be calculated as an average per manufacturing plant and calendar year, broken down by packaging type and format. In practice, producers bear responsibility for demonstrating compliance with recycled content targets as part of their technical documentation.

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LL

LyondellBasell (LYB)

· · filed 16 Sept 2026 · source

PDF

LyondellBasell (LYB) supports the Commissions ongoing efforts to consider industry and stakeholders perspectives on PPWR secondary legislation, whilst also ensuring its timely completion. LYB is a large multinational chemical and polyolefins manufacturing company that has anchored its strategy on sustainability.

LinkedInX
EB

European Bioplastics

· · filed 16 Sept 2026 · source

European Bioplastics (EUBP) is the European association representing the interests of the bioplastics industry along the entire value chain. Its members produce, refine, and distribute bioplastics, i.e. plastics that are biobased, biodegradable, or both.

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SC

Stichting Chemelot

· · filed 16 Sept 2026 · source

Chemelot is one of Europes largest integrated chemical and materials clusters and hosts existing and emerging activities across mechanical recycling, advanced recycling, circular feedstock processing and chemical and polymer production. Chemelot supports the development of robust sustainability criteria for plastic recycling technologies.

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PS

Promeco SPA

· · filed 16 Sept 2026 · source

PDF

Promeco welcomes the opportunity to respond to the Call for Evidence on sustainability criteria for recycling technologies under Article 7(9) of EU PPWR regulation. We would welcome a robust and practicable framework that supports plastics recycling as a primary objective, while acknowledging that complementary technologies are required to reach this objective.

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TA

The Advisory Board for Finnish PROs (Tuottajayhteisöjen neuvottelukunta TYNK)

· · filed 16 Sept 2026 · source

PDF

Advisory Board for Finnish PROs Comments on the Sustainability Criteria for Plastic Recycling Technologies The Advisory Board for Finnish PROs appreciates the opportunity to provide comments on the European Commission's initiative to establish sustainability criteria for plastic recycling technologies. The Advisory Board for Finnish PROs supports the development of common sustainability criteria.

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EP

European Plastics Converters (EuPC)

· · filed 16 Sept 2026 · source

PDF

EuPC welcomes the opportunity to contribute to the Call for Evidence on the forthcoming implementing measures under Article 7(8), (9) and (10) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Our position paper enclosed sets out industry priorities for a calculation and verification framework: an inclusive, fair and transparent calculation methodology and a credible, proportionate certification and…

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A

ANFAC

· · filed 16 Sept 2026 · source

ANFAC, the Spanish Association of Automobile and Truck Manufacturers, considers that the sustainability criteria for plastic recycling technologies should be objective, transparent, verifiable and technologically neutral. It is also crucial that the future delegated act identifies the criteria used to assess such technologies and the documentation by which their compliance can be demonstrated.

Filed in Spanish · English published by the European Commission

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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.