Plastics Recyclers Europe

Brussels, 10 September 2026 Position on the PPWR Draft Implementing Regulation Establishing Rules on National Registers of Producers INTRODUCTION In response to the public consultation on the draft Implementing Regulation under Article 44(14) of the Packaging and Packaging Waste Regulation (PPWR), this document sets out Plastics Recyclers Europe’s (PRE) priorities on the technical specifications for national…

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

Despite the significant progress achieved during the previous policy cycle, the European plastics recycling industry now stands at a critical crossroads. Ongoing challenges such as market volatility, legal uncertainty, unfair competition, and regulatory fragmentation threaten not only future investments but also the very capacity already built within the sector.

The revision represents a key opportunity to strengthen the role of public procurement as a driver of circularity, resilience, European competitiveness, and the regionality principle to boost uptake of European made materials.

Plastics Recyclers Europe (PRE) welcomes the overall ambition of the Industrial Accelerator Act (IAA) to strengthen the competitiveness and resilience of Europes industrial base. However, PRE regrets the lack of concrete ambition and targeted measures to address the challenges currently faced by the plastics recycling industry, and the entire waste management value chain more broadly.

Plastics Recyclers Europe (PRE), the organisation representing European plastics recyclers, welcomes the IDAA as a pivotal step toward achieving the EUs climate objectives while reinforcing the resilience and global competitiveness of EIIs.

Plastics Recyclers Europe (PRE) would like to provide comments on Annex II, category Substantial contribution to the transition to a circular economy. Plastics Recyclers Europe (PRE) is an organisation representing the voice of European plastics recyclers, who reprocess plastic waste into high-quality material destined for the production of new articles.

Plastics Recyclers Europe welcomes the ECs initiative to revise the Waste Framework Directive (WFD), as an opportunity to improve the waste management of the textile sector, in line with the EU waste hierarchy and the objectives of the EU Textiles Strategy. Please find attached our feedback on the proposal.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the initiative’s objective to harmonise separate waste collection rules at EU level. Our association supports the revision of the Waste Framework Directive (WFD)1 as an opportunity to introduce measures that lead to a clear harmonised distinction between waste as a resource from waste to be disposed of.

With more than 730 facilities generating an annual turnover of 8.7 B, offering an installed capacity of 11.3Mt and employing more than 30,000 persons, the EU plastic recycling industry is a key player on the global scale. Moreover, recycling plastic waste greatly contributes to lowering GHG emissions and reducing pollution from the (mis-)management of plastic waste.

PRE welcomes the publication of the proposal for a Regulation establishing ecodesign requirements for sustainable products (ESPR) and repealing Directive 2009/125/EC, as an opportunity to foster product sustainability in the EU, in the context of the EU Green Deal and the Circular Economy Action Plan. Please find attached our position paper on the EC proposal.

Avenue de Broqueville 12 1150 Brussels – Belgium [phone removed] [email removed] www.plasticsrecyclers.eu Thursday, 12 November 2020 Subject: Sustainable Products Initiative – Roadmap Consultation Inception Impact Assessment – Legislative Proposal Plastics Recyclers Europe (PRE) welcomes the initiative taken by the EU Commission to develop a policy framework on sustainable products to complement the Green Deal…

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

[phone removed] [email removed] www.plasticsrecyclers.eu Avenue de Broqueville 12 1150 Brussels – Belgium 18 November 2021 Subject: Proposal for a Regulation - Carbon Border Adjustment Mechanism Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the proposal for a Carbon Border Adjustment Mechanism (CBAM) as an opportunity to establish a system where a level…

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

Plastics Recyclers Europe welcomes the proposal for a Regulation laying down harmonised conditions for the marketing of construction products (CPR), amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.

Plastics Recyclers Europe (PRE) welcomes the opportunity to give a feedback to the Inception Impact assessment on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals. As an industry association representing plastic recyclers, we are supportive to update the CLP Regulation given more than a decade of scientific and technological progress.

PRE advocates for the recyclability of plastic packaging by design and the inclusion of recycled content in parts and components for new vehicles placed on the market. Therefore, PRE welcomes the requirements of the EC proposal for all vehicles to be designed according to their end-of-life management.

Plastics Recyclers Europe (PRE) represents the interest of the plastics recycling industry. Several of PRE members are specialized in treating the shredder light fraction resulting from the ELV treatment to produce plastics recyclate for use in the traditional plastics compounding and converting industries. A fraction of this material is already being used in the automotive supply chain.

To achieve carbon neutrality, the European industry needs to reduce its dependency on fossil fuels. These are used mostly in the energy sector but, given the electrification of transport, these chemicals will be increasingly used for the production of plastics.

A different methodological framework for the application for authorization should be allowed, whereby the applicants would be allowed to compare different waste management options for the waste containing the substances in question under the analysis of alternatives. The substitution plan could feature aspects such as the development of technology to remove the substance from the input material.

We welcome the European Commission (EC) proposal for a Regulation on preventing plastic pellet losses to reduce microplastics pollution as an opportunity to develop a comprehensive EU framework to tackle microplastics.

Avenue de Broqueville 12 1150 Brussels – Belgium [phone removed] [email removed] www.plasticsrecyclers.eu 18/01/2022 Microplastics pollution – measures to reduce its impact on the environment Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the European Commission (EC) initiative to reduce the presence in the environment of unintentionally released microplastics…

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

Plastics Recyclers Europe (PRE) provides comments on the draft implementing decision laying down rules for calculating, verifying and reporting recycled plastic content in single-use beverage bottles. Mass balance accounting plays a key role in supporting the transition to a circular economy and the development of emerging recycling technologies.

With more than 730 facilities generating an annual turnover of 8.7 B, offering an installed capacity of 11.3Mt and employing more than 30,000 persons, the EU plastic recycling industry is a key player on the global scale.

Plastics Recyclers Europe welcomes the ECs initiative to revise the Union Custom Code (UCC) as an opportunity to create a level playing field between the EU industry and global economic partners. Please find attached a paper detailing our position on this initiative. PRE remains available to further discuss the elements included in this paper with the relevant policy officers at DG TAXUD

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the reform of the Union customs legislation as an opportunity to bridge several EU policies while ensuring a playing level field for all products being placed on the Single Market.

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)

Brussels, 16 September 2026 Calculating and verifying recycled content from post-consumer plastic waste INTRODUCTION The document proposes a robust verification methodology aligned with Article 7(8) of the Packaging and Packaging Waste Regulation (PPWR), which requires calculating and verifying recycled content from post-consumer plastic waste.

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

Plastics Recyclers Europe (PRE), the organization representing European plastics recyclers, supports the Digital Product Passport (DPP) as a critical tool to enhance transparency in product sustainability under the ESPR. However, to ensure that plastics circularity can effectively benefit from the DPP, PRE would like to highlight key issues that need to be addressed during the design of the secondary legislation.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the proposal for a revision of the Waste Shipment Regulation (WSR) and appreciates the opportunity to provide comments, which can be found attached.

The revision of the Waste Shipment Regulation provides the opportunity to address key issues that Plastics Recyclers Europe (PRE) is pleased to present. 1. Less administrative burdens, same environmental and human health protection To increase the circularity of plastic waste, transboundary shipments should become swifter and constraint by less administrative burdens.

Plastics Recyclers Europe (PRE) welcomes the European Commissions initiative to establish EU-wide end-of-waste (EoW) criteria for plastic waste. PRE has long supported harmonised EoW criteria as a key tool to strengthen the internal market for plastic recyclates, reduce administrative burden, and provide legal certainty for recyclers operating across borders.

Joint proposal for an effective mirror clause under Article 7(10) of PPWR INTRODUCTION FEAD, PRE and Recycling Europe recommend introducing under Article 7(10) of the Packaging and Packaging Waste Regulation (PPWR) a clear Made in Europe preference for plastic recycled content (RC) targets: ➢ For packaging produced or filled in the EU: compliance with recycled content targets should rely on recycled plastics…

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

The proposal sets an ambitious legal framework to prevent any failure of the electricity market in the EU and represents a fundamental measure in support of energy-intensive industries like plastic recycling facilities.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the utilization of all data for holistic evaluation of chemicals and acknowledges that more can be done to achieve synergies in the utilization of data at the European level. Please find more details in the attachment.

Plastics Recyclers Europe, the association representing the plastic recycling industry at the EU level, welcomes the ECs initiative to revise the EU textile labelling rules, as an opportunity to introduce requirements on communicating on the environmental aspects of textiles, in line with the objectives of the EU Textiles Strategy. Please find attached our feedback to the public consultation.

The plastics recycling industry has made vast progress to treat complex waste streams. The processes implemented at the recycler facilities successfully manage to produce recyclates below 500 mg/kg of the sum of the PBDEs. The remaining fraction, containing the concentrate of PBDEs, is to be sent, today, to the disposal route for destruction.

We read the Inception Impact Assessment with great interest and agree with most of the considerations included therein; most notably the trade-off reflected upon between the ambition of an absolute toxic-free environment and the circular economy. In this response, we would like to highlight how WEEE/ELV plastics recycling contributes to both of these objectives.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the drafted implementing decision laying down rules for the application of Directive (EU) 2019/904 (SUPD) as regards the calculation, verification, and reporting of data on the separate collection of waste single-use plastic beverage bottles.

Plastics Recyclers Europe (PRE), the Brussels-based leading association representing the plastic recycling industry, welcomes the proposal to constitute an EU Green Bond Standard as a key element to address and deliver the goal of the Green Deal, the targets of the Circular Economy Action Plan and the objectives of the Strategy for Plastics in the Circular Economy.

Plastic Recyclers Europe (PRE) welcomes the inception impact assessment on Eco-design and Energy labelling requirements for computers. We are enthusiastic that the improvements of the current legislation and the set initiatives would stimulate economic developments and innovation, as well as strengthen the sustainable society.

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