Rules for the calculation and verification of recycled content in plastic packaging

176 submissions in the snapshot (171 from organisations), portal total 176. Feedback list on the portal.

171 of 171 organisation submissions analysed; the model reads them as: opposes 1 supports 22 wants changes 103 45 held back for review (low confidence).

• Micro company, FRA Company, FRA model reads as: opposes source
  • Provide exemptions for micro businesses and enterprises falling below a certain threshold.

    I thought the EU was meant to champion the innovation and imagination of small businesses, but unless you give an exemption for micros or those under a certain threshold there won't be anyone left.

• ecoplus. Niederösterreichs Wirtschaftsagentur GmbH NGO, AUT model reads as: wants changes source
  • Ensure the calculation method is technology-open and does not disadvantage specific recycling technologies.

    However, the design of the calculation method should ensure that it is technology-open and does not structurally disadvantage any specific recycling technologies.

    machine translation by the Commission, original in DE
  • Recognise mass balance accounting to allocate recycled content where carbon streams cannot be physically separated.

    In particular, mass balance accounting should be recognised as an appropriate tool to allocate recycled content.

    machine translation by the Commission, original in DE
  • Create a uniform, standardised, and digitally supported verification system for all market participants instead of SME exemptions.

    Instead of different requirements for different company sizes, a uniform, transparent and digitally supported system that is workable for all market participants should be created.

    machine translation by the Commission, original in DE
• REDcert Gesellschaft zur Zertifizierung nachhaltig erzeugter Biomasse mbH Other, DEU model reads as: wants changes source
  • Rely on established market certification schemes rather than building parallel regulatory structures.

    The strategic premise here must be to rely on certification schemes that are already established and functioning in the market, rather than building inefficient parallel regulatory structures.

    machine translation by the Commission, original in DE
  • Avoid requiring companies to fundamentally redesign existing IT systems and detection methods.

    At the same time, new rules must not force companies to fundamentally redesign their established IT systems and detection methods.

    machine translation by the Commission, original in DE
  • Initiate a formal structured exchange between the European Commission and established system operators like REDcert.

    First, a formal exchange between the European Commission and established system operators such as REDcert should be initiated.

    machine translation by the Commission, original in DE
• Asociace českého tradičnního obchodu Business association, CZE; register: Trade unions and professional associations model reads as: wants changes source
  • Link existing certification standards to the Digital Product Passport instead of establishing a new greenfield apparatus.

    the Commission should not create a completely new “greenfield” certification apparatus, but should link existing established standards (EN 15343, RecyClass, EuCertPlast) to the forthcoming Digital Product Passport (DPP).

    machine translation by the Commission, original in CS
  • Require third-country certification bodies to hold strict ISO/IEC 17065 accreditation supervised by European Accreditation Bodies.

    it is necessary to insist that certification bodies operating in third countries be subject to strict ISO/IEC 17065 accreditation under the supervision of European Accreditation Bodies (EA).

    machine translation by the Commission, original in CS
• DR. JOHANNES HEIDENHAIN GmbH Company, DEU model reads as: wants changes source
  • Recognise industrial closed material loops and avoid rigid post-consumer-recycled-only rules that displace post-industrial recyclate.

    The attached position paper highlights the need to recognise industrial closed material loops and to avoid rigid PCR-only requirements that create shortages or displace suitable PIR.

  • Base verification on supplier data and annual mass balances rather than component-level tracking in downstream ERP and PLM systems.

    Verification should rely on supplier data and annual mass balances instead of creating component-level tracking in downstream PLM and ERP systems without reducing packaging waste.

• Chemical Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Adopt the implementing act promptly using the Single-Use Plastics Directive fuel-use-excluded mass balance methodology.

    Chemical Recycling Europe urges the Commission to adopt the Article 7(8) implementing act without delay, on the basis of the SUPD Implementing Decision's fuel-use-excluded mass balance methodology.

  • Refine the methodology to recognize non-fuel gaseous outputs, remove default zero factors for solid outputs, enable cross-site credit transfers, and recognize pre-2030 credits.

    The refinements set out in this position, recognising non-fuel, dual-use gaseous outputs from fluid catalytic cracking (FCC) beyond propylene alone, removing the default zero factor for solid outputs on an evidence-based footing, enabling broader site-to-site credit transfers within the EU27, EFTA and the United Kingdom safeguarded by like-for-like and certification requirements, and recognising mass balance credits generated ahead of the 2030 obligation on a clearly transitional basis, would preserve the credibility of the methodology while allowing the market to scale recycled content supply as quickly and cost-effectively as possible.

• Pöppelmann GmbH & Co. KG Kunststoffwerk-Werkzeugbau Company, DEU model reads as: wants changes source
  • Determine recycled content as an annual plant-level average and recognize existing certifications directly.

    Recycled content shall be determined as an average per manufacturing plant per year on the basis of material flows at annual level for producers and the upstream supply chain alike. Established evidence (RecyClass, Blue Angel, EMAS) must be directly recognised to avoid double testing.

    machine translation by the Commission, original in DE
  • Rely on standardized, open, and machine-readable data systems such as the Digital Product Passport.

    the EU needs to build on standardised, open and machine-readable systems (such as the Digital Product Passport) to which customer interfaces can technically connect.

    machine translation by the Commission, original in DE
  • Implement a flexible token-based accounting system within packaging categories instead of a rigid per-package quota.

    A flexible token-based accounting system (at least within the packaging category) ensures an environmentally sensible and economically efficient use of recycled materials.

    machine translation by the Commission, original in DE
• Procter & Gamble Company, BEL; register: Companies & groups model reads as: wants changes source
  • Recognise mass balance accounting under a technology-neutral and fuel-use-excluded approach with proportionate verification.

    Mass Balance Accounting (MBA) needs to be recognised as the appropriate tool by which to allocate recycled content.

  • Maintain compliance aggregation at the level of packaging type, format, manufacturing plant, and year rather than per individual pack or SKU.

    The legislative text explicitly defines the relevant point of aggregation and it relates to packaging type and format as referred to in Table 1 of Annex II, calculated as an average per manufacturing plant and year.

  • Apply targets to the packaging unit as a whole using aggregate PCR weight rather than requiring each individual plastic component to comply.

    The IA required should allow an aggregate PCR quantity, calculated by weight across all qualifying parts to be used as the basis of the target.

• Japan Cosmetic Industry Association Business association, JPN model reads as: wants changes source
  • Allow a complementary approach to calculate and manage recycled content across multi-component finished packaging as a whole.

    in addition to calculating and managing recycled content separately for each component and manufacturing plant, a complementary approach should be allowed to calculate and manage recycled content for the finished packaging as a whole, using the total weight of its plastic packaging components (A+B+C) as the denominator.

  • Base verification on process documentation and material inputs while addressing normal production variability rather than testing individual units.

    Verification should primarily rely on reliable evidence such as material input quantities, production volumes, recycled-content allocation, process records and technical documentation, rather than requiring excessive testing of individual packaging units.

  • Treat chemical and mechanical recycling neutrally and permit credible mass balance chain of custody systems with existing third-party certifications.

    Mechanical recycling and chemical recycling should be treated in a technology-neutral manner. Chemically recycled content should be eligible to count towards recycled-content targets, including through an appropriate mass-balance approach, where the methodology is scientifically and technically sound and a suitable Chain of Custody enables recycled feedstock inputs and allocations to be tracked and verified.

• Olmmer Sp z oo Company, POL model reads as: wants changes source
  • Adopt a mass balance methodology that fully reflects the complete industrial value chain, including treatment and refining phases.

    To unlock vital circular investments across Europe, the final framework must adopt a mass balance methodology that fully reflects the complete industrial value chain.

  • Allow a flexible, credit-based mass balance approach that exempts fuel outputs and bases recycled content attribution on verifiable, process-specific yields.

    We urge the Commission to allow a flexible, credit-based mass balance approach that exempts fuel outputs and bases recycled content attribution on verifiable, process-specific yields.

• Japan Electronics and Information Technology Industries Association （JEITA） Business association, JPN model reads as: wants changes source
  • Avoid requiring physical segregation between EU-bound and non-EU-bound packaging where traceability can be ensured through auditable allocation or mass-balance methods, and recognize equivalent non-EU verification.

    First, the methodology should not require physical segregation between EU-bound and non-EU-bound packaging where sufficient traceability and verifiability can be ensured through auditable allocation methods.

  • Identify and report eligible pre-consumer recycled material separately from post-consumer recycled plastic.

    Second, while respecting the current minimum recycled-content targets based on post-consumer recycled (PCR) plastic, JEITA recommends that eligible pre-consumer recycled material be clearly identified and reported separately from PCR.

  • Provide a clear mechanism to exclude packaging covered by application-specific derogations from the recycled-content calculation without requiring physical segregation.

    Where a derogation is granted under Article 7(12) or other applicable provisions, the relevant packaging should be clearly excluded from the recycled-content calculation.

• BASF Company, DEU; register: Companies & groups model reads as: wants changes source
  • Adopt a Fuel Use Excluded mass balance approach that links credits to verified mass in non-fuel applications without overly restrictive proportional downstream fuel deductions.

    For BASF, a Fuel Use Excluded (FUE) mass balance approach is the best way to ensure the most cost-efficient way for scaling-up chemical recycling in the EU and for achieving PPWR targets.

  • Account for exclusions of fuels, energy recovery, and process losses while attributing recycled-content credits to verified non-fuel material.

    BASF supports a methodology that accounts for the exclusion of fuels, energy recovery, and process losses, while linking recycled-content credits to the verified mass of material used in non-fuel applications.

• ATIEL Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Avoid unnecessary physical segregation, product-level traceability, duplicate SKUs, or duplicate inventories.

    Calculation rules should avoid unnecessary physical segregation, product-level traceability, duplicate SKUs or duplicate inventories, particularly where production serves both EU and non-EU markets.

  • Recognize existing certification, audit, and assurance systems that provide equivalent evidence.

    Existing certification, audit and assurance systems should be recognised where they provide equivalent evidence, to avoid duplication and reduce administrative burden.

  • Provide longer transition periods, clear guidance, and worked examples to support implementation.

    Longer transition periods, clear guidance, and worked examples are needed to support consistent implementation by operators, suppliers, auditors, and certification bodies.

• Lamor Corporation Oyj Company, FIN model reads as: wants changes source
  • Allow brand owners to purchase and bank independently verified recycled content prior to 2030 to apply toward post-2030 obligations.

    Allow brand owners to purchase and bank independently verified recycled content before 2030 and apply it towards their post-2030 obligations.

  • Base recycled-content attribution on verifiable process data and actual yields rather than generic averages.

    Base recycled-content attribution on verifiable process data and actual yields, rather than generic assumptions or technology averages.

  • Allow credit-based and non-proportional mass-balance allocation across integrated production systems.

    Allow credit-based and non-proportional allocation across integrated production systems, including upgrading, refining and facilities where recycled and fossil feedstocks are co-processed.

• Micro company, ITA Company, ITA model reads as: supports source
  • Ensure uniform rules that reduce administrative burden by providing legal clarity to the recycling industry.

    reduce the administrative burden for compliance across the EU by providing the recycling industry with the legal clarity it needs to make the necessary investments

    machine translation by the Commission, original in IT
  • Assist companies in implementing recycled content obligations by prohibiting non-recyclable composite materials.

    help businesses properly implement the obligations on recycled content in plastic packaging by banning non-recyclable composite materials.

    machine translation by the Commission, original in IT
• Atria Oyj Company, FIN; register: Companies & groups model reads as: wants changes source
  • Calculate recycled content at the material supplier's production unit and allow downstream operators to aggregate declared percentages.

    The methodology should establish the calculation regarding recycled plastic at the level of the material suppliers production unit, and require the supplier to declare the recycled content percentage of each delivered material.

  • Permit technical documentation and reporting to be aggregated at company or legal entity level rather than plant-by-plant.

    The format of the technical documentation should allow evidence to be compiled and submitted per legal entity, and allow groups to report on a combined basis, as is possible today under Finnish EPR arrangements.

  • Allow mass balance chain of custody and count chemical recycling on the same basis as mechanical recycling.

    The methodology should allow mass balance chain of custody and count recycled content from chemical recycling on the same basis as mechanically recycled content, subject to the criteria adopted under Article 7(9).

• CONAI e COREPLA Company, ITA model reads as: wants changes source
  • Base the implementing act on a dual TFEU legal basis of internal market and environment.

    Provide for a dual legal basis in the TFEU, Article 114 internal market and Article 191 environment

    machine translation by the Commission, original in IT
  • Use Implementing Decision 2026/1425 under the Single-Use Plastics Directive as the reference method.

    Consider Implementing Act 2026 of the Single-Use Plastics (SUP) Directive for the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles;

    machine translation by the Commission, original in IT
  • Verify compliance via an accredited European third-party certification scheme covering EU and imported packaging.

    Provide for compliance through a scheme accredited in Europe and certifiable by a third party;

    machine translation by the Commission, original in IT
• Bioeksen AR GE Teknolojileri A.Ş Company, TUR model reads as: wants changes source
  • Place primary calculation and verification obligations on converters and let downstream actors rely on supplier declarations.

    The implementing act should place the calculation and primary verification obligation on the economic operator incorporating the recyclate, and allow downstream operators (manufacturers of packaged products, importers) to rely on a supplier declaration backed by a certified chain-of-custody scheme without re-verification.

  • Recognise existing chain-of-custody schemes and allow controlled mass balance rather than establishing a new EU-only scheme.

    The act should accept established third-party certification schemes (e.g. EuCertPlast, RecyClass, ISCC PLUS or equivalent) and permit controlled mass-balance allocation with a defined bookkeeping period, rather than introducing a new EU-only scheme.

  • Explicitly reflect exemptions for medical device and in vitro diagnostic packaging within the documentation format.

    The documentation format should include a dedicated declaration field for exempt packaging, stating that no recycled-content calculation is required and that the exemption is evidenced by the device's regulatory status (e.g. reference to the EU declaration of conformity under Regulation (EU) 2017/746).

• BEWI Company, NOR model reads as: wants changes source
  • Recognise existing standards and credible third-party certification systems.

    Recognises existing standards and credible third-party certification systems

  • Recognise mass balance for both mechanical and chemical recycling.

    Recognises mass balance for both mechanical and chemical recycling

  • Apply technology-neutral rules and equivalent verification requirements.

    Applies technology-neutral rules and equivalent verification requirements

• Veolia Company, BEL; register: Companies & groups model reads as: wants changes source
  • Establish a technology hierarchy based on environmental intensity and greenhouse gas emissions.

    We advocate for the implementation of a hierarchy of recycling technologies to define eligibility for mandatory recycled content.

  • Prioritise a polymer-only mass-balance method and restrict fuel-exempt allocation to operational data tied to production sites.

    We reiterate our preference for a "polymer-only" approach which provides superior traceability and transparency by ensuring recycled content credits are strictly allocated to plastics outputs rather than fuels or other chemicals, which prevents greenwashing and maintains a level playing field between mechanical and chemical recycling.

  • Exclude bio-based plastic from recycled content obligations under the PPWR.

    Bio-based plastic shall not account for recycled content obligations in PPWR.

• COREPLA - Consorzio Nazionale per la raccolta, il riciclo e il recupero degli imballaggi in plastica Other, ITA model reads as: wants changes source
  • Base the act on a dual legal basis in the TFEU covering both internal market and environmental provisions.

    Provide for a dual legal basis in the TFEU, Article 114 internal market and Article 191 environment

    machine translation by the Commission, original in IT
  • Align methodology with the Single-Use Plastics Directive implementing decision for beverage bottles.

    Consider Implementing Act 2026 of the Single-Use Plastics (SUP) Directive for the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles;

    machine translation by the Commission, original in IT
  • Verify compliance through an accredited European scheme certifiable by third parties.

    Provide for compliance through a scheme accredited in Europe and certifiable by a third party;

    machine translation by the Commission, original in IT
• The Brewers of Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure mandatory recycled content quotas are supported by adequate supplies of food-grade recyclate and fair access to deposit return system materials.

    Mandated recycled content quotas must be backed by a sufficient, high-quality, and food-grade supply of recyclate (specifically food-grade rPET), including by ensuring that beverage producers retain fair access to rPET generated through well-functioning Deposit Return Systems.

  • Calculate recycled content targets across the whole packaging unit or format rather than on individual micro-components.

    Target calculations must apply across the packaging unit or format as a whole rather than imposing unrealistic quotas on individual micro-components.

  • Measure compliance at the assembly and filling site instead of at upstream supplier facilities.

    Compliance measurement must be tied to the assembly and filling site ("manufacturing plant") rather than upstream supplier facilities.

• Roundtable for Reusable Containers Trays and Pallets Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Recognise closed-loop mechanical recycling within the secondary legislation sustainability criteria.

    Recognition of closed-loop mechanical recycling in the sustainability criteria;

  • Calculate recycled content targets based on the average across all manufacturing sites.

    Ensuring that recycled content targets are calculated based on the average of all manufacturing sites;

  • Require imported post-consumer plastic waste to meet EU standards as a minimum.

    Ensure imported post-consumer plastic waste follows EU standards as a minimum.

• German Aerospace Industries Association (BDLI e.V.) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Recognise reusable packaging systems and introduce transitional arrangements so existing packaging in circulation is not disadvantaged or prematurely discarded.

    The future framework should ensure that reusable packaging solutions continue to be recognised as an important contribution to circularity and environmental performance and are not unintentionally disadvantaged compared to single-use packaging.

  • Clarify the scope of obligations and differentiate between consumer-facing packaging and industrial B2B packaging.

    The implementing measures should clearly define the scope of obligations and distinguish, where appropriate, between consumer-facing packaging and industrial B2B packaging.

  • Establish clear thresholds and proportionate documentation requirements for companies placing limited packaging quantities on the market in specialised sectors.

    Clear thresholds, simplified procedures and proportionate (technical) documentation requirements would help avoid administrative burdens while supporting the environmental objectives of the PPWR.

• Japan Business Council in Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Allocate compliance responsibilities clearly across the supply chain so downstream operators can rely on upstream supplier information without duplicative verification.

    Packaging users should be able to demonstrate compliance based on information received from their direct suppliers and should not be required to duplicate verification activities that have already been appropriately performed upstream.

  • Permit auditable mass-balance allocation without excluding chemical recycling, aligned with European and international standards.

    Recycled plastic derived from chemical recycling should not be excluded, and methodologies should be aligned, where appropriate, with relevant international and European standards in order to support globally integrated supply chains.

  • Rely on existing certification schemes and favour periodic assessments over lot-by-lot verification.

    Verification requirements should favour practical periodic assessments rather than transaction-level or production-lot-based verification.

• NewClimate Institute Academic or research institution, DEU model reads as: wants changes source
  • Mandate proportional allocation based on measured input and output data and attribute credits only to plastic outputs.

    Article 7(8) should mandate proportional allocation based on measured input/output data.

  • Prohibit the transfer of attributed recycled content amounts between facilities or entities.

    Article 7(8) should adopt SUPD's ban on transfer of attributed amounts across facilities or entities.

  • Define Commission-mandated minimum standards for measurement and auditor accreditation.

    Article 7(8) must establish Commission-mandated minimum standards for measurement and auditor accreditation.

• bobine Company, FRA; register: Companies & groups model reads as: wants changes source
  • Include a direct physical attribution pathway where an operator demonstrates no fossil-blended intermediate exists before the monomer stage.

    The methodology should include a direct physical attribution pathway where the operator demonstrates that no fossil-blended intermediate intervenes between the waste input and the monomer output, measured on a single-pass basis.

  • Differentiate between physically measured recycled content and allocation-based recycled content in claims.

    Reliable, verifiable and enforceable claims presuppose that the methodology distinguishes between physically measured recycled content and recycled content established by allocation.

  • Ensure proportionate documentation and verification requirements for SMEs and first-of-a-kind plants while defining physical measurement verification.

    Ensure proportionate documentation and verification requirements for SMEs and first-of-a-kind plants, whose certification and audit costs are largely fixed.

• Encina Development Group Company, USA model reads as: wants changes source
  • Define eligible post-consumer plastic waste, recycled outputs, exclusions, and the calculation point.

    Define eligible post-consumer plastic waste, recycled outputs, exclusions, and the point at which recycled content is calculated.

  • Allow auditable chain-of-custody models including mass balance or controlled mixing where physical segregation is impracticable.

    Permit auditable chain-of-custody models, including controlled mixing or mass balance where physical segregation is impracticable.

  • Establish transparent rules for allocation, reconciliation, conversion factors, and double-counting across the value chain.

    Establish transparent allocation, reconciliation, conversion-factor, and double-counting rules across the value chain.

• ALPLA Werke Alwin Lehner GmbH & Co KG Company, AUT; register: Companies & groups model reads as: wants changes source
  • Establish a regulatory pathway towards a rolling-average mass balance methodology.

    The implementing act should establish a pathway towards rolling-average mass balance;

  • Ensure a level playing field through robust equivalence requirements for imported recycled plastics.

    ensure a level playing field through robust equivalence requirements for imported recycled plastics;

  • Establish a phased, risk-based verification framework while avoiding duplicative certification.

    recognise existing EU regulatory controls and avoid duplicative certification; clarify the treatment of novel technologies and purity tolerances; and establish a phased, risk-based verification framework with harmonised documentation, declaration and reporting requirements across the value chain, while minimising unnecessary administrative burden.

• SEMI Europe Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Assess recycled-material suitability by specific material grade and intended application rather than just polymer type.

    Recycled-material suitability should therefore be assessed at the level of the specific material grade and intended packaging application, rather than solely by polymer type or general market availability.

  • Ensure requirements for traceability, documentation, and verification remain clear, proportionate, and internationally applicable.

    SEMI Europe supports clear, proportionate and internationally applicable requirements for traceability, documentation and verification.

• Fonterra Ltd Company, NZL model reads as: wants changes source
  • Evaluate recycled material suitability against hygiene, safety, and functional requirements of the specific packaging application.

    Suitability must be demonstrated against the hygiene, safety and functional requirements of the actual packaging application, including sensitive food logistics.

  • Establish fair, transparent, and technology-neutral equivalence routes for third-country certification and chain-of-custody systems.

    The rules should recognise credible international certification, auditing and chain-of-custody systems where they provide equivalent assurance.

  • Allow compliance reconciliation by packaging type and format over a calendar year across multi-site groups.

    Compliance should be calculated by packaging type and format over a calendar year using verified input-side evidence and controls to prevent double counting.

• China Packaging Federation NGO, CHN model reads as: wants changes source
  • Recognize mass balance for compliance accounting while differentiating mechanical from chemical recycling.

    Recognize the mass balance method: Treat it as the primary method for compliance accounting, but it should not be the core method for all recycling routes.

  • Calculate compliance on a factory annual weighted average rather than mandating compliance per product.

    Adhere to annual averaging: Calculate based on the factorys annual weighted average instead of mandating compliance for individual products.

  • Grant equal compliance access to third-country traceability systems and allow qualified third-party auditing institutions worldwide.

    Clarify a unified compliance pathway for third-country suppliers and grant equal compliance access to mature practical traceability systems from third countries, facilitating compliance and market access for non-EU countries and ensuring smooth international trade.

• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Replicate the mass balance calculation methodology agreed under the Single-Use Plastics Directive Implementing Decision.

    1) Replicate under PPWR the mass balance calculation methodology agreed under the recently adopted SUPD Implementing Decision.

  • Adopt a polymer-only mass balance method and review clause recognizing complementary recycling roles.

    Thus, Recycling Europe believes that the polymer-only mass balance method is better suited to the plastic recycling landscape, and would provide greater transparency and trust from final consumer .

  • Prioritize mechanical recycling over chemical recycling unless technically infeasible.

    3) Prioritize recycling technologies with the lowest environmental impact, i.e. mechanical recycling.

• Evonik Industries AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Deduct fuel based on certified sales volumes rather than proportional deduction at every step.

    The fuel use exempt mass balance methodology should be retained, but fuel should be deducted based on certified volumes of materials produced, rather than proportionally deducting fuel at each step of the process as is prescribed under SUPD.

  • Do not use the Single Use Plastics Directive rules as a blueprint for the Packaging and Packaging Waste Regulation.

    However, we believe that they cannot serve as a blueprint for the Packaging and Packaging Waste Regulation (PPWR) as they do not support the economically viable use of all recycling technologies, especially in connection with existing assets.

  • Adopt a certified sales volume-based approach to assign full credits for non-fuel materials.

    In our view, a so-called certified sales approach would constitute an efficient and effective way forward.

• Polyolefin Circular Economy Platform Business association, BEL; register: Trade and business associations model reads as: supports source
  • Align with the approach established under single-use plastic beverage bottles, including mass balance excluding fuel use.

    PCEP supports alignment with the approach already established for chemically recycled content in single-use plastic beverage bottles, including the use of a mass balance methodology that excludes fuel use from allocation calculations.

  • Adopt the implementing act within the established timeline to ensure legal clarity.

    PCEP therefore encourages the Commission to adopt the implementing act within the timeline established under the PPWR in order to provide the legal clarity needed to accelerate recycling investments and capacity development in Europe.

• Micro company, ZAF Business association, ZAF model reads as: wants changes source
  • Allow bilateral equivalence agreements rather than requiring identical national legislation in third countries.

    Do not require identical national legislation in the third country for equivalence. Allow a bilateral equivalence agreement on the model used for organic products.

  • Put intermediary measures in place for non-EU recyclate until EU criteria are established.

    Put intermediary measures in place for non-EU recyclate until the EU criteria are set, including recognition under Regulation (EU) 2022/1616 as sufficient until 2030.

  • Recognise accredited international and industry standards and third-party audit without tying recognition to a single scheme.

    Recognise accredited international and industry standards and third-party audit, without tying recognition to a single scheme, so alternatives such as EN 15343 remain valid.

• Micro company, ZAF Business association, ZAF model reads as: wants changes source
  • Do not require identical national legislation in third countries and allow bilateral equivalence agreements.

    Do not require identical national legislation in the third country for equivalence. Allow a bilateral equivalence agreement on the model used for organic products.

  • Put intermediary measures in place for non-EU recyclate until EU criteria are set.

    Put intermediary measures in place for non-EU recyclate until the EU criteria are set, including recognition under Regulation (EU) 2022/1616 as sufficient until 2030.

  • Recognise accredited international and industry standards and third-party audit without tying recognition to a single scheme.

    Recognise accredited international and industry standards and third-party audit, without tying recognition to a single scheme, so alternatives such as EN 15343 remain valid.

• CO2 Value Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Systematically integrate CCU technologies into recycling legislation.

    1. Systematically integrating CCU technologies in EU legislations regarding recycling, as it is a key lever of advanced recycling;

  • Introduce mass balance accounting to enable feedstock differentiation.

    2. Introducing mass balance accounting to be able to differentiate feedstocks;

  • Ensure consistency across legislations to give investors clarity.

    3. Ensuring consistency throughout existing and upcoming legislations in order to ensure companies and investors have clarity when making financial decisions.

• Svaz chemického průmyslu České republiky Business association, CZE; register: Trade and business associations model reads as: wants changes source
  • The methodology should restrict mass balance accounting to cases where traceability is maintained, yields and losses are documented, independent verification occurs, and double counting is prevented.

    The methodology should permit the use of mass balance accounting only where the traceability of material flows is maintained, yields and losses are documented, independent verification is conducted, and double counting is prevented.

  • Only recyclate derived from post-consumer waste should count toward targets, excluding fuel or energy recovery uses.

    Only recyclate derived from post-consumer waste (PCR) should be recognised for the purpose of meeting the targets, while materials used as fuel or for energy recovery should not be counted.

  • Equivalent requirements including audits, traceability, and pre-import controls must be applied to materials from third countries.

    Equivalent requirements must be applied to materials originating in the EU and in third countries, including audits, traceability and pre-import controls.

• ANFACO-CYTMA Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • The methodology should specifically accommodate food contact packaging and ensure an adequate supply of food-grade recycled materials.

    That methodology should take particular account of the specificities of food contact packaging, where food safety requirements significantly limit the options available for incorporating recycled material.

    machine translation by the Commission, original in ES
  • Traceability and documentation rules should be proportionate to risk and position in the supply chain to avoid duplication.

    Traceability and documentation requirements are proportionate to the risk and position of each operator in the chain.

    machine translation by the Commission, original in ES
  • Administrative burdens should be minimised for food sector operators, especially SMEs.

    Minimise administrative burdens for food businesses, especially SMEs.

    machine translation by the Commission, original in ES
• EuroCommerce Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The framework should be based on robust, auditable chain-of-custody systems and draw on recognized benchmarks like ISEAL without restricting equivalent approaches.

    To provide businesses with sufficient flexibility, the framework should be based on the use of robust and auditable chain-of-custody systems capable of ensuring the traceability of the relevant material and substantiating the claimed recycled content.

  • Independent third-party certification should not be mandated as the sole acceptable verification mechanism.

    Furthermore, the framework should not prescribe independent third-party certification as the only acceptable means of verification.

• FEDIAF EuropeanPetFood Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Permit fuel-use-exempt mass-balance allocation instead of a weight-content calculation.

    permit fuel-use-exempt mass-balance allocation rather than a weight-content calculation

  • Set the compliance boundary at the packaging type and format level as an annual average rather than per component or production line.

    set the compliance boundary at the level of packaging type and format, as an annual average, not per component or production line

  • Rely on existing certified chain-of-custody schemes instead of introducing a duplicate verification layer.

    rely on existing certified chain-of-custody schemes rather than a duplicate verification layer

• Detergents Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Clarify the definition of plastic part and allow calculation based on aggregate PCR weight across qualifying parts.

    Clarify the definition of plastic part and allow recycled content to be calculated based on the aggregate weight of PCR incorporated across qualifying plastic parts, rather than requiring each component to meet the target separately;

  • Establish a simplified methodology permitting annual aggregation at manufacturer level across packaging portfolios.

    Establish a simplified calculation and verification methodology that would allow an annual aggregation at manufacturer level across the relevant packaging portfolio prioritising components and formats where its use is technically feasible and safe;

  • Recognise a mass balance accounting approach based on technology neutrality, fuel-use-excluded allocation, and existing documentation.

    Recognise a transparent and auditable mass balance accounting approach based on technology neutrality, fuel-use-excluded allocation, proportionate verification and the reuse of existing documentation and chain-of-custody systems;

• On behalf of an anonymous client Company, GBR model reads as: wants changes source
  • The Commission should recognise additional supply chain stewardship and chain-of-custody schemes that presume conformity with chemical regulations.

    We would urge the Commission to support the development of additional recognised supply chain stewardship and chain-of-custody schemes for recycled plastics, including agreed testing frequencies, traceability requirements, provenance controls, and risk management measures.

  • The Commission should establish a harmonised EU-wide Quality Management System and technical guidance defining mass balance methodologies for all plastics.

    We ask the Commission to develop a harmonised EU-wide Quality Management System (QMS) and technical guidance defining acceptable mass balance methodologies, verification requirements, and accounting rules to ensure consistent implementation across all Member States.

  • A flexibility mechanism should allow operators to offset recycled content shortfalls in specific components across the finished packaging unit.

    We ask the Commission to introduce a practical flexibility mechanism allowing economic operators that are unable to achieve mandated recycled content levels in a specific packaging component to offset the shortfall through higher recycled content use elsewhere within the finished packaging unit, provided overall PCR levels within the packaging unit are maintained.

• Rethink Plastic Alliance NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The EU should reject credit mass balance systems, prioritise segregation and controlled blending, and restrict mass balance strictly to site-level rolling averages.

    This means prioritising segregation and controlled blending models, and allowing only rolling average mass balance at site level.

  • Full system boundaries must be established from the waste stage through to the recyclate stage.

    System boundaries should be fully accounted for, starting from the plastic waste stage down to plastic recyclate to capture all pre- and post- treatment steps.

  • Full disclosure of hazardous substances should be mandated across the supply chain in line with the precautionary principle.

    the precautionary principle requires full disclosure of hazardous substances throughout the supply chain to prevent unsafe materials from being certified as recycled content and avoid contamination.

• Systemiq Ltd Other, GBR; register: Companies & groups model reads as: wants changes source
  • Base the PPWR implementing act on the SUPD Implementing Decision with three targeted amendments to support chemical recycling.

    Our position is that the PPWR implementing act should be based directly on the SUPD Implementing Decision, with three targeted amendments to support a sustainable and competitive chemical recycling system in Europe, outlined below.

  • Subject recyclate generated outside the EU to equivalent measures and base certification on recognized schemes.

    Additionally, recyclate generated outside the EU should be subject to measures equivalent to those in Article 7(8), and recycled content certification should be based on EU recognized certification schemes and be consistent with chain-of-custody systems already in operation, such as ISCC PLUS, which work at facility level.

  • Ensure recycled plastics are identifiable at customs, traceable throughout the value chain, and independently certified.

    More broadly, the recycled plastics should be identifiable at customs, remain traceable throughout the value chain, certified and audited by independent EU-accredited third-party certification body.

• Neste Company, BEL model reads as: wants changes source
  • Prioritize the competitive scale-up of chemical recycling assets in the EU in the mass balance decision.

    The mass balance (MB) decision for recycled content under the Packaging and Packaging Waste Regulation (PPWR) must prioritize the competitive scale-up of chemical recycling assets in the EU to avoid heavy reliance on imports to supply recycled content targets.

  • Adopt a mass balance accounting method that allows existing infrastructure to contribute toward recycled content targets for contact-sensitive packaging.

    However, the viability of further investment and the ramp-up of Nestes project hinges on a MB accounting method for recycled content allowing existing infrastructure to contribute towards PPWR recycled content targets for contact-sensitive packaging.

  • Implement a mass balance approach deducting losses based on real yields and certified sales to material uses.

    To change this, the PPWR should implement a MB approach with losses deducted based on real-yields and certified sales to material uses at each step of the value-chain in full alignment with the EU definition of recycling.

• OMV AG Business association, AUT; register: Companies & groups model reads as: wants changes source
  • Adopt a methodology linking recycled-content credits to the verified mass of material used in non-fuel applications.

    OMV therefore supports a methodology that emphasizes a robust, auditable mass-balance approach for content allocation and links recycled-content credits to the verified mass of material used in non-fuel applications.

  • Ensure the regulatory framework enables and supports the utilization of European integrated production units.

    For chemical recycling to have a chance to develop successfully in Europe, the regulatory framework must enable and support the utilization of European production sites (existing integrated units like distillation and hydrotreating) in an increasingly competitive and challenging global market.

  • Take into account that olefinic or aromatic cracker co-products can be used as chemical building blocks.

    Furthermore, it should take into account that olefinic or aromatic Cracker Co-products can be used as chemicals building blocks.

• ANFAC Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Clarify the calculation unit and aggregation level for recycled content, especially for packaging made of multiple plastic components.

    In this context, it is considered important that the future methodology clarifies the unit on which the calculation of recycled content should be made, including cases of packaging composed of several plastic components.

    machine translation by the Commission, original in ES
  • Clearly define the required documentation, origin evidence, and supply-chain traceability information for post-consumer recycled plastic.

    It is also essential to clearly define the documentation needed to prove the percentage of recycled content and its origin of post-consumer plastic waste.

    machine translation by the Commission, original in ES
  • Define the time or production basis for assessing compliance and clarify transitional treatment for previously manufactured materials.

    Another relevant aspect is the definition of the time or production basis to be used for the calculation and verification of recycled content.

    machine translation by the Commission, original in ES
• German Environment Agency Public authority, DEU model reads as: wants changes source
  • Allow an accumulation phase in 2028 and 2029 so that recycled plastics used then count toward 2030 targets.

    Therefore the implementing act pursuant to Article 7(8) PPWR should allow for an accumulation phase for recyclate use in the years 2028 and 2029.

  • Ensure mandatory reporting of post-consumer recycled content data under the Article 44(14) implementing regulation to enable eco-modulation.

    We therefore ask the commission to ensure the reporting of this data in the implementing regulation according to Art. 44 (14) PPWR.

• LyondellBasell (LYB) Company, NLD; register: Companies & groups model reads as: wants changes source
  • Base the implementing act on the Single-Use Plastics Directive Decision with targeted amendments for gas and solid chemical recycling streams.

    Our position is that the PPWR implementing act should be based directly on the SUPD Implementing Decision, with three targeted amendments to support a sustainable and competitive chemical recycling system in Europe, outlined below.

  • Allow restricted credit transfers between facilities owned by the same company covering the same product in the same or contiguous countries.

    Third, including a restricted credit transfer only between facilities owned by the same company and covering the same product and the same or contiguous countries.

  • Subject non-EU recyclate to equivalent rules and rely on facility-level certification schemes and customs traceability.

    Additionally, recyclate generated outside the EU should be subject to measures equivalent to those in Article 7(8), and recycled content certification should be based on EU recognized certification schemes and be consistent with chain-of-custody systems already in operation, such as ISCC PLUS, which work at facility level.

• The Polish Union of the Cosmetics Industry Business association, POL; register: Trade and business associations model reads as: wants changes source
  • Apply recycled-content obligations at the company portfolio level rather than per individual component and format.

    We therefore call for the recycled-content requirements to apply at company portfolio level, rather than separately to each individual plastic packaging part and format.

  • Enable the use of chemical recycling by building on the Single-Use Plastics Directive framework.

    The methodology should also enable the effective use of chemical recycling, building on the approach already recognised under the Single-Use Plastics Directive.

  • Keep verification requirements proportionate to avoid repeated third-party certification across the value chain.

    Verification requirements should remain proportionate and avoid repeated third-party certification of the same information throughout the value chain, particularly where this would create disproportionate costs for SMEs.

• ExxonMobil Company, BEL; register: Companies & groups model reads as: wants changes source
  • Secondary legislation should explicitly recognize and support pyrolysis as a critical complementary recycling technology.

    To deliver the PPWR's objectives at scale, the secondary legislation should explicitly recognize and support pyrolysis as a critical complementary recycling technology, enabling difficult-to-recycle polyolefin waste to be converted into feedstocks that make new products.

  • The Commission should clarify the Waste Framework Directive for co-processing technologies and adopt mass balance rules that reflect integrated industrial operations.

    The Commission should clarify the interpretation of the Waste Framework Directive for technologies where waste is co-processed with virgin feed and both fuel and materials are produced. It should adopt mass balance rules for recycled content that reflect integrated industrial operations, reward the volume of plastic waste chemically recycled into raw materials to make new products, and provide investment certainty.

  • Secondary legislation should establish a framework that supports investment and affordability rather than restricting global supply chains.

    The secondary legislation should prioritize the creation of a framework supporting investment and affordability instead of creating barriers to global supply chains and creating complexity that disproportionally impacts small and medium-sized enterprises (SMEs).

• Valgroup Company, BRA model reads as: wants changes source
  • Base sustainability and calculation rules on technological neutrality and verifiable life-cycle performance rather than closed technology lists.

    technological neutrality anchored in verifiable performance through life-cycle analysis rather than closed lists of technologies

    machine translation by the Commission, original in PT
  • Permit aggregation at the audited perimeter level rather than per installation, and extend the balance sheet period beyond a quarter.

    Aggregation at the audited perimeter level (not per installation) is recommended, including petrochemical co-processing; the balance sheet period longer than the quarter, while maintaining the prohibition of negative balances

    machine translation by the Commission, original in PT
  • Establish an operator-level equivalence pathway accepting third-party schemes like ISCC PLUS instead of conditioning recognition on geographic agreements.

    A measurement path is recommended at operator level, with acceptance of the ISCC PLUS test, accredited bodies in Latin America, avoidance of duplication of audits and proportionality in frequency

    machine translation by the Commission, original in PT
• VNO-NCW / VTCR Business association, NLD model reads as: wants changes source
  • Adopt the Implementing Act promptly to ensure regulatory certainty for 2030 targets.

    Adopt the Implementing Act without delay!

  • Include solid recycled feedstocks and intermediates within the methodology subject to verified non-fuel use.

    The PPWR methodology should include solid recycled feedstocks and intermediates. Their eligibility should depend on demonstrated and verified non-fuel use.

  • Permit controlled transfers of mass balance credits between production sites.

    Controlled transfers should be possible within an auditable mass balance system, reflecting the operation of integrated European value chains.

• USA Pulses Business association, USA model reads as: wants changes source
  • Provide calculation rules and worked examples for bags, liners, bulk packaging, wrapping, and straps.

    Publish clear calculation rules and worked examples for food-contact bags, liners, flexible bulk packaging, wrapping and straps, including multi-component packaging.

  • Create a standard supplier evidence format covering calculation, origin, traceability, and verification.

    Establish a standard supplier evidence format covering recycled-content calculation, post-consumer origin, traceability and verification status.

  • Allow downstream operators to rely on verified upstream evidence instead of repeated customer audits.

    Allow downstream operators to rely on verifiable upstream evidence, subject to due diligence, rather than requiring repeated audits for each customer or shipment.

• Federation of Food and Drink Industries of the Czech Republic Business association, CZE; register: Trade unions and professional associations model reads as: wants changes source
  • Provide clear definitions for packaging units and parts, assessing recycled-content targets at the packaging level.

    The practical application will depend on the exact definitions of the terms packaging, packaging unit and plastic part. These should therefore be clearly defined in the implementing act to ensure a consistent EU approach. Currently, our sector is subject to targets under Single-use Plastics Directive. In the interest of legislation consistency, the focus should be on achieving the applicable target at packaging level.

  • Clarify that closure targets either apply to the entire packaging or follow specific polymer targets rather than separate bottle targets.

    Should it be required that caps must reach the recycled content target separately, this obligation should not follow Art. 7.1(c), as given the current state of EFSA approval, technology, and available material, compliance with the target would be impossible. Instead, caps should be either considered a part of the whole packaging, or it should follow the target in Art. 7.1(b).

  • Clarify how compliance responsibility across different packaging types is assigned across plants.

    However, to date, there remains lack of clarity as to how responsibility for compliance with this target is allocated across, sales, grouped and transport packaging.

• Centexbel-VKC Academic or research institution, BEL model reads as: wants changes source
  • Base the calculation of recycled content on EN 15343 and ISO 22095 standards.

    The calculation of the recycled content should be based on the EN 15343 standard which clearly states the way to calculate the recycled content with a distinction between PCR and PIR and the ISO 22095 standard ensures the complete chain of custody.

  • Allow companies with an ISO 9001 certified system to obtain QA-CER certification without extra administrative burden.

    Any company having an certified ISO 9001 quality system should be able to get this certification without any additional administrative burden.

• Karl Lagerfeld Company, NLD model reads as: wants changes source
  • Base the calculation and verification methodology on the ISO 14021 standard.

    Methodology for calculating and verifying recycled content should be based on ISO 14021.

• FEDIMA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Avoid unnecessary duplication and administrative burden in documentation, traceability, and verification requirements.

    Requirements on documentation, traceability, verification and audits should avoid unnecessary duplication and administrative burden, particularly in complex or cross-border supply chains.

  • Clarify the accounting point for recycled content, conditions for mass balance models, and chain of custody rules.

    FEDIMA considers that the Commission should clarify the point in the value chain at which recycled content is to be accounted for, the conditions for the use of mass balance models, and the minimum chain of custody requirements.

  • Keep verification and reporting practical and proportionate, taking food-contact compliance into account.

    Verification and reporting requirements should therefore be practical and proportionate, particularly where operators depend on documentation provided by packaging suppliers.

66 more analysed submissions on the consultation page.