Conditions for importing recycled materials into the EU for use in packaging

130 submissions in the snapshot (122 from organisations), portal total 130. Feedback list on the portal.

122 of 122 organisation submissions analysed; the model reads them as: opposes 2 supports 8 wants changes 83 29 held back for review (low confidence).

• Rubies Masquerade Co. (UK) Ltd / Rubies NL Company, GBR model reads as: wants changes source
  • The methodology should recognize existing certification and chain-of-custody schemes.

    The methodology should recognise established certification and chain-of-custody schemes

  • The rules should permit evidence at the family, batch, or supplier level where appropriate.

    permit family/batch/supplier-level evidence where appropriate

  • The methodology should avoid requiring multiple brand owners to independently audit the same recycler.

    avoid requiring each brand owner independently to audit the same recycler.

• Asociace českého tradičnního obchodu Business association, CZE; register: Trade unions and professional associations model reads as: wants changes source
  • Mandatory periodic on-the-spot inspections by accredited certification bodies should replace self-declarations for third-country sites.

    Physical on-the-spot audits: Mandatory periodic inspections of third country production sites by accredited certification bodies (ISO/IEC 17020/17065); replacement of self-declarations by physical verification.

    machine translation by the Commission, original in CS
  • European secondary raw material producers must not face significantly stricter requirements than third-country competitors.

    Equivalence of standards: It is necessary to ensure a legislative set-up in such a way that European producers of secondary raw materials are not subject to significantly stricter criteria than producers from third countries.

    machine translation by the Commission, original in CS
  • The EU should analyse third-country waste quality criteria thoroughly before finalizing European requirements.

    Therefore, it is appropriate to first analyse in detail the quality criteria for waste from third countries and to design the requirements for the European area judiciously in relation to secondary raw materials produced and traded outside the EU on the global market.

    machine translation by the Commission, original in CS
• Micro company, NLD Company, NLD model reads as: wants changes source
  • Equivalence assessments should be defined at the level of the partner country's entire waste and recycling system.

    Define equivalence assessment at the level of a trading partner's whole waste and recycling system, not individual certified sites or plants.

  • Only plastic waste sorted, collected, and recycled within the EU27, EFTA, and UK should count toward recycled-content targets.

    Confirm that only plastic waste sorted, collected and recycled within the EU27, EFTA and the United Kingdom counts towards mandatory recycled-content targets for packaging produced or filled in Europe.

  • Third-country equivalence must require independently audited chain-of-custody traceability with importer compliance risk.

    Require that any future recognition of third-country equivalence be paired with independently audited chain-of-custody traceability, with the economic operator placing the product on the EU market responsible for verifying that traceability and bearing the compliance risk, with documentation and EU audit access comparable to EU standards.

• Micro company, DNK Company, DNK model reads as: opposes source
  • Micro-enterprises should be subject to substantially simpler rules than large corporations.

    1. Micro-enterprises should have significantly simpler rules than large enterprises

    machine translation by the Commission, original in DA
  • The reuse of clean and functional packaging should be facilitated rather than restricted.

    2. Reuse of clean and functional packaging should be made easier and not more difficult.

    machine translation by the Commission, original in DA
  • Clear de minimis thresholds and exemptions must be introduced for businesses handling minimal packaging volumes.

    4. There should be clear de minimis thresholds and exemptions for companies with very limited quantities of packaging.

    machine translation by the Commission, original in DA
• Chemical Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The equivalence framework should be assessed at system level, prioritize European material, and enforce traceability.

    The approach set out in this position (equivalence assessed at system level, European material first, and enforceable traceability throughout) offers a credible path forward that safeguards the integrity of the EU's recycled-content targets and the investment case for European recycling infrastructure, while leaving the door open, on the right terms, to the future recognition of genuinely equivalent systems elsewhere.

• Procter & Gamble Company, BEL; register: Companies & groups model reads as: wants changes source
  • Make the Implementing Act fundamentally permissive towards international trade in post-consumer recyclate and consider blanket recognition of equivalence for suitable third countries.

    As a consequence, the Implementing Act should strive to be fundamentally permissive in nature, rather than a construct that effectively prohibits international trade in post-consumer recyclate.

  • Avoid disproportionate traceability and documentation requirements that could create de facto barriers to trade.

    The mirror clauses should not create disproportionate traceability or documentary requirements that might conflict with WTO rules by creating de facto barriers to trade that cannot be effectively addressed by due diligence.

  • Permit the certification of non-EU recycled materials under established EU accredited schemes.

    Non-EU recycled material should be able to be certified according to established and trusted EU accredited systems (i.e., Recyclass, PolyCert Europe, ISCC+, GRS etc.).

• Micro company, NLD Company, NLD model reads as: wants changes source
  • Keep the responsibility for maintaining packaging data with manufacturers and brand owners rather than individual importers.

    We believe the responsibility for creating, maintaining and verifying packaging information should primarily remain with the manufacturer or brand owner that actually controls the packaging, rather than with each individual importer.

  • Establish a centralised system for sharing packaging information across the supply chain.

    There should be a simple and centralised system whereby the manufacturer provides the required packaging information once and wholesalers and importers can rely on or access that information throughout the supply chain.

  • Refrain from imposing obligations on SME importers that are outside their practical ability to fulfill.

    We strongly ask the Commission to consider the reality of these indirect supply chains and ensure that PPWR does not place obligations on SME importers that they have no practical ability to fulfil.

• Japan Cosmetic Industry Association Business association, JPN model reads as: wants changes source
  • Allow third-country recycled materials to count toward targets based on objective equivalence of outcomes rather than country of origin alone.

    Equivalence should be assessed based on objective and verifiable conditions and outcomes at the relevant stages of collection, sorting and recycling, rather than on the country or region of origin alone.

  • Accept recognised third-party certifications and chain of custody systems as proof of compliance.

    Where equivalent assurance can be demonstrated, internationally recognised third-party certification, accredited audits and Chain of Custody systems should be accepted as evidence of compliance.

  • Prevent unnecessary duplication of audits and documentation across multi-country supply chains and provide adequate transition time.

    Unnecessary duplication of certification, audits and documentation should be avoided, and sufficient transition time should be provided.

• Japan Electronics and Information Technology Industries Association （JEITA） Business association, JPN model reads as: wants changes source
  • Assess equivalence based on substantive environmental protection rather than demanding identical administrative and regulatory systems.

    First, equivalence for recycled materials originating from third countries should be assessed on the basis of an equivalent level of protection of the environment and human health, rather than requiring identical regulatory systems or full alignment with EU legislation, permitting systems or administrative procedures.

  • Utilise existing international standards and certifications through a gap-based verification approach.

    JEITA therefore recommends a gap-based approach: use existing evidence first and verify only requirements not already adequately covered.

  • Prevent duplicative audits by permitting downstream operators to rely on verified results from upstream tiers.

    Where the equivalence of a recycling facility or recycled material has already been adequately verified at an appropriate upstream stage, downstream operators should be allowed to rely on that result.

• Micro company, ESP Company, ESP model reads as: wants changes source
  • Mandate sampling and laboratory analysis of recycled content for all imported plastics at customs entries.

    establish the need for sampling and analysis of recycled content for all imported plastics, setting a minimum percentage of sampling on customs entries.

    machine translation by the Commission, original in ES
  • Broaden the definition of recycled material to encompass pre-consumer industrial waste.

    Furthermore, we would like you to consider extending the concept of recycled material to include pre-consumer material.

    machine translation by the Commission, original in ES
• Česká asociace odpadového hospodářství Business association, CZE model reads as: wants changes source
  • Replace self-declarations with mandatory periodic physical inspections of third-country production facilities by accredited bodies.

    Mandatory periodic inspections of third country production sites by accredited certification bodies (ISO/IEC 17020/17065); replacement of self-declarations by physical verification.

    machine translation by the Commission, original in CS
  • Ensure European secondary raw material producers do not face stricter requirements than competitors from third countries.

    It is necessary to ensure a legislative set-up in such a way that European producers of secondary raw materials are not subject to significantly stricter criteria than producers from third countries.

    machine translation by the Commission, original in CS
  • Balance European criteria against global standards to maintain competitiveness and prevent circumvention.

    Therefore, the best possible way to compare and balance EU criteria with those of other continents seems appropriate, in order not to undermine the economic competitiveness of European secondary materials on the global market and to reduce incentives to circumvent European standards when imported into the EU.

    machine translation by the Commission, original in CS
• Micro company, GBR Business association, GBR model reads as: wants changes source
  • Ensure that UK recycled material can contribute to PPWR recycled content targets from 2030 onwards without a delayed transition period.

    It is therefore imperative that UK material can contribute to the recycled content targets under the PPWR from 2030 onwards. Replicating the SUPD transition period with a delayed inclusion would be extremely damaging, creating an artificial trade barrier that does not improve environmental integrity, but instead starves the EU market of high-quality, compliant feedstock.

  • Provide early clarity on site-based certification requirements under the mirror clause.

    However, we request that clarity on any site-based certification requirements is provided as early as possible so that operators can be compliant from day one.

  • Align certification requirements pragmatically with existing schemes.

    Where possible, it would be useful if the requirements to be pragmatic and align with existing certification schemes.

• Clean Planet Energy Company, GBR model reads as: wants changes source
  • Provide a prompt recognition route for the UK based on outcome-oriented criteria rather than identical legislation.

    Equivalence should, however, be assessed by outcomes and verifiable controls rather than word-for-word identity with EU legislation.

  • Permit physical movement of pyrolysis oil and intermediates from certified UK facilities to EU facilities with material-attached attribution.

    Permit physical movement of PPO and later intermediates from a certified UK facility to EU facilities where the recycled attribution remains attached to the material through batch declarations and verified conversion factors.

  • Provide transitional recognition during pending formal country assessments.

    Include transitional recognition so that compliant supply chains are not interrupted while formal country assessments are pending.

• PHOENIX group Company, DEU; register: Companies & groups model reads as: wants changes source
  • Clearly define responsibilities across the supply chain so companies are only accountable for data and activities under their control.

    Responsibilities should be clearly defined across recyclers, converters, packaging suppliers, producers, importers, and private label owners. Companies should only be accountable for data and activities under their control, while maintaining appropriate due diligence obligations.

  • Recognise existing independent certification and verification schemes as proof of compliance.

    Existing independent certification and verification schemes should be accepted as evidence of compliance to avoid duplicate audits, reduce administrative burden, and ensure consistency across the supply chain.

  • Ensure downstream actors do not bear disproportionate liability when reasonable due diligence has been conducted.

    Where reasonable due diligence has been conducted, downstream actors should not bear disproportionate liability for inaccuracies originating upstream.

• Bioeksen AR GE Teknolojileri A.Ş Company, TUR model reads as: wants changes source
  • Clarify that equivalence applies to the recyclate itself rather than the importer of the packaged product.

    Clarify that equivalence attaches to the recyclate, not to the importer of the packaged product.

  • Assess equivalence at the facility level via accredited third-party certification.

    Assess equivalence at facility level through accredited third-party certification.

  • Use the same benchmark for third-country recyclate as applied to EU facilities.

    Use the same benchmark as for EU recyclate.

• Veolia Company, BEL; register: Companies & groups model reads as: wants changes source
  • Count only European recyclates toward targets for packaging produced or filled in the EU.

    For packaging produced or filled in the EU, only European (EU, EFTA,UK) recyclates shall count toward the recycled content targets.

  • Apply strict mirror clauses requiring independent EU-accredited certification and chain-of-custody tracking for third-country imports.

    If imports from third countries are permitted to contribute to EU mandates, the "mirror clause" principle must be applied rigorously.

  • Apply the technology hierarchy to imported materials by prioritizing mechanical recycling and excluding high-emission processes.

    Imported materials must follow the EU technology hierarchy, prioritizing low-emission, high-efficiency mechanical recycling.

• 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 implementing acts on a dual legal basis of Article 114 and Article 191 of the TFEU, alongside a renewed impact assessment.

    should consider a dual legal basis of the TFEU: internal market within the meaning of Article 114 and also environment within the meaning of Article. 191. Moreover, it should also reconsider an impact assessment on the EU market, since almost ten years have passed since the data used for the preparatory work for the PPWR, which, moreover, has been significantly amended since the Commission’s proposal, including by reducing the abovementioned equivalence requirements between the EU and non-EU markets.

    machine translation by the Commission, original in IT
  • Extend certification schemes upstream to cover the separate collection phase in third countries.

    Since the PPWR states that only material recovered from post-consumer plastic waste is eligible for recycled content obligations and that specifically for non-EU materials equivalence also covers the collection phase, certification schemes should also extend upstream, towards separate collection, to verify compliance with the same European conditions for collection and treatment activities aimed at quality recycling.

    machine translation by the Commission, original in IT
  • Harmonise equivalence audit criteria with the environmentally sound management standards of the Waste Shipment Regulation.

    In this regard, there is a direct and binding link with the new Waste Shipment Regulation (EU) 2024/1157 (WSR), in particular with the ESM audit standards, to which the audit criteria laid down by the PPWR for the certification of equivalence must be harmonised.

    machine translation by the Commission, original in IT
• Fonterra Ltd Company, NZL model reads as: wants changes source
  • Ensure third-country equivalence pathways are fair, practical, non-discriminatory, and avoid duplicated certification.

    Third-country recyclers, packaging suppliers and exporters must have clear and workable routes for demonstrating equivalence.

  • Assess outcomes rather than the location or label of the recycling process using transparent and technology-neutral criteria.

    Sustainability and equivalence criteria should be transparent, science-based and technology-neutral, and should assess outcomes rather than the location or label of the recycling process.

  • Provide adequate transition periods that begin only after the relevant secondary legislation is complete and sufficiently clear.

    Transition periods should begin only once the relevant implementing and delegated acts are complete and sufficiently clear.

• Baden-Württembergischer Genossenschaftsverband e.V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Reduce bureaucratic burdens and establish regulation based on trust, proportionality, and practical proof mechanisms.

    The BWGV therefore advocates a consistent reduction in bureaucratic burdens and regulation based on trust, proportionality and practical proof and control mechanisms.

    machine translation by the Commission, original in DE
  • Provide practical means of proof, protect legitimate expectations regarding supplier declarations, and significantly lower evidence requirements.

    The BWGV is therefore in favour of practical means of proof, adequate protection of legitimate expectations in the case of reliable supplier’s declarations and a significant reduction in the documentation and evidence requirements.

    machine translation by the Commission, original in DE
  • Avoid enforcing substance restrictions primarily through extensive detection and monitoring obligations for producers.

    Substance restrictions should therefore not primarily be enforced through extensive detection and monitoring obligations for producers.

    machine translation by the Commission, original in DE
• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Require recycled plastics collected and recycled in Europe for packaging produced or filled in the EU.

    Require Made in Europe recyclates for packaging produced or filled in the EU: In that case, compliance with recycled content (RC) targets should rely on recycled plastics originating from post-consumer waste collected & recycled in Europe (EU27+EFTA+UK).

  • Establish robust mirror measures with two-level equivalence at country and facility levels for packaging produced and filled outside the EU.

    Establish robust mirror measures for packaging produced and filled outside the EU: For those packaging placed on the EU market, recycled plastics should only count towards RC targets where compliance with requirements and standards equivalent to those applicable in the EU can be demonstrated, or European recyclates can be used.

  • Establish harmonised verification procedures and ensure effective enforcement, market surveillance, and transparency across the value chain.

    The Implementing Act should establish harmonised verification procedures, while Member States should ensure effective controls on imported packaging and introduce dissuasive harmonised sanctions.

• Micro company, NOR NGO, NOR model reads as: wants changes source
  • Ensure that harmonized registration and reporting are not undermined by additional national requirements.

    Harmonization must not be undermined by additional national requirements.

  • Make data requirements proportionate and grounded in data that is readily available.

    Data requirements must be proportionate and based on data that is readily available.

  • Allow existing product data and Digital Product Passports to be reused to prevent duplicate reporting.

    Existing product data and Digital Product Passports must be reusable to reduce the reporting burden.

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

    Do not require identical national legislation in the third country for equivalence.

  • Recognise accredited international and industry standards and third-party audit without restricting 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.

  • Implement intermediary measures for non-EU recyclate until the EU sets its criteria, including recognition under Regulation (EU) 2022/1616.

    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.

• EDANA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Assess post-consumer recycled content on quality, safety, and functionality rather than volume alone.

    Recycled content availability should not be assessed solely on the basis of volume.

  • Allow maximum flexibility under Article 7 via plant-level averaging and workable interpretations across components.

    The upcoming methodology should make full use of the flexibility already embedded in Article 7, notably through averaging at manufacturing-plant level and a workable interpretation of any plastic part.

  • Maintain technology neutrality to enable mass balance approaches and chemical recycling.

    The framework should remain technology-neutral and enable a complementary portfolio of recycling solutions.

• ANFACO-CYTMA Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Ensure sufficient availability of recycled material suitable for food contact to meet PPWR targets without shortages.

    Ensure sufficient availability of recycled material suitable for food contact.

    machine translation by the Commission, original in ES
  • Base requirements for imported recycled materials on regulatory equivalence and mutual recognition.

    Requirements for imported materials are based on criteria of equivalence and mutual recognition.

    machine translation by the Commission, original in ES
  • Design certification and traceability systems to be robust yet proportionate, taking account of impacts on SMEs.

    Certification and traceability systems are robust but proportionate.

    machine translation by the Commission, original in ES
• Micro company, COD Company, COD model reads as: wants changes source
  • Admit digital event-level provenance as an equivalence pathway alongside third-party audits.

    Admit digital event level provenance as an equivalence pathway, alongside third party audits.

  • Establish minimum requirements for event-level digital evidence including point-of-capture signatures, timestamps, and immutability.

    Set minimum requirements for that evidence: signature at the point of capture, timestamp, immutability once written, verifiability by an independent third party, no publication of personal data.

  • Avoid framing requirements on the assumption that formal municipal waste collection infrastructure is already present.

    Avoid wording that assumes formal municipal waste collection infrastructure already exists.

• Svaz chemického průmyslu ČR Business association, CZE; register: Trade and business associations model reads as: wants changes source
  • Apply a two-stage equivalence assessment evaluating the third country's legal and technical framework before auditing specific recycling facilities.

    We recommend applying a two-stage equivalence assessment under which the legal and technical framework of the third country would first be assessed, followed by verification of the specific recycling facility.

  • Retain mandatory independent third-party verification carried out by accredited bodies and reject self-declarations alone.

    Mandatory independent third-party verification should be retained, with certification renewed periodically and carried out by a competent and accredited body; self-declarations by economic operators alone should not suffice.

  • Recognize existing certification and chain-of-custody schemes as evidence of meeting the implementing act requirements.

    Existing certification and chain-of-custody schemes, such as EN 15343, RecyClass/EuCertPlast, ISCC PLUS or ISO 22095, may be recognised as evidence, provided that they cover the requirements of the implementing act and provide an adequate level of assurance.

• FEDIAF EuropeanPetFood Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Accept recognized international certification schemes for demonstrating equivalence instead of duplicating them with a parallel EU regime.

    We therefore ask that recognised international certification schemes be accepted as the basis for demonstrating equivalence, rather than a parallel EU regime that duplicates them;

  • Place verification obligations on importers and suppliers of recyclate rather than downstream users.

    that verification obligations rest with importers and suppliers of recyclate, not downstream users such as brand owners and fillers;

  • Apply equivalent environmental, health, and recycling standards equally to imported recyclate and imported packaged products.

    and that equivalent environmental, health and recycling standards apply to imported recyclate and imported packaged products alike, to preserve a level playing field.

• Thailand PPWR Consortium - All sectors Business association, THA model reads as: wants changes source
  • Equivalence should be demonstrated at the level of the specific operation rather than requiring entire third-country regulatory systems to be equivalent.

    Importantly, equivalence should be capable of being demonstrated at the level of the relevant operation or activity rather than depending on broad equivalence of an entire third-country regulatory system.

  • Qualifying post-consumer recycled plastic from both EU and non-EU origins should be eligible for joint accounting without unnecessary segregation.

    Qualifying PCR from EU and non-EU sources should be capable of being combined and accounted for together, subject to appropriate traceability, material-accounting and anti-double-counting controls.

  • The Commission should permit the use of existing credible evidence and globally applicable verification arrangements to demonstrate compliance.

    Existing credible evidence should likewise remain usable where it demonstrates the applicable requirements, with supplementary evidence addressing identified gaps rather than repeating the entire assessment.

• Detergents Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should recognise established international certification and chain-of-custody schemes alongside country-level equivalence.

    Recognising established international certification and chain-of-custody schemes, as well as country-level equivalence where appropriate, as credible means of demonstrating compliance with Article 7

  • Equivalence assessments should be based on comparable outcomes rather than demanding replication of EU administrative systems.

    Assessing equivalence based on comparable environmental, health, quality and traceability outcomes, without requiring third countries to replicate EU regulatory or administrative systems;

  • Implementation mechanisms for the mirror clause should minimise administrative and operational burdens and costs.

    Ensuring that implementation mechanisms for the Article 7 mirror clause minimise administrative operational burden and costs, particularly for companies operating in complex supply chains.

• Extrupet Pty ltd Company, ZAF model reads as: wants changes source
  • The EU should recognise equivalent systems of control and verification for recycled plastic produced outside the EU even without identical legislation.

    For recycled plastic produced outside the EU, we recommend that the EU recognise equivalent systems of control and verification, even where the third country does not have the same legislation as the EU.

  • The verification system should remain risk-based and practical, especially for established technologies like food-grade rPET.

    The system should be risk-based and practical, particularly for established recycling technologies such as food-grade rPET.

  • Recyclers outside the EU should be allowed to demonstrate equivalence through combining national rules, international standards, certification, testing, and third-party audits.

    We recommend that the EC allow recyclers outside EU to demonstrate equivalence through a combination of national requirements, international standards, certification, laboratory testing and independent third-party verification.

• The Association of European Self-Care Industry (AESGP) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Implementing measures must strictly adhere to the exemptions established for medicinal products and specific medical devices.

    The Commission should ensure that the implementing measures fully respect the exemptions established by the co-legislators for medicinal products and certain medical device packaging under Art. 7 of the PPWR.

  • New implementing rules should ensure legal certainty and avoid creating indirect disadvantages or excessive administrative burdens for exempt packaging.

    Considering the highly regulated nature of healthcare products, it is important that these new rules provide legal certainty, avoid disproportionate administrative burdens to companies, and do not create indirect disadvantages for exempt packaging through documentation requirements, compliance systems or economic instruments.

  • The Commission must preserve the availability of suitable recycled plastics for non-exempt packaging applications.

    It is also essential to maintain the availability of suitable recycled plastics for packaging applications that remain within the scope of the recycled-content requirements, including secondary, grouped and transport packaging, as well as food supplements and other consumer healthcare products that do not benefit from Article 7 exemptions.

• Micro company, FRA Business association, FRA model reads as: wants changes source
  • The Commission should evaluate the availability of suitable recycled materials for sensitive packaging across the EU before 2030.

    We call on the European Commission to assess, at EU level, the current and foreseeable availability before 2030 of recycled materials suitable for sensitive packaging, in particular food packaging.

    machine translation by the Commission, original in FR
  • Temporary and targeted revisions should be introduced if capacity falls short or health safety remains uncertain.

    In the event of insufficient capacity or health uncertainty, Elipso recommends temporary, targeted and regularly reassessed revisions.

    machine translation by the Commission, original in FR
  • Traceability and certification schemes covering the entire value chain must be robust, clear, and operationally realistic.

    ELIPSO also calls for robust and clear traceability and certification systems, covering the entire value chain, system-wide, applicable to mechanical and chemical recycling, while remaining on realistic and proportionate operational implementation arrangements for businesses.

    machine translation by the Commission, original in FR
• On behalf of an anonymous client Company, GBR model reads as: wants changes source
  • The submitter requests expanding recognition to include recycled plastics from countries subject to the OECD Decision and third countries with equivalent standards.

    We ask the Commission to expand recognition to include recycled plastics sourced from countries subject to the OECD Decision on the Control of Transboundary Movements of Wastes Destined for Recovery Operations and other third party countries that can demonstrate equivalent environmental, traceability, and compliance standards.

• FEAD - European Waste Management Association Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The submitter requests a Made in Europe preference requiring European recycled plastics for packaging produced or filled in the EU.

    1. Require Made in Europe recyclates for packaging produced or filled in the EU: In that case, compliance with RC targets should rely on recycled plastics originating from post-consumer waste collected & recycled in Europe (EU27+EFTA+UK).

  • The submitter requests robust mirror measures establishing country-level and facility-level equivalence for packaging produced and filled outside the EU.

    2. Establish robust mirror measures for packaging produced and filled outside the EU: For those packaging placed on the EU market, recycled plastics should only count towards RC targets where compliance with requirements and standards equivalent to those applicable in the EU can be demonstrated, or European recyclates can be used.

  • The submitter requests effective enforcement, market surveillance, harmonised verification procedures, and transparency throughout the value chain.

    3. Ensure effective enforcement, market surveillance and transparency throughout the value chain: The mirror clause will only be effective if accompanied by robust enforcement.

• Cefic Business association, BEL model reads as: wants changes source
  • The submitter urges applying a common set of outcome-based equivalence requirements to all recycled content placed on the Union market across all relevant entry points.

    Apply a common set of outcome-based equivalence requirements to all recycled content placed on the Union market.

  • The submitter asks the Commission to build upon the verification architecture established under the Single-Use Plastics Directive.

    Build on the verification architecture established by Commission Implementing Act (EU) 2026/1425 under the Single-Use Plastics Directive (SUPD), including batch declarations, facility-level verification, competent and independent verifiers, standardised certificates, certificate pass-through and recognition across Member States.

  • The submitter recommends establishing harmonised EU requirements for certification schemes and utilizing certificate-linked declarations for customs controls.

    Establish harmonised EU requirements for the recognition and supervision of certification schemes and certification bodies, building where appropriate on existing EU approaches, accreditation arrangements and harmonised standards.

• Octal SAOC, Alpek Polyester Company, OMN model reads as: wants changes source
  • The submitter urges that eligibility of recycled content should be based on demonstrated equivalence and performance rather than geographical origin.

    Eligibility of recycled content should not depend exclusively on the country where waste was collected or recycled.

  • The submitter asks the Commission to leverage existing international certification, chain-of-custody, and audit systems.

    OCTAL supports independent third-party verification and recommends that the Commission leverage established international certification, chain-of-custody and audit systems where they can demonstrate the specific PPWR requirements.

• Micro company, DEU Company, DEU model reads as: wants changes source
  • The submitter requests establishing equivalence strictly at the installation level rather than imposing a country-level condition.

    Our request: equivalence under Article 7(10) established at installation level by accredited third-party audit on the model of Regulation (EU) 2026/1738, with a five-year cycle shortened on risk, mutual recognition between the regimes, and no additional country-level condition.

  • The submitter asks for strict chain-of-custody rules requiring physical segregation and identity preservation rather than credit-based mass balance.

    Eligibility for third-country volumes should require physical segregation with identity preserved to the consignment sealed at the audited installation, independently weighed, analysed per lot with no credit-based mass balance.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Focus the implementing act on clarifying calculation and verification without imposing requirements beyond Article 7.

    The implementing act should focus on clarifying how recycled content is calculated and verified, without adding requirements beyond those already set out in Article 7.

  • Recognise existing national and international standards to avoid certification divergence.

    The PPWR should recognise relevant existing national and international standards to avoid creating divergence between certification schemes across countries.

  • Follow the precedent of existing measures such as traceability rules under the Single-use Plastics Directive.

    As a rule, the Implementing Act should follow the precedent of existing measures, such as the traceability requirements for the new technologies under Single-use Plastics Directive.

• European Plastics Circularity (EPC) Coalition Business association, BEL; register: Companies & groups model reads as: wants changes source
  • Assess equivalence at the whole country level rather than only at the installation level.

    Assess equivalence at country level, not only at installation level.

  • Permit only recycled content from the EU, EFTA, and UK until system-level equivalence is enforced, subject to shortage safeguards.

    Until system-level equivalence is operational and enforced, only recycled content genuinely produced in the EU, EFTA and the UK should count towards the targets, with a built-in safeguard for proven shortages.

  • Establish deterrent enforcement through real assessments, audits, and harmonised penalties.

    Make it enforceable, through real assessments, audits and penalties, harmonised as far as possible and deterrent enough that non-compliance costs more than compliance.

• Rethink Plastic Alliance NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Align the recycling definition strictly with EU rules by excluding fuel and ensuring imported recyclates meet identical criteria.

    The EU implementing act for assessing, verifying and certifying equivalence should strictly align the definition of recycling with EU legislation by excluding fuel, and ensuring imported post-consumer recycled plastic meets identical recycling, environmental, and non-fuel processing criteria.

  • Base equivalent rules on plant-level mass balance and equitable credit allocation per economic area.

    The equivalent rules should also be based on plant-level mass balance at the level of the manufacturing plant and credit allocation equitably distributed per economic area to ensure a level-playing field between operators, especially European SMEs.

  • Incorporate waste management safeguards from the EU Waste Shipment Regulation into the methodology.

    Last but not least, the methodology should incorporate the waste management safeguards from the EU Waste Shipment Regulation to ensure coherence among EU legislation.

• TOMRA Systems ASA Company, NOR; register: Companies & groups model reads as: wants changes source
  • Count non-European recycled plastics only when produced under equivalent standards across collection, sorting, recycling, traceability, and enforcement.

    Recycled plastics from outside Europe should count toward EU targets only when produced under equivalent standards for collection, sorting, recycling, traceability and enforcement.

  • Adopt practical safeguards including system-level equivalence, interim rules, shortage safeguards, and robust audits.

    TOMRA therefore supports the EPCCs call for practical safeguards: system-level equivalence assessments; clear interim rules until equivalence is enforceable; appropriate shortage safeguards; and robust audits and penalties to prevent non-compliant materials from undercutting responsible investment.

• Versalis, Eni Group Company, ITA; register: Companies & groups model reads as: wants changes source
  • Establish a robust, predictable, and enforceable equivalence framework with strong mirror clauses.

    Strong mirror clauses are essential to ensure a level playing field, safeguard the integrity of the EU regulatory framework and guarantee that imported recycled plastics counted towards PPWR targets comply with standards equivalent to those applicable within the Union.

  • Establish a transparent and reliable system for assessing, verifying, and certifying equivalence across the entire plastics recycling value chain.

    Building on these precedents, the implementing act should establish a transparent and reliable system for assessing, verifying and certifying equivalence across the entire plastics recycling value chain encompassing both third countries and non-EU operators.

• Reloop NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Assess equivalence at the country level rather than only at the installation level.

    Assess equivalence at country level, not only at installation level.

  • Count only EU, EFTA, and UK recycled content towards targets until system-level equivalence is enforced, subject to a safeguard for proven shortages.

    Until system-level equivalence is operational and enforced, only recycled content genuinely produced in the EU, EFTA and the UK should count towards the targets, with a built-in safeguard for proven shortages.

  • Make rules enforceable via assessments, audits, and deterrent penalties so non-compliance costs more than compliance.

    Make it enforceable, through real assessments, audits and penalties, harmonised as far as possible and deterrent enough that non-compliance costs more than compliance.

• Eastman Company, BEL; register: Companies & groups model reads as: wants changes source
  • Assess equivalence at the national whole-system level rather than solely at the plant level.

    Assess equivalence at country level, not only at installation level.

  • Allow only recycled content produced in the EU, EFTA, and the UK until system-level equivalence is operational, allowing third-country material only once verified and traceable.

    Until system-level equivalence is operational and enforced, only recycled content genuinely produced in the EU, EFTA and the UK should count towards the targets, with a built-in safeguard for proven shortages.

  • Ensure enforcement through rigorous assessments, audits, and penalties that deter non-compliance.

    Make it enforceable, through real assessments, audits and penalties, harmonised as far as possible and deterrent enough that non-compliance costs more than compliance.

• Aliplast spa Company, ITA model reads as: wants changes source
  • Evaluate equivalence at the country level instead of relying solely on single-installation certification.

    Assess equivalence at country level, not only at installation level.

  • Count only EU, EFTA, and UK recycled content towards targets until system-level equivalence is functional, with safeguards for shortages.

    Until system-level equivalence is operational and enforced, only recycled content genuinely produced in the EU, EFTA and the UK should count towards the targets, with a built-in safeguard for proven shortages.

  • Enforce requirements through harmonised assessments, audits, and deterrent penalties.

    Make it enforceable, through real assessments, audits and penalties, harmonised as far as possible and deterrent enough that non-compliance costs more than compliance.

• Association of Plastic Recyclers Business association, USA model reads as: wants changes source
  • Recognize recycling programs and waste management regulations in Canada and the United States as equivalent to those of EU member states.

    Canada and the United States have strong regulations for the environmentally-sound management of waste, and robust, source-separated recycling programs that should be recognized as equivalent to those of the EU member states.

  • Require independent third-party certification of post-consumer plastics to verify recycled content compliance under PPWR.

    APR recommends that the Commission require independent third-party certification of post-consumer plastics as the most reliable and robust method to verify recycled content compliance under PPWR.

  • Establish a process allowing qualified subnational agencies, certification bodies, or independent third parties to act as proxy competent authorities for North American recyclers.

    APR requests that the Commission establish a process for qualified subnational agencies, certification bodies, or other independent third parties to serve as a proxy competent authority for North American recyclers.

• Eurochambres Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish practical and proportionate rules that reflect the diversity of packaging formats placed on the EU market.

    Eurochambres therefore calls for practical and proportionate rules that reflect the diversity of packaging placed on the EU market.

  • Base compliance on verifiable information transmitted along the supply chain without requiring downstream operators to reconstruct inaccessible data.

    Compliance should be based on verifiable information transmitted along the supply chain, without requiring downstream operators to reconstruct information that is not reasonably available to them.

• VNO-NCW / VTCR Business association, NLD model reads as: wants changes source
  • Restrict eligibility for mandatory recycled-content targets to plastic waste collected, sorted, and recycled within the EU27, EFTA, and the United Kingdom.

    Only plastic waste collected, sorted and recycled within the EU27, EFTA and the United Kingdom should count towards mandatory recycled-content targets for packaging produced or filled in Europe.

  • Adopt the Implementing Act without delay to ensure investment certainty.

    Adopt the Implementing Act without delay. Timely adoption is essential to provide investment certainty and make the 2030 recycled-content targets operational.

• USA Pulses Business association, USA model reads as: wants changes source
  • Assess equivalence based on environmental and human-health outcomes instead of requiring identical regulatory structures.

    Assess equivalence against environmental and human-health outcomes rather than requiring identical regulatory structures.

  • Recognise qualified third-party auditors outside the EU and existing certification or audit evidence.

    Recognize qualified third-party auditors outside the EU and existing certification or audit evidence where it demonstrates compliance with the required criteria.

  • Allow verified upstream evidence to support multiple transactions where processes remain unchanged instead of requiring repeated shipment audits.

    Allow verified upstream evidence to support multiple transactions where the material, facility, process and certification remain unchanged, rather than requiring repeated audits for every shipment.

• Micro company, GBR Company, GBR model reads as: opposes source
  • Exempt micro-businesses from the obligation to appoint authorised representatives.

    Micro-businesses should be exempt from the obligation to appoint authorised representatives, based on appropriate staff and turnover thresholds.

  • Introduce a de minimis sales volume threshold per destination country to exempt low volumes from triggering representative requirements.

    Where an exemption is not possible, a de minimis threshold per destination country should apply, below which small volumes of cross-border sales do not trigger the requirement for a separate authorised representative.

  • Establish an EU-wide one-stop-shop and standardised packaging data submission for small businesses.

    A genuine EU-wide one-stop-shop system should be created, allowing small businesses to meet registration, reporting and compliance requirements centrally rather than entering into separate contracts and paying separate fixed fees in every Member State.

• Centexbel-VKC Academic or research institution, BEL model reads as: wants changes source
  • Require non-EU recycled material to be certified under EU-accredited certification systems.

    Non-EU recycled material should be certified according to EU accredited systems (Recyclass - Polycert Europe - GRS - ..)

• ecoplus. Niederösterreichs Wirtschaftsagentur GmbH NGO, AUT model reads as: wants changes source
  • The same traceability, certification, environmental, and verification standards must apply equally to both EU and non-EU operators.

    Traceability, certification, environmental and health protection, product quality and independent verification requirements must apply equally to European and non-European companies.

    machine translation by the Commission, original in DE
  • Recognition of third-country recyclates must be strictly based on robust evidence and independent control mechanisms.

    The recognition of recyclates from third countries may only be based on robust evidence and transparent, independent control mechanisms.

    machine translation by the Commission, original in DE
  • Trade policy instruments and restrictions should be explored if equivalent standards cannot be ensured.

    If equivalent application and control of requirements in third countries cannot be ensured, appropriate trade policy instruments should be explored.

    machine translation by the Commission, original in DE
• FEDIMA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The rules should establish objective equivalence criteria and prevent duplicate documentation and audit demands.

    The rules should provide objective equivalence criteria and avoid unnecessary duplication of documentation, audits or certification requirements.

  • The Commission should recognize independent audits and build upon existing certification and traceability schemes.

    FEDIMA recommends that the Commission recognises independent audits and, wherever possible, builds on existing and well-established certification and traceability schemes.

  • The rules should maintain commercial feasibility and avoid restricting reliable non-EU sources of food-contact compliant recycled material.

    The rules should therefore strike the right balance between regulatory robustness and commercial feasibility, avoiding unnecessary restrictions on access to reliable sources of recycled material from outside the EU.

• Faerch A/S Company, DNK; register: Companies & groups model reads as: wants changes source
  • Require recyclates from post-consumer plastic waste collected and recycled in the EU, EFTA, or UK for compliance with PPWR Article 7 targets for packaging produced or filled in the EU.

    Faerch supports requiring recyclates from post-consumer plastic waste collected and recycled in the EU, EFTA or UK for compliance with PPWR Article 7 targets for packaging produced or filled in the EU.

  • Admit third-country recyclates for packaging produced and filled outside the EU only where equivalence is demonstrated through a two-step approach reflecting the SUPD framework.

    For packaging produced and filled outside the EU, third-country recyclates should be eligible where equivalence is demonstrated through a two-step approach broadly reflecting the SUPD framework: a country-level equivalence assessment by European authorities of national legislation on waste collection, recycling and emissions, followed by independent facility certification and annual third-party audits.

  • Require waste origin and processing to be traceable through documentation across the value chain.

    Waste origin and processing must be traceable through documentation across the value chain.

• Japan Clean Ocean Material Alliance (CLOMA) Business association, JPN model reads as: wants changes source
  • Base equivalence on environmental outcomes rather than demanding identical regulatory systems.

    In establishing conditions for recycled content originating from third countries, third countries should not be required to adopt regulatory, recycling or certification systems identical to those applied within the EU in order for equivalence to be recognised.

  • Apply the outcome-based equivalence approach consistently to both recycled plastics and packaged goods incorporating them.

    This approach to equivalence should be applied consistently not only to recycled plastics originating from outside the EU, but also where packaging, packaging components or packaged products incorporating such recycled plastics are manufactured outside the EU and placed on the EU market.

  • Recognise existing national documentation, verification, and certification systems where appropriate.

    Where sufficient assurance can be provided regarding the origin, traceability and recycled content of plastics, the European Commission should make maximum practical use of existing national documentation, verification, certification and audit systems.

• Atria Oyj Company, FIN; register: Companies & groups model reads as: wants changes source
  • Assess third-country recyclate equivalence against the same standards and evidence required of Union installations.

    Equivalence should be assessed based on the same evidence as an installation in the Union would have to provide.

  • Require accredited third-party audits directly at the recycling installation rather than accepting document reviews at import.

    The assessment should be made at the installation where the waste is recycled, by an auditor accredited for that purpose. A simple document review at the point of import should not serve as a substitute.

  • Place legal responsibility for the accuracy of declared recycled content on the importer and the certifier.

    Responsibility for the accuracy of the declared recyled content should rest with the importer and the certifier.

• Futerro S.A. Company, BEL; register: Companies & groups model reads as: wants changes source
  • Base the methodology on robust, verifiable, and auditable equivalence requirements with market surveillance measures if not met.

    To ensure a genuine level playing field, the methodology should rely on robust, verifiable and auditable requirements to demonstrate that recycled content claimed outside the EU is subject to rules equivalent to those required of EU operators.

  • Exclude non-EU materials from PPWR targets if equivalent enforcement cannot be ensured.

    If equivalent enforcement of PPWR requirements cannot be ensured in third countries, appropriate market surveillance and trade-related measures should be considered, including the exclusion of such materials from counting towards PPWR recycled-content targets.

  • Extend equivalent verification principles to future obligations under Article 8 for bio-based plastic packaging.

    Robust verification of equivalence is to be extended beyond recycled-content requirements and should guide the implementation of all future PPWR obligations, including those that will be developed under Article 8 for bio-based plastic packaging.

• Japan Chemical Industry Association Business association, JPN; register: Trade and business associations model reads as: wants changes source
  • Assess equivalence based on objective supply chain outcomes rather than country of origin.

    Equivalence of recycled content collected, sorted or recycled outside the EU should be assessed on the basis of objective and verifiable conditions and outcomes at the relevant stages of the supply chain, rather than on the country or region of origin as such.

  • Permit existing international third-party certification and audits without mandating a single specific scheme.

    Where equivalent levels of reliability, traceability and verifiability required under the PPWR can be demonstrated through existing international third-party certification, accredited audits, Chain of Custody (CoC) systems, technical documentation, supplier declarations or other auditable records, these should be usable as evidence of compliance.

  • Grant an adequate transition period to accommodate global supply chains.

    Given that global recycled-material supply chains often involve multiple operators and jurisdictions, an adequate transition period should be provided, taking into account certification capacity and costs and the time needed to establish the necessary data, contractual, traceability and documentation systems.

• CONAI e COREPLA Business association, ITA model reads as: wants changes source
  • Provide a dual legal basis in the TFEU under Article 114 and Article 191.

    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
  • Reconsider carrying out an impact assessment to support the executive act.

    Reconsider an impact assessment to support the 3 Executive Act.

    machine translation by the Commission, original in IT
  • Extend European accredited verification and traceability schemes to collection.

    Provide for verification and traceability schemes extended to collection, accredited in Europe and certifiable by third party

    machine translation by the Commission, original in IT
• Ministry of Environment of the Czech Republic Public authority, CZE model reads as: wants changes source
  • Postpone obligations if significant auditing, verification, or accreditation capacity shortages are found.

    Where significant capacity shortages are identified, the application of the relevant obligations should be postponed until the necessary capacity is in place.

  • Base the verification system on risk assessment and targeted checks instead of systematic auditing across all operators.

    The system should be based on risk assessment and targeted verification measures rather than systematic checks across all operators and supply chains.

  • Link established standards to the Digital Product Passport instead of establishing an entirely new certification system.

    Commission should not create an entirely new certification system from scratch, but should link existing, established standards (EN 15343, RecyClass, EuCertPlast) with the planned Digital Product Passport (DPP).

33 more analysed submissions on the consultation page.