VinylPlus

VinylPlus has uploaded a document describing the following recommendations to deliver a Circular Economy in Europe, for Europe: - Revise Technical Guidance on waste classification to ensure waste classification follows an End of Life (EoL) product classification logic. - Make pre-demolition/renovation audits and the separate collection at source, and identification of recyclable waste streams, mandatory.

VinylPlus is the European PVC (Polyvinyl Chloride) value chains voluntary commitment to sustainable development, gathering primary production, transformation and recycling companies. VinylPlus believes that the revision of the EU Public Procurement directives is an opportunity to align procurement with EU priorities and recommends that their includes in particular those changes necessary to: 1.

VinylPlus, the European PVC Value Chain Commitment to Sustainability, invites the Commission to consider the following points of attention in delivering an IAA which delivers its purpose: - Assess sector-specific exposure to public demand and include safeguards, before IAA requirements are imposed on a sector or product for which public demand represents a dominant share of the market (e.g., pipes and fittings).

The European Council of Vinyl Manufacturers and VinylPlus, the sustainability commitment of the European PVC Value Chain, strongly support the Commissions proposed 2026-2030 product benchmark values for VCM, S-PVC and E-PVC. They are technically justified, important for carbon leakage protection, and should be maintained unchanged in the final Regulation.

VinylPlus’s comments on the Inception Impact Assessment roadmap “Review of the Construction Products Regulation” VinylPlus is the voluntary commitment of the European PVC industry. It establishes a long-term framework for the sustainable development of the industry in the EU-27, UK, Norway and Switzerland.

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

VinylPlus supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular plastics target will all be needed.

Europes housing affordability crisis requires faster, simpler and more cost effective construction and renovation. With around 80% of PVC applications used in buildings, the European PVC value chain is well positioned to support accelerated housing delivery by providing durable, affordable, energy efficient and increasingly circular construction materials that are already widely deployed across Europe.

Construction products are currently governed by a complex framework of product, energy, chemicals, waste, procurement and sustainability legislation. While each framework pursues legitimate objectives, their interaction often creates duplication, inconsistent requirements and legal uncertainty.

VinylPlus, the voluntary commitment of the European PVC industry to sustainable development, supports the implementation of the Digital Product Passport (DPP) as a tool for enhancing transparency and circularity. To ensure its success, the governance and operation of DPP service providers must align with principles of fairness, security, and practicality, particularly for material-intensive industries like PVC.

Advanced materials are intentionally engineered to deliver innovative solutions needed for a more efficient, sustainable and competitive industry, and Polyvinyl Chloride (PVC) meets this definition. Continuous improvements in its formulation, processing and recycling have made PVC a high-performance, adaptable and circular material with long service life, lightweight and energy efficiency properties.

VinylPlus recommends the following: - Water resilience requires resilient infrastructure: Effective water management must be supported by durable, climate-resilient and resource-efficient water distribution, wastewater and stormwater networks.

VinylPlus welcomes the EUs initiative to develop and harmonise recyclate-specific EoW criteria at EU level and supports the contributions made by Plastics Europe, European Plastics Converters (EuPC) and Plastics Recycling Europe (PRE). As a complement, we would like to stress in particular the following points: 1.

The revision of the Governance Regulation should ensure that National Energy and Climate Plans (NECPs) provide the predictability, transparency and investment framework required for the decarbonisation of energy-intensive industrial value chains such as PVC, while safeguarding Europes industrial competitiveness and strategic autonomy.

VinylPlus, representing the European PVC Value Chain, requests a targeted correction to Annex III, Part I, entry EU3011 of Regulation (EU) 2024/1157. PVC is not fluorinated polymer. The current drafting nevertheless places PVC under the indent for "fluorinated polymers" and, as a result, subjects PVC to footnote 7 ("Post-consumer wastes are excluded").

To strengthen coherence across EU legislation, we recommend that the Unions rules of origin serve as a common reference point not only for origin marking in the context of customs and trade policy, but also for ecolabels, public procurement, and other instruments that will increasingly incorporate Made in Europe as European preference criteria in product legislation as well as purchasing and consumption decisions…

VinylPlus® welcomes the Commission initiative to establish harmonised rules for the calculation and verification of average loss rates (ALRs) for sorted waste under Directive 2008/98/EC. As a European value-chain commitment promoting the circularity of PVC in general and, especially in construction applications, VinylPlus® supports robust and transparent methodologies for measuring recycling performance.

The Roadmap is useful to clarify the Commission’s purpose and intentions. The members of the Plastics producers’ associations are not themselves producing E&E goods therefore we cannot comment on the effectiveness and efficiency of RoHS legislation. However, we will be able to comment on the coherence, relevance and EU added value.