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 Also not shown: 3 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their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
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.
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.
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…
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
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.
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.
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…
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.
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…
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.
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.
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.
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
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.
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.
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.
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)
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)
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.
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.
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.
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.
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.
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.
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…
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
The Inter IKEA Group 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). For nearly 80 years, packaging has been a cornerstone of the IKEA business model.
Response to the call for evidence on the delegated act supplementing the Regulation with sustainability criteria for plastic recycling technologies Feedback submission by Systemiq Ltd on behalf of a group of 8 companies and associations from across the value chain for plastic packaging manufacturing and recycling in Europe (see attached appendix for signatories).
Cosmetics Europe's response to the European Commission's Call for Evidence on Article 7 PPWR Cosmetics Europe's contribution to the “Call for Evidence” on the implementing and delegated acts under Article 7 of Regulation (EU) 2025/40 Cosmetics Europe welcomes the publication of the European Commission's Call for Evidence concerning the implementing and delegated acts under Article 7 of Regulation (EU) 2025/40 on…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Confapi, the Italian Confederation of Small and Medium-Sized Private Industry, which represents 118.00 small and medium-sized industrial companies with more than 1.3 million employees, shares the general objective of supporting circularity, reducing the use of primary raw materials and stimulating demand for high-quality recycled plastic, as provided for in Regulation (EU) 2025/40 on packaging and packaging waste.
Filed in Italian · English published by the European Commission
The sustainability criteria under the PPWR should apply the Do No Significant Harm (DNSH) principle across seven un-aggregated areas: carbon footprint (via Product Environmental Footprint/PEF without credit mass balance), human toxicity, energy use, water use/pollution, localized pollution, biodiversity, and fossil resource use.
NMWE sets out the following sector-specific recommendations on Sustainability criteria for recycling installations: Our sector supports a level playing field between EU and non-EU recycling installations, following these principles: - The Commission should ensure that the criteria do not create artificial barriers to trade and assess their potential trade implications.
OCTAL Position OCTAL SAOC FZC / Alpek Polyester Middle East supports robust sustainability criteria for technologies used to produce recycled plastic for packaging. OCTAL considers it essential that these criteria follow a technology-neutral approach.
Versalis, Enis chemical company, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the sustainability criteria for plastic recycling technologies under Article 7(9) of the Packaging and Packaging Waste Regulation (PPWR).
Methodology for calculating recycled content The methodology adopted for calculating post-consumer recycled content in plastic packaging will be a key determinant of the economic viability and scalability of plastic recycling value chains in Europe.
This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries.
The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.
TNO Public 16 September 2026 Contact person: [email removed] Ref. Ares(2026)8797557 - 16/09/2026 www.tno.nl TNO welcomes the European Commission's initiative to develop sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Polish Association of the Cosmetics and Detergents Industry (PSPKD) welcomes the opportunity to contribute to the development of environmental criteria for plastic recycling technologies under Article 7 of the PPWR.
As a consumer goods manufacturer with operations in multiple global markets, we have identified two areas of particular concern in relation to the sustainability of plastic recycling technologies that we would appreciate the Commission addressing through the forthcoming implementing acts.
Elipso supports the development of a European circular plastics economy, provided that the PPWR targets for the incorporation of recycled materials do not in any way compromise health safety or existing sectoral regulations.
Filed in French · English published by the European Commission
FEAD welcomes the European Commissions intentions on the sustainability criteria for plastic recycling technologies under Article 7(9) of the Packaging and Packaging Waste Regulation. This contribution focuses exclusively on the future delegated act establishing those criteria.
September 15, 2026 1/3 Valmet comments on sustainability criteria for plastic recycling technologies Valmet is a global technology supplier enabling industries transition towards circular, resource-efficient and low-carbon operations through solutions for material recovery, advanced recycling and process optimisation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Plastové obaly a recyklované materiály – pravidla pro recyklaci, dovoz a obsah recyklovaného materiálu Stanovisko HK ČR Hospodářská komora České republiky (HK ČR) vítá možnost vyjádřit se k připravovaným prováděcím pravidlům v návaznosti na nařízení PPWR. HK ČR podporuje cíle směřující k rozvoji oběhového hospodářství a efektivnímu využívání recyklovaných materiálů.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The U.S. trade agenda is built on fairness, transparency, and predictable rules that let businesses on both sides of the Atlantic plan with confidence. Unfortunately, the Commissions current approach on PPWR falls short. The attached technical comments outline those shortcomings as well as practical ways to fix them, including: 1.
As the European association representing manufacturers of self-care products, including non-prescription medicines, medical devices, and food supplements, AESGP supports the main objectives of the Packaging and Packaging Waste Regulation (PPWR) to promote circularity and contribute to a more resource-efficient packaging system across the European Union.
Position Stockholm, 2026-09-16 Henrik Oxfall IKEM:s position om hållbarhetskriterier för plaståtervinningstekniker Inledning EU förordning om förpackningar och förpackningsavfall (PPWR) innebär att hållbarhetskriterier för återvinningstekniker ska utvecklas som en del av regelverket för att främja återvinning, högkvalitativa återvunna material och en cirkulär ekonomi.
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Detergents Europe, representing the cleaning and hygiene products industry in Europe, fully supports the objectives of the Packaging and Packaging Waste Regulation (PPWR) to enable a circular packaging economy. Our goal is to increase the use of post-consumer recycled (PCR) content in plastic packaging, thereby supporting the transition to more circular and sustainable packaging solutions within our sector.
Through this paper, Reusable Packaging Europe (RPE) seeks to contribute to the European Commissions implementing act under Article 7(8) of the Packaging and Packaging Waste Regulation (PPWR), establishing the methodology for calculating and verifying the percentage of recycled content recovered from post-consumer plastic waste. RPE welcomes the Commissions work to develop a robust and harmonised methodology.
Please find attached joint EPRO and EXPRA feedback to the consultation on the following topics: Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging (implementing act under article 7(8)). Packaging and packaging waste sustainability criteria for plastic recycling technologies (delegated act under article 7(9)).
FEDIAF, the European Pet Food Industry Federation, welcomes the opportunity to respond to this call for evidence. Our central point is this: the technologies these criteria qualify will decide whether recycled content can be sourced for pet food packaging at all, because mechanical recycling cannot currently supply contact-suitable material for our non-PET multilayer flexibles.
Contribution to the European Commission Call for Evidence Implementation of Article 7 of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Plastic packaging – harmonisation of rules for calculating and verifying recycled content in plastic packaging Packaging and packaging waste – sustainability criteria for plastic recycling technologies Schreiner Group GmbH & Co.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
PPWR CALL FOR EVIDENCE SK Chemicals' Position on Secondary Legislation for Recycled Content under the PPWR Regulation (EU) 2025/40 on packaging and packaging waste SK Chemicals produces chemically recycled PET (CR PET) and chemically recycled copolyesters through a chemical recycling process in which waste PET is depolymerised to monomer-level intermediates and purified.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Cabot supports the ICBA comments and would like to provide the following: Cabot recommends the European Commission to adopt outcome-based, technology-neutral sustainability criteria for plastic recycling under the PPWR.
Repsol PPWR Article 7(9): Sustainability criteria for recycling technologies Executive Summary and Priority Policy Asks Repsol welcomes the opportunity to contribute to the development of sustainability criteria for recycling technologies under Article 7(9) of Regulation (EU) 2025/40 on packaging and packaging waste.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eastman supports technology neutrality - sustainability criteria should assess technologies based on the environmental and circularity outcomes they achieve. It should ensure maximum circularity and environmental outcomes by ensuring that every recycling technology is evaluated based on the waste streams it can process, the quality of material it produces, and its ability to displace virgin plastic in demanding…
PPWR – Sustainability criteria Introduction To support the implementation of the Packaging and Packaging Waste Regulation (PPWR) and the sustainability criteria for available recycling technologies, PRE proposes a practical sustainability assessment mechanism.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
LG Energy Solution Wrocław sp. z o.o. adres korespondencyjny: ul. LG 1 A, Biskupice Podgórne, 55-040 Kobierzyce, Dolnośląskie, Poland NIP: 8961550941, REGON: 364187232, KRS: 0000614214, Kapitał Zakładowy: 4 648 372 000,00 PLN Sąd Rejonowy dla Wrocławia-Fabrycznej we Wrocławiu, VI Wydział Gospodarczy Krajowego Rejestru Sądowego OL/2026/C/001/ Biskupice Podgórne, 15 September 2026 Call for Evidence: Packaging and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Suzuki Motor Corporation welcomes the European Commissions Call for Evidence on recycled content under Articles 7(8), 7(9) and 7(10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback. We support the objective of promoting the use of recycled materials while ensuring a high level of environmental protection and protection of human health.
SCHP ČR supports the establishment of technology-neutral, harmonised and scientifically robust criteria based on the demonstrable environmental impact of the specific facility concerned, rather than solely on the type of technology employed.
Henkel supports the objective of increasing recycled plastic content in packaging and establishing harmonized EU rules that are practical, enforceable, and supportive of a circular economy. Sustainability criteria should be science-based, performance-driven, and technology-neutral.
EUMEPS supports sustainability criteria that direct plastic waste towards the route capable of producing useful secondary raw material with the best verified environmental performance. Mechanical recycling should be preferred for clean applications where it achieves the required quality efficiently.
ANFACO-CYTMA considers that future sustainability criteria for recycling technologies should be based on scientific evidence, maintain technological neutrality and assess the different solutions according to their environmental performance, safety and ability to provide recycled materials fit for their intended uses.
Filed in Spanish · English published by the European Commission
PPWR Comment on certification requirement for recycled content verification Ref. Ares(2026)8787073 - 16/09/2026 16 September 2026 The success of the Packaging and Packaging Waste Regulation (EU) 2025/40 will be measured against its ability to work in practice.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and brand owners. DI welcomes the opportunity to provide input on sustainability criteria for plastic recycling technologies. Sustainability criteria should be based on objective environmental performance and remain technology-neutral.
CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050.
The International Carbon Black Association (ICBA) welcomes the opportunity to provide feedback to this call for evidence. We thank you for taking the time to consider our views, concerns and suggestions which we have summarized in the attached document.
Agbiz makes this submission on behalf of the South African agri-food export sector, focusing on the conditions for using recyclate from third countries (Article 7(10)) and the sustainability criteria for recycling technologies (Article 7(9)), where the risk to agri-food trade is greatest and on which the Commission has expressly invited evidence. What is at stake.
EDANA, the international association representing the nonwovens industry and its value chain, would like to thank the European Commission for the opportunity to provide input on the following initiatives related to the Packaging and Packaging Waste Regulation (PPWR): Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging; Conditions for importing recycled…
The Thailand PPWR Consortium welcomes the opportunity to provide feedback on the development of the implementing rules under Article 7(10) of Regulation (EU) 2025/40. Thailand is an important manufacturing and supply-chain partner for the European market, including for plastics, packaging, converted products, parts, components and recycled materials.
The Thailand PPWR Consortium welcomes the opportunity to provide feedback on the development of sustainability criteria for plastic recycling technologies under Article 7(9) of Regulation (EU) 2025/40. The Consortium supports the objective of ensuring that recycled plastics counted toward the Article 7 recycled-content targets are produced through recycling processes that provide credible environmental performance…
The Thailand PPWR Consortium welcomes the opportunity to provide feedback on the development of the methodology for the calculation and verification of recycled content under Article 7(8) of Regulation (EU) 2025/40. Thailand is an important manufacturing and supply-chain partner for the European market, including for plastics, packaging, converted products, parts, components and recycled materials.
Please find our formatted comments in the attachment. The Food Packaging Forum Foundation (FPF) welcomes the opportunity to provide evidence to develop sustainability criteria for plastic recycling technologies relevant to the Packaging and Packaging Waste Regulation (PPWR).
PCEP welcomes the development of sustainability criteria for plastic recycling technologies and considers it important that the regulatory framework recognises the complementary contribution of different recycling pathways to the circular economy.
Landbell Group company European Recycling Platform (ERP) supports the development of robust sustainability criteria for plastic recycling technologies. The criteria should be technology-neutral, allowing different recycling technologies to demonstrate compliance rather than favouring or excluding specific technologies by design. Please see attached for full feedback.
Medicines for Europe, representing generic, biosimilar, and value-added medicines manufacturers across Europe, welcomes the opportunity to contribute to the call for evidence on the Packaging and packaging waste - sustainability criteria for plastic recycling technologies. Please find our submission attached.
The sustainability criteria should consider the origin of recycled plastics, but also the environmental impact of recycling technologies used, as stressed in Art. 7(9) PPWR. The criteria should enable a robust differentiation between recycling technologies according to their overall environmental performance.
Novonesis and Carbios welcome the European Commission's initiative to establish sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation. Setting a clear and science-based framework for how recycling technologies are assessed is essential if Europe is to meet the recycled-content targets of the PPWR, strengthen the circularity and competitiveness of its plastics…
While clarifying non-compliance penalties would be extremely helpful, allowing recycled content purchased before 2030 to count towards those obligations (and beyond) is crucial to maintaining existing chemical recycling production capacity as well as to finance additional capacity.
Current Situation in China Regulatory Foundation: Environmental regulations, pollutant discharge permit systems and national product quality standards are already in place. Technology Routes: Physical (mechanical) recycling is the mainstream, while chemical recycling remains at the demonstration stage.
This submission concerns the application of Article 7 of Regulation (EU) 2025/40 (PPWR) to packaging used for natural mineral waters within the meaning of Directive 2009/54/EC. It draws attention to the need to ensure regulatory coherence between the mandatory recycled-content requirements under the PPWR and the specific EU regulatory framework governing natural mineral waters.
Fonterra supports the objective of increasing recycled content in plastic packaging. However, Article 7 must be implemented in a way that protects food safety and product performance, accommodates global and seasonal food supply chains, and does not create a de facto barrier to trade for third-country exporters.
The Meat Industry Association of New Zealand (MIA) supports the objectives of the EU Packaging and Packaging Waste Regulation (PPWR) to reduce packaging waste, improve recyclability, and strengthen the circular economy. However, implementation must recognise the realities of global food supply chains and the essential role packaging plays in food safety, shelf life, product integrity, and food waste reduction.
ALPLA welcomes the call for evidence on the PPWR delegated act on sustainability criteria for plastic recycling technologies. To ensure credible and comparable assessments without disproportionate burdens, the future framework should be transparent, harmonised and workable for operators across the European Union (EU).
Plastic Energy Technology Ltd (Plastic Energy) welcomes the opportunity to respond to the European Commissions Call for Evidence on the delegated act under Article 7(9) PPWR, concerning sustainability criteria for recycling technologies. Plastic Energy is a European chemical recycling company that converts end-of-life plastic waste into recycled feedstock for the production of new plastics.
Encina submits these comments from the perspective of a developer of advanced recycling technology and a prospective supplier of circular feedstocks. Please see the attachment for Encinas complete feedback. Encina is a United States-based technology developer working to produce circular chemicals and decarbonize the global chemicals industry.
bobine is a French chemtech start-up dedicated to the electrification and decarbonization of industrial processes. Its proprietary technology, combining heterogeneous catalysis and electromagnetic induction, runs entirely on electricity and converts the pyrolysis gas or oil derived from post-consumer polyolefin waste (PE/PP), which cannot be recycled today, into virgin-quality monomers suitable for food-contact…
The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).
The Natural Polymers Group (NPG) is a coalition of diverse stakeholders who share a common vision: to promote nature-based non-plastic substitutes for the global plastic pollution problem. The NPG represents materials made of natural polymers that have not been chemically modified, including a new generation of nature-based, non-plastic materials capable of replacing conventional plastics and bioplastics.
RCTP welcomes the European Commissions work on the secondary legislation under Article 7 of the Packaging and Packaging Waste Regulation (PPWR) and wishes to highlight the following points: Recognition of closed-loop mechanical recycling in the sustainability criteria; Ensuring that recycled content targets are calculated based on the average of all manufacturing sites; Recognition of existing assessment methods for…
Plastics Europe urges the Commission to design and implement sustainability criteria that provide investment certainty, enable scale-up of innovative recycling technologies, and safeguard EU competitiveness, while delivering plastics circularity at scale. Mechanical, solvent-based and chemical recycling each play a complementary role in the management of plastic waste.
Kolmar Group AG EXTERNAL USE Ref. Ares(2026)8755467 Page 1 of 3 - 15/09/2026 Kolmar Group AG’s response to Call for Evidence on the Delegated Act under Article 7(9) of the Regulation (EU) 2025/40 (PPWR) “Sustainability Criteria for Recycling Technologies” INTRODUCTION Kolmar Group AG welcomes the opportunity to respond to the Call for Evidence on the Delegated Act on sustainability criteria for recycling…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BlueAlp welcomes the opportunity to respond to the Call for Evidence on the Delegated Act on sustainability criteria for recycling technologies under Article 7(9) of the Regulation (EU) 2025/40 (PPWR), and to contribute its members' technical and operational experience to the development of a robust, workable framework.
CONAI and COREPLA welcome the contribution to the consultation of the European Commission on the Delegated Decision supplementing Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), pursuant to Article 7(9), with the sustainability criteria applicable to plastic recycling technologies.
Filed in Italian · English published by the European Commission
EFPIA, representing the innovative, research-based pharmaceutical industry in Europe, welcomes the European Commissions work to establish sustainability criteria for plastic recycling technologies under the PPWR.
The European plastic recycling sector is at a crossroads. As a global leader in environmental services, Veolia believes that the definition of "sustainable recycling technologies must evolve from a mere accounting exercise into a rigorous tool for industrial decarbonization. To achieve circularity, we must implement a legally binding hierarchy of recycling technologies. 1.
September 2026 The LEGO Group’s response to Call for Evidence on Packaging and Packaging Waste – sustainability criteria for plastic recycling technologies Introduction The LEGO Group is committed to making its packaging increasingly sustainable. As of 2025, 95% of our packaging by weight is made from paper, cardboard and other paper-based materials.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.
Call for Evidence on upcoming implementing and delegated acts relating to recycling and recycled content/materials under the Packaging and Packaging Waste Regulation (PPWR) Ref. Ares(2026)8749065 - 15/09/2026 IBMA, the International Biocontrol Manufacturers Association represents the biocontrol industry, with over 200 member companies globally.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BEWI welcomes the European Commissions initiative to establish harmonised rules for calculating and verifying recycled content in plastic packaging under Art 7 of the PPWR. BEWI operates across the plastic value chain as a manufacturer of packaging, insulation, construction products & components, as well as a major collector and recycler of post-consumer plastic waste in Europe.
As the EU develops its framework for sustainable plastic recycling, Kaneka believes that its effectiveness will depend on a robust, science-based approach that ensures recycling delivers on the EUs circular economy objectives and minimizes unintended environmental impacts.
Comments of the Czech Republic on the Proposed Delegated Act under Article 7(9) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic supports the establishment of sustainability criteria based on objective, transparent, and scientifically sound indicators.
MoeBIOS is a project funded by the Circular Bio-based Europe Joint Undertaking and its members. MoeBIOS stands for Improving Waste Management of Biobased Plastics and the Upcycling in Packaging, Textile and Agriculture Sectors. The European Union funds it under grant agreement No. 101157652.
ReBioCycle is a project funded by the Circular Bio-based Europe Joint Undertaking and its members. ReBioCycle stands for "A new European blueprint for circular bioplastics upcycling solutions". Views and opinions expressed are, however, those of the author(s) only and do not necessarily reflect those of the European Union or CBE JU. Neither the European Union nor the CBE JU can be held responsible.
Feedback of Bioeksen Ar-Ge Teknolojileri A.Ş. (Türkiye) manufacturer of CE-marked in vitro diagnostic medical devices (Regulation (EU) 2017/746) placed on the EU market; a downstream user of plastic packaging that will have to source recyclate-containing packaging from 2030 onwards. Keep the criteria technology-neutral and outcome-based.
CONAI and COREPLA welcome the contribution to the consultation of the European Commission on the Delegated Decision supplementing Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), pursuant to Article 7(9), with the sustainability criteria applicable to plastic recycling technologies.
Filed in Italian · English published by the European Commission
We support the development of effective sustainability criteria that contribute to the PPWR's circular-economy objectives and facilitate the uptake of high-quality recycled materials. Sustainability criteria for plastic recycling technologies should be outcome-based and technology-neutral.
Clean Planet Energy (CPE) develops processes that convert hard-to-recycle post-consumer plastic waste into purified pyrolysis oil and circular hydrocarbon feedstocks. Our experience is that environmental performance depends on the feedstock, plant configuration, energy sources, product slate, process integration and the quality of the displaced virgin materialnot simply on the name of a recycling technology.
Futerro is a European producer and recycler of PLA, a bio-based polymer. As an actor involved in both biopolymer production and recycling technologies, Futerro encourages the Commission to develop sustainability criteria that are science-based and technology-neutral.
- Sustainability criteria should assess recycling technologies on the basis of objectively measurable outcomes, science-based criteria and environmental performance rather than favouring specific recycling pathways. - Mechanical recycling, chemical recycling, solvent-based recycling, biotechnological recycling and other recycling solutions should be regarded as complementary approaches.
The Finnish Meat Industry (Atria Suomi Oyj, HKFoods Oyj and Snellmanin Lihanjalostus Oy) welcomes the opportunity to provide feedback on the delegated act (DA) regarding PPWRs article 7 point 9, establishing sustainability criteria for plastic recycling technologies. The companies account for the great majority of meat production in Finland. 1.
Technology openness as a key principle for sustainability criteria under Article 7(9) PPWR Article 7(9) PPWR requires the Commission to define sustainability criteria for plastic recycling technologies based on the assessment under Article 7(8). These criteria should not lead to a regulatory preference for, or exclusion of, any specific recycling technology.
The PPWR requires the Commission to establish sustainability criteria for plastic recycling technologies. These criteria will help ensure that recycled plastic used in packaging delivers the greatest possible environmental benefits through the reuse of single components.
Filed in Italian · English published by the European Commission
I'm an artist, who just recently started building their buisiness. After years of struggling I was finally at a point, where I could earn enough to live. I don't mind paying PPWR. I don't mind paying to recycle trash in general.
Established in 1969, Faerch is a leading provider of circular, rigid food packaging with integrated recycling capabilities, and leads the market with the post-consumer recycled content in our polyethylene terephthalate (PET) plastic trays. Headquartered in Holstebro, Denmark, we employ around 5,000 people across 25 plants in Europe.
Technical-environmental sustainability criteria (Article 7(9)) Logical basic role of mechanical recycling: For single-flow plastic (e.g.: Pet, PE, PP) mechanical recycling has the lowest specific energy consumption and the lowest CO2e emissions. Its place in terms of sustainability is unquestionable.
Filed in Czech · English published by the European Commission
### Please refer to Annex### B-Plast 2000 welcomes the objective of the PPWR to reduce the use of primary plastics and strengthen the European circular economy. However, the concentration of recycled content on post-consumer recycled content (PCR) must not lead to regulatory devaluation of high-quality post-industrial recycled content (PIR).
Filed in German · English published by the European Commission
Brussels, September 2026 EUROPEN’s response to calls for evidence on Article 7 of the Packaging and Packaging Waste Regulation (PPWR) Introduction In August 2026, the EU Commission launched three calls for evidence in relation to Article 7 of the PPWR, which establishes recycled content targets in plastic packaging.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Vantaan Energia is Finland's largest Waste-to-Energy company and we welcome the opportunity to provide feedback. We are preparing a EUR 1 billion CC(U)S project that will capture the 600 ktpa CO from our plants as well as a residual waste sorting facility that will reduce the fossil share of our feedstock.
FEICA, the Association of European Adhesive & Sealant Industry, welcomes the opportunity to provide input to the public consultation on sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation. Please refer to the attached document for our extended feedback.
My name is Arne Bohlen and I am the CEO of B-Plast 2000 KunststoffverarbeitungsGmbH. Our company produces industrial plastic waste and brings it back into the economy as a high-quality recycled raw material. This will avoid waste and replace new plastics from fossil raw materials. I am deeply concerned about the planned concentration of European requirements on recycled plastic from used consumer products.
Filed in German · English published by the European Commission
## Please also refer to Annex## B-Plast 2000 welcomes the objective of the PPWR to reduce the use of primary plastics and strengthen the European circular economy. However, the concentration of recycled content on post-consumer recycled content (PCR) must not lead to regulatory devaluation of high-quality post-industrial recycled content (PIR).
Filed in German · English published by the European Commission
ZF feedback into public consultation Title ZF Group Position – PPWR sustainability criteria for plastic recycling technologies ZF is a globally active EU headquartered company and a key supplier to the automotive and wind industry, with a strong manufacturing, R&D and employment footprint in Europe. ZF Group welcomes the PPWR – but implementation must remain fair and workable. I. General principles 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We maintain that third-country equivalence recognition should be based on verifiable capacity and environmental performance as objective criteria, and should not be demarcated by non-technical proxy indicators such as geographic affiliation or group membership. We have five core concerns. First, we oppose the "OECD-status demarcation".
Japan Cosmetic Industry Association (JCIA) supports the development of a robust and practicable sustainability framework for plastic recycling technologies under Article 7(9). LCA-based greenhouse gas (GHG) emissions, expressed in CO2 equivalents, are an important and internationally comparable indicator for assessing recycling technologies. However, sustainability should not be assessed on GHG emissions alone.
The sustainability assessment and resulting key criteria for plastic recycling technologies should be technology neutral, so as to permit (rather than hinder) innovation in support of a circular plastics economy. This requires a focus on objective and transparent indicators of performance rather than an a priori preference for a specific technology per se.
Invito a presentare contributi della Commissione europea sui criteri di sostenibilità per le tecnologie di riciclaggio della plastica nell’ambito del Regolamento (UE) 2025/40 sugli imballaggi e i rifiuti di imballaggio 10 settembre 2026 Confcommercio esprime le proprie osservazioni nell’ambito delle quattro consultazioni avviate dalla Commissione europea in relazione all’attuazione del Regolamento (UE) 2025/40 sugli…
Filed in Italian · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
bobine is a French chemtech start-up dedicated to the electrification and decarbonization of industrial processes. Its proprietary technology, combining heterogeneous catalysis and electromagnetic induction, runs entirely on electricity and converts the pyrolysis gas or oil derived from post-consumer polyolefin waste (PE/PP), which cannot be recycled today, into virgin-quality monomers suitable for food-contact…
CRE welcomes the opportunity to respond to the Call for Evidence on the Delegated Act on sustainability criteria for recycling technologies under Article 7(9) of the Regulation (EU) 2025/40 (PPWR), and to contribute its members' technical and operational experience to the development of a robust, workable framework.
Helix Projects BV welcomes the opportunity to respond to the Call for Evidence on the Delegated Act on sustainability criteria for recycling technologies under Article 7(9) of the Regulation (EU) 2025/40 (PPWR).
The Czech Traditional Trade Association brings together traditional Czech retail networks, defends the interests of Czech traders, protects and develops the tradition of Czech shops, supports Czech producers as well as regional products. There seems to be a need for an adversarial comprehensive impact study on the legislative introduction of a post-consumer recycled waste obligation for food contact packaging.
Filed in Czech · English published by the European Commission
FEDIMA represents European manufacturers and suppliers of ingredients to the bakery, confectionery and patisserie industries. FEDIMA welcomes the opportunity to provide feedback on this initiative and supports science-based, transparent and harmonised sustainability criteria for plastic recycling technologies.
Fecc the European Association of Chemical Distributors welcomes the opportunity to contribute to the Commissions Call for Evidence on sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).
I'm a sole trader in Italy. I run my entire business alone. In some EU countries I have had only ONE ORDER this year. That can mean only 0.510 grams of packaging placed on that countrys market for the entire year. Some published estimates for cross-border EPR compliance and representation run into thousands of euros per year. THIS IS COMPLETELY DISPROPORTIONATE.
Zawsze byłam wielką zwolenniczką Unii Europejskiej: idea jedności, wolności i równości gospodarczej, poszukiwanie siły we współpracy ekonomicznej, we wspólnocie- są to idee bardzo mi bliskie zwłaszcza w obliczu napięć politycznych i konfliktów z jakimi w ostatnich latach mierzy się Europa. Tym bardziej nie potrafię zrozumieć, jak mógł powstać projekt EPR.
I am running a physical shop which sells used vinyl records and CDs here in Germany which helps me make a living and employ 3 people who work for me, 2 part-time and one full-time. I have started my store in 2022 relying on the possibility to be able to sell my stock online and in the store likewise.
As the regulatory affairs specialist of an SME manufacturer of sterile and non-sterile medical devices (surgical instruments, MDR classes I, Ir, IIa, IIb), we would like to draw attention to a practical challenge in demonstrating recycled content along complex supply chains. Our products frequently contain small plastic components with a packaging function that are sourced from general-purpose plastics processors.
UPM supports sustainability criteria that are technology-neutral and outcome-based. Recycling technologies should be assessed based on their demonstrated environmental and circularity performance rather than on the technology used.
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
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