Sustainability criteria for plastic recycling technologies

211 submissions in the snapshot (169 from organisations), portal total 211. Feedback list on the portal.

169 of 169 organisation submissions analysed; the model reads them as: opposes 11 supports 15 wants changes 108 35 held back for review (low confidence).

• Micro company, DEU Company, DEU model reads as: wants changes source
  • Exempt micro-enterprises from the authorised representative obligation and introduce a de minimis limit for cross-border shipments.

    First, micro-enterprises should be generally exempted from the obligation of authorised representatives according to the known staff headcount and turnover limits. For undertakings that exceed these limits but still send small quantities across borders, at least one de minimis limit per destination country should apply as a fall-back solution, below which there is no obligation to appoint their own authorised representative.

    machine translation by the Commission, original in DE
  • Create a genuine one-stop-shop solution for central registration and reporting across all Member States with one-off fixed costs.

    Instead, a genuine one-stop-shop solution is needed, allowing the registration and reporting obligations for all Member States to be fulfilled centrally and with only one-off fixed costs.

    machine translation by the Commission, original in DE
  • Technically standardise packaging data transmission so it does not need to be reprocessed per country.

    Third, the transmission of data to authorised representatives or to a single point of contact should be technically standardised so that once packaging data is collected, it does not need to be reprocessed for each country.

    machine translation by the Commission, original in DE
• Micro company, AUT Company, AUT model reads as: wants changes source
  • Establish a centralized EU authority to pool and harmonise PPWR implementation across all Member States.

    It would be more appropriate to have a central authority at EU level that pools and harmonises implementation for all Member States.

    machine translation by the Commission, original in DE
• Micro company, DEU Company, DEU model reads as: wants changes source
  • Establish a single government agency responsible for recycling compliance across all EU countries.

    With a single government agency responsible for all EU countries, this could work really well.

  • Modify the PPWR to make it affordable and manageable for small businesses.

    My hope is that, after some time, the PPWR will be modified into a reasonable form that is also affordable for small businesses not only for major players like Amazon.

• Micro company, GBR Company, GBR model reads as: opposes source
  • Target large platforms rather than small export businesses.

    Instead of harming the real culprits ( Amazon, Temu, Shien etc), it has already in just 2 days started to destroy exports from small business to Europe.

  • Place small businesses at the heart of the legislation.

    If they had small business would have been at the heart of the legislation.

• Micro company, FRA Company, FRA model reads as: wants changes source
  • Introduce exemption thresholds or a single simplified European system for micro and very small enterprises.

    It is essential to provide for exemption thresholds or a single, simplified European system for micro and very small enterprises.

    machine translation by the Commission, original in FR
• EAS Project Company, EST model reads as: opposes source
  • Provide a pan-EU registration option and mutual recognition across Member States.

    Article 45 requires a separate authorised representative in every member state of non-establishment, by law, with no pan-EU option, so selling one product in Germany, France, Italy and Spain now means four registrations, four contracts and four representatives, with no mutual recognition between them.

• Micro company, FIN Company, FIN model reads as: opposes source
  • Support entrepreneurs and workers affected by the Packaging Directive.

    Does the Commission indicate the amount by which these 60 million entrepreneurs and workers will be supported?

    machine translation by the Commission, original in FI
  • Refrain from adding provisions that complicate and limit business activities.

    It is not the role of the European Union to add any additional provisions that complicate and limit the activities of companies.

    machine translation by the Commission, original in FI
• Micro company, GBR Business association, GBR model reads as: wants changes source
  • Introduce an exemption for small businesses below a certain threshold of takings or scale.

    I ask that you reconsider this law in regards to how it affects people like me, and consider an exemption within a certain threshold of takings/business scale.

• Micro company, SVK Company, SVK model reads as: opposes source
  • Revise packaging and foreign registration rules so small creators are not required to pay high fees, register across multiple countries, and hire foreign representatives.

    Expecting a one-person shop to register in multiple EU countries, pay hundreds of euros in fixed annual fees, and hire foreign representatives just to send a few handmade parcels a year is absurd.

• Micro company, ITA Company, ITA model reads as: wants changes source
  • Establish a single EU-wide platform for registration and fee payment.

    At least reunite it all on one platform to register and pay from.

  • Implement unified registration across all EU member states in one step.

    There should a unified registration for all the countries in one go, and different levels of taxation for the differently sized companies( or number of parcels shipped per month/ year...)

• Micro company, ITA Environmental organisation, ITA model reads as: supports source
  • Ensure the methodology can reconstruct the shift from post-consumer waste to recycled material and prevent double counting across supply chains.

    The methodology should therefore make it possible to reconstruct the shift from post-consumer waste to recycled material used in packaging.

    machine translation by the Commission, original in IT
  • Base sustainability criteria for recycling technologies on measurable process performance rather than technology type alone.

    For the sustainability criteria of recycling technologies, an assessment based on the measurable performance of the process, rather than solely on the type of technology used, seems preferable.

    machine translation by the Commission, original in IT
  • Make part of verification data available to competent authorities in a structured digital format, separating control documents from confidential data.

    Finally, part of the data produced through the verification system should be made available to the competent authorities in a structured format, keeping the documentation necessary for controls separate from commercially confidential information.

    machine translation by the Commission, original in IT
• Micro company, DEU Company, DEU model reads as: wants changes source
  • Exclude micro and small businesses from the requirements of the PPWR regulation.

    Please exclude micro and small businesses from the crushing impacts of the new PPWR regulation.

• Micro company, DEU Company, DEU model reads as: wants changes source
  • Provide an exemption for micro-enterprises or establish a simplified EU-wide registration and reporting system.

    I strongly support either a genuine exemption for micro-enterprises and very small-volume sellers, or a simple EU-wide registration and reporting system that allows small businesses to sell across the single market without having to go through separate systems in each Member State.

    machine translation by the Commission, original in DE
• Micro company, NLD Company, NLD model reads as: wants changes source
  • Create a single centralized EU registration number.

    create one central EU registration number

  • Establish a centralized one-stop EU registration tailored to business size rather than applying a blanket law.

    create a one stop EU registration for the size of businesses so that the new law can be measured to size not as a blanket law

  • Prioritize regulating the largest polluters first while providing smaller businesses paths to gradually reduce waste.

    focus on the largest polluters first and give the rest of the economy the option to nudge themselves in to a situation of producing less waste, most businesses want to comply but they do not want to die.

• Micro company, BEL Company, BEL model reads as: wants changes source
  • Ensure registration costs do not exceed the cost of waste.

    the cost of registration should never surpass the cost of the waste.

  • Pause the legislation until a centralized, free joint registration and waste payment platform is established.

    Please, reconsider this bill and pause it until a free joint platform for registration is made available, where all waste payments can be centralized.

• Micro company, FRA Company, FRA model reads as: wants changes source
  • Introduce an EU-wide de minimis threshold for micro-enterprises alongside a single EU registration and reporting system.

    I would therefore strongly support an EU-wide de minimis threshold for micro-enterprises, combined with one single EU registration and reporting system for cross-border packaging EPR.

  • Allow micro-businesses to report total packaging volumes once and allocate contributions centrally between Member States.

    A micro-business should be able to report its total packaging volumes once, with the relevant contributions subsequently allocated between Member States, rather than having to maintain multiple national registrations for very small quantities.

  • Ensure compliance costs for micro-enterprises do not exceed the proportionate environmental contribution due for actual packaging placed on the market.

    For micro-enterprises, compliance costs should never exceed the environmental contribution that would reasonably be due based on the actual packaging volumes placed on a national market.

• Cefic Business association, BEL model reads as: wants changes source
  • Design sustainability criteria to be technology-neutral and aligned with the PPWR definition of high-quality recycling.

    Cefic considers it essential that these sustainability criteria are designed to be technology-neutral and aligned with the PPWR definition of high-quality recycling (Recital 30 and Article 3(41)), ensuring that all recycling technologies, including chemical recycling technologies, are assessed based on what they deliver in practice.

  • Incorporate broader circularity and resource efficiency indicators beyond climate metrics alone.

    Incorporate broader circularity and resource efficiency indicators, beyond climate metrics alone, with performance primarily assessed against the virgin materials being substituted in line with PPWR high-quality recycling objectives, while also recognising, where relevant, the avoidance of incineration and landfill for complex waste streams;

  • Keep sustainability criteria flexible and innovation-friendly to accommodate evolving chemical recycling technologies.

    Last but not the least, remain flexible and innovation-friendly, reflecting the nascent stage of chemical recycling, where limited data availability and evolving technologies make rigid or prescriptive criteria premature.

• Micro company, FRA Company, FRA model reads as: opposes source
  • Harmonize cross-border obligations instead of maintaining varying national requirements that burden microentrepreneurs.

    obligations that vary from country to country, which is absurd in the context of the EU single market.

• Micro company, PRT Company, PRT model reads as: wants changes source
  • Introduce a de minimis exemption or turnover/volume threshold with simplified obligations for microbusinesses.

    Please build a de minimis exemption or meaningful turnover/volume threshold into PPWR implementation, with simple, harmonised obligations for microbusinesses and no requirement for a representative in every Member State.

  • Proportionately allocate the largest regulatory obligations to the largest packaging and waste producers.

    The greatest obligations should fall on the largest producers of packaging and waste, whose emissions and material footprints dwarf those of microbusinesses reusing existing materials.

  • Ensure environmental responsibility requirements are proportionate and targeted where the greatest harm occurs.

    Environmental responsibility must be proportionate, coherent and applied where the greatest harm occurs.

• Micro company, SWE Company, SWE model reads as: wants changes source
  • Establish a unified single-report registration and combined payment system modeled on the OSS system.

    There needs to be a unified system like the OSS system where we can register our packaging volumes per member state with a single report, and pay the fees for the waste generated in a single, combined payment.

• UPM-Kymmene Oyj Company, FIN; register: Companies & groups model reads as: supports source
  • Assess recycling technologies based on demonstrated environmental and circularity performance rather than the specific technology used.

    Recycling technologies should be assessed based on their demonstrated environmental and circularity performance rather than on the technology used.

  • Recognize the role of technologies capable of processing complex waste streams that would otherwise face incineration or landfill.

    In particular, sustainability criteria should recognise the contribution of recycling technologies capable of treating complex waste streams that cannot effectively be recycled through other routes and that would otherwise be directed to incineration, landfill or other forms of value loss.

  • Maintain sufficient flexibility in criteria to support innovation and technological progress while ensuring environmental credibility.

    The criteria should remain sufficiently flexible to support innovation and technological development while ensuring environmental credibility and transparency.

• Günter Bissinger Medizintechnik GmbH Company, DEU model reads as: wants changes source
  • Envisage a simplified verification procedure with tiered evidence requirements based on material quantity or component size for very small components.

    For very small components with a low material weight, a simplified verification procedure could be envisaged (e.g. conservative default assumptions instead of full traceability documentation), provided that the packaging function of the overall packaging (e.g. the primary transport or grouped packaging) is otherwise demonstrated to be compliant.

  • Clarify the calculation level for multi-component packaging units by providing guidance on whether evidence must be provided per individual component or at the overall packaging unit level.

    We would welcome clear guidance on whether the recycled-content evidence must be provided at the level of each individual component, or by analogy with Article 3(43) of the Regulation ("integrated component") at the level of the overall packaging unit.

  • Raise awareness among non-specialised suppliers through a cross-sector information campaign or an interpretive note.

    Since the suppliers concerned frequently do not perceive themselves as addressees of the Regulation, a supporting cross-sector information campaign or an easily accessible interpretive note would be helpful, clarifying that technical components without an obvious packaging function may also fall within the scope of the Regulation depending on the purchaser's intended use.

• Micro company, DEU Company, DEU model reads as: opposes source
  • Reconsider and revise the EPR regulations to prevent the destruction of online-selling based micro-businesses.

    So please reconsider the regulations before it is too late.

• Drewno-klejone sp. z o.o. Company, POL model reads as: opposes source
  • Address the excessive administrative and financial burden imposed by EPR regulations that halts cross-border trade for smaller enterprises.

    tak w tym wypadku skonstruowała potworka, który całkowicie zatrzyma handel zagraniczny w mniejszych podmiotach.

• Micro company, ITA Company, ITA model reads as: opposes source
  • Introduce an EU-wide de minimis exemption for microbusinesses based on company size, turnover, and actual packaging volume.

    We need a REAL EU-WIDE DE MINIMIS EXEMPTION based on the size of the business, turnover and actual packaging volume.

  • Exempt microbusinesses below the threshold from separate national registrations, authorised representatives, reporting systems, and fixed minimum fees.

    Below that threshold, microbusinesses should be exempt from separate national registrations, authorised representatives, national reporting systems and fixed minimum fees.

• Procter & Gamble Company, BEL; register: Companies & groups model reads as: wants changes source
  • Adopt a technology-neutral sustainability assessment framework based on objective performance indicators rather than favoring or penalizing specific technologies.

    The sustainability assessment and resulting key criteria for plastic recycling technologies should be technology neutral, so as to permit (rather than hinder) innovation in support of a circular plastics economy.

  • Specify a single harmonised, simplified comparative LCA methodology with a presumption of conformity for technologies within recognised performance ranges.

    In order to keep the burden proportionate, the Commission should specify a single harmonised, simplified comparative LCA methodology (building off the approach for the Product Environmental Footprint category rules), with a presumption of conformity for technologies falling within recognised performance ranges.

  • Subject assessment methodologies and criteria to regular review and adaptation rather than relying on a fixed technology list.

    Lastly, any assessment methodologies and criteria should be subject to regular review and adaptation to technological maturation in order to continue to permit future innovation rather than rely on a fixed technology list.

• China Synthetic Resin Association, Plastics Reuse and Recycling branch (CPRRA) NGO, CHN model reads as: wants changes source
  • Base third-country equivalence recognition on verifiable technical capacity and facility performance rather than OECD status.

    We maintain that third-country equivalence recognition should be based on verifiable capacity and environmental performance as objective criteria, and should not be demarcated by non-technical proxy indicators such as geographic affiliation or group membership.

  • Implement equivalence recognition under existing international standards without starting from scratch.

    Equivalence recognition therefore need not start from scratch; it can be implemented under the existing international standards system.

  • Mutually recognise China's institutional traceability supervision system rather than layering duplicate certification.

    This system should be mutually recognized with the EU's existing supervisory capacity, rather than having duplicate certification layered on top of the existing system.

• B-Plast 2000 Kunststoffverarbeitungs-GmbH Business association, DEU model reads as: wants changes source
  • Take due account of high-quality plastic recycled from industrial waste alongside post-consumer waste.

    I would therefore ask the European Commission to take due account of high-quality plastics from industrial waste that have been proven to be recycled.

    machine translation by the Commission, original in DE
  • Ensure rules are economically feasible and sustainable for small and medium-sized enterprises.

    The rules must be environmentally sound, economically feasible and sustainable for small and medium-sized enterprises.

    machine translation by the Commission, original in DE
• B-Plast 2000 Kunststoffverarbeitungs-GmbH Company, DEU model reads as: wants changes source
  • Recognise certified and traceable post-industrial recycled content within the delegated acts or through targeted amendment of Article 7.

    B-Plast 2000 asks the Commission to properly recognise certified and traceable PIRs.

    machine translation by the Commission, original in DE
  • Consider a combined recycling rate with a guaranteed minimum PCR share or limited credit for PIR.

    A combined recycling rate with a guaranteed minimum PCR share or at least a limited PIRAn calculation in technically justified cases would be useful.

    machine translation by the Commission, original in DE
  • Subject imported recyclates to the same environmental, quality, labor, and control standards as European companies.

    Imported recyclates must be subject to the same environmental, quality, labour and control standards as European companies.

    machine translation by the Commission, original in DE
• Bioeksen AR GE Teknolojileri A.Ş Company, TUR model reads as: wants changes source
  • Keep sustainability criteria technology-neutral and based on measurable outcomes rather than process lists.

    Keep the criteria technology-neutral and outcome-based.

  • Define operational specifications and standards for recyclate output quality.

    The criteria should require recyclate to be delivered against a defined grade specification with documented contaminant control and batch-to-batch consistency, using existing standards (e.g. EN 15343 traceability, EN 15342/15344/15346/15348 characterisation).

  • Assess environmental performance against relevant counterfactuals such as landfill, incineration, or virgin production on a life-cycle basis.

    Energy use and emissions should be compared with the fate the waste stream would otherwise have (incineration or landfill) and with virgin production, on a life-cycle basis (ISO 14040/14044).

• Ministry of Environment of the Czech Republic Public authority, CZE model reads as: wants changes source
  • Maintain a technology-neutral approach towards different recycling technologies based on objective indicators.

    When preparing the implementing act, we recommend: maintaining a technology-neutral approach towards different recycling technologies; relying on life-cycle assessment (LCA) methodologies and other objective performance indicators; assessing technologies on the basis of their actual energy consumption, material yield, emissions profile, and resource efficiency; taking into account differences in the characteristics and quality of input materials; ensuring transparency, reproducibility, and verifiability of the assessment methodologies applied.

  • Base the sustainability assessment on quantifiable parameters such as material yield, energy consumption, and emissions balance.

    Quantifiable parameters for sustainability assessment: Material yield, defined as the ratio of the weight of the output polymer to the input.

• Kaneka Company, BEL; register: Companies & groups model reads as: wants changes source
  • Ensure the sustainability criteria are technology-neutral and science-based.

    1. Ensure technology-neutral and science-based sustainability criteria

  • Recognise the comprehensive environmental benefits of recycling output.

    2. Recognise the full environmental benefits of recycling output

  • Incorporate considerations for microplastic generation and release into the criteria.

    3. Ensure sustainability criteria which account for microplastic generation and release

• BEWI Company, NOR model reads as: wants changes source
  • Build the methodology on recognized standards and third-party certification systems.

    The future methodology should build on recognised standards and established third-party certification systems, including EN 15343, REDcert² and equivalent chain-of-custody schemes.

  • Accept mass balance chain-of-custody models for both mechanical and chemical recycling.

    Mass balance should therefore be accepted as a chain-of-custody model for both routes, subject to equivalent requirements for traceability, defined system boundaries, third-party certification and prevention of double counting.

  • Provide appropriate transition flexibility for contact-sensitive packaging where closed-loop recycling is technically unfeasible.

    Where closed-loop recycling is therefore not technically realistic, the methodology should provide appropriate flexibility during a transition period.

• Veolia Company, BEL; register: Companies & groups model reads as: wants changes source
  • Establish a legally binding technology hierarchy grounded in mandatory Life Cycle Analysis.

    We urge the European Commission to establish a technology hierarchy grounded in mandatory Life Cycle Analysis (LCA), evaluating GHG emissions, energy consumption, and generation.

  • Include energy, water, and solvent consumption with appropriate weighting in the sustainability criteria.

    It is key to include energy consumption (electricity, gas, fuel oil), water consumption, and the use of solvents, with a weighting that accurately reflects industrial reality (approximately 50% attributed to energy consumption).

  • Maintain consistency in waste treatment comparisons within Life Cycle Assessments.

    We are in favor of the Life Cycle Assessment methodology, but we call for consistency in the choice of waste treatment technologies during comparisons (e.g., not comparing chemical recycling with Waste-to-Energy: the comparison should remain between recycling technologies).

• EFPIA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure the delegated act fully respects and aligns with exemptions for medicinal-product packaging without creating indirect recycled-content obligations.

    The sustainability criteria should be implemented consistently with these exemptions and should not create indirect requirements for packaging that the co-legislators have expressly excluded from the recycled-content targets.

  • Provide guidance on the safe use of mechanically recycled post-consumer material in pharma packaging similar to food-contact regulations.

    Inspired by the new EU regulation for food-contact materials, similar guidance for conditions under which mechanically recycled post-consumer material in pharma packaging can be considered safe could help foster increased use of recycled content in the pharma sector.

  • Publish a science- and risk-based guideline framework adhering strictly to stated timelines to safeguard medicine supply chains.

    Publication of the framework must adhere to stated timelines, to give sufficient time for packaging changes to be implemented within global supply chains without impacting supply of medicines to patients.

• COREPLA - Consorzio Nazionale per la raccolta, il riciclo e il recupero degli imballaggi in plastica Other, ITA model reads as: wants changes source
  • Establish a dual legal basis in the TFEU covering both the internal market and the 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
  • Reconsider an impact assessment that includes a proportionality and subsidiarity review by Member States.

    Reconsider an impact assessment to support the 3 Executive Act. Include a proportionality and subsidiarity assessment by the Member States

    machine translation by the Commission, original in IT
  • Define granular sustainability criteria that go beyond broad recycling categories and ensure their weighting in recyclability assessments is proportionate.

    Define sustainability criteria according to levels of granularity that go beyond the mere distinction between categories of the main recycling processes

    machine translation by the Commission, original in IT
• Plastics Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish minimum eligibility benchmarks rather than ranking different recycling routes.

    The framework should establish minimum eligibility benchmarks rather than rank recycling routes, enabling all recycling technologies to contribute effectively to meeting recycled content targets.

  • Underpin the criteria with transparent governance and proportionate requirements to limit administrative burden.

    To be credible and implementable, the criteria should be underpinned by transparent governance - including published assumptions, datasets, and system boundaries - and by proportionate data and requirements that limit administrative burden.

  • Ensure sustainability criteria are clear, workable, and technology neutral across complementary recycling technologies.

    Sustainability criteria for plastics recycling technologies under the PPWR should be clear, workable, and technology neutral.

• 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 sustainability criteria.

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

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

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

  • Ensure that imported post-consumer plastic waste meets EU standards as a minimum.

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

• Japan Business Council in Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Assess recycling technologies based on objective environmental performance outcomes rather than pre-determining eligibility.

    Technologies should therefore be assessed on the basis of environmental outcomes and overall performance rather than by pre-determining the eligibility of specific technologies.

  • Balance environmental criteria with the practical availability and supply of recycled materials.

    Sustainability criteria should strike an appropriate balance between environmental performance and the practical availability of recycled materials.

  • Provide adequate transition periods and align criteria with existing frameworks to avoid compliance burdens.

    Regulatory certainty, transparency and adequate transition periods are essential to encourage continued investment in recycling technologies and infrastructure.

• bobine Company, FRA; register: Companies & groups model reads as: wants changes source
  • Assess technology performance over consistent system boundaries using measured yields rather than theoretical assumptions across the full chain.

    The assessment should cover the full chain, from waste reception to polymer-grade output: routes producing a fungible intermediate require downstream hydrotreatment and steam cracking, whose energy use and emissions are part of their footprint, just as the absence of such steps is part of the performance of routes converting the waste-derived stream directly into monomers.

  • Target advanced recycling to waste streams that mechanical recycling cannot process.

    Take into account the nature of the waste streams addressed. Advanced recycling delivers its full environmental value when it treats streams that mechanical recycling cannot, rather than competing with it for easily recyclable feedstock.

  • Establish a periodic review mechanism and accept data from industrial pilots and demonstrators to accommodate emerging technologies.

    A periodic review mechanism would prevent the criteria from consolidating the market around existing configurations, and evidence requirements should be met with data from industrial pilots and demonstrators, not only commercial-scale installations.

• Encina Development Group Company, USA model reads as: wants changes source
  • Apply technology-neutral and performance-based eligibility criteria to all recycling technologies.

    Apply technology-neutral, performance-based eligibility criteria to all recycling technologies.

  • Harmonize life-cycle boundaries, allocation rules, data-quality requirements, and comparative baselines.

    Use harmonized life-cycle boundaries, allocation rules, data-quality requirements, and comparative baselines.

  • Recognize output quality and virgin feedstock substitution, including chemical intermediates used for new plastic manufacturing.

    Recognize output quality and the ability to substitute for virgin feedstocks, including production of chemical intermediates used to manufacture new plastic.

• ALPLA Werke Alwin Lehner GmbH & Co KG Company, AUT; register: Companies & groups model reads as: wants changes source
  • Base sustainability assessments on clearly defined LCA and PEF methodologies with explicitly disclosed assumptions and boundaries.

    To address these challenges, ALPLA calls for sustainability assessments based on clearly defined Life Cycle Assessment (LCA) and Product Environmental Footprint (PEF) methodologies, with reference processes, system boundaries, allocation methodologies and key assumptions explicitly disclosed and justified.

  • Base circularity indicators on physical material flows and report attributed claims separately with transparent allocation disclosures.

    Circularity indicators should be based on physical material flows that support credible packaging-to-packaging recycling, while attributed or allocated claims should be reported separately with clear disclosure of the underlying allocation approach.

  • Exclude transport distance from initial sustainability assessments until harmonized data and calculation rules are established.

    Transport distance should be excluded from the initial assessment and considered only once harmonised data and calculation rules are available.

• Meat Industry Association of New Zealand Business association, NZL model reads as: wants changes source
  • Recognize global food supply chains and the critical role of packaging in food safety and product integrity.

    However, implementation must recognise the realities of global food supply chains and the essential role packaging plays in food safety, shelf life, product integrity, and food waste reduction.

  • Provide greater clarity, flexibility, and international alignment regarding recyclability, reuse, and labelling requirements for imported products.

    MIAs submission highlights concerns regarding the practical application of recyclability, reuse, and labelling requirements for imported products and calls for greater clarity, flexibility, and international alignment.

  • Apply a risk-based and outcomes-focused approach to avoid creating unnecessary trade barriers and compliance burdens.

    A risk-based, outcomes-focused approach will help achieve environmental goals without creating unnecessary trade barriers or compliance burdens.

• Fonterra Ltd Company, NZL model reads as: wants changes source
  • Establish clear, transparent, and non-discriminatory equivalence pathways for third-country recycled materials and technologies.

    To achieve these objectives, the sustainability criteria should establish clear, transparent and non-discriminatory equivalence pathways for recycled materials and recycling technologies originating outside the European Union.

  • Recognize credible international certification, auditing, and chain-of-custody systems providing equivalent assurance to EU standards.

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

  • Grant appropriate transition periods that begin only after sustainability criteria and recognition processes are finalized and clear.

    Appropriate transition periods that begin only once sustainability criteria and recognition processes are finalised and sufficiently clear.

• China Packaging Federation NGO, CHN model reads as: wants changes source
  • Focus standards on end performance indicators rather than prescribing technological routes.

    Standards shall focus on end performance indicators such as emissions and energy consumption rather than prescribing specific technological routes.

  • Permit country-specific verifiable background data, such as local power generation mix, within unified standards.

    Develop unified environmental performance standards while permitting the use of country-specific and verifiable background data (including actual power generation mix) to demonstrate compliance.

  • Recognize compliance assessments conducted under third countries' domestic laws to achieve standard equivalence.

    Recognize compliance assessments conducted by other countries under their domestic laws to achieve standard equivalence and verifiable compliance.

• Trafigura PTE Ltd Company, CHE model reads as: wants changes source
  • Allow recycled content purchased before 2030 to count towards upcoming 2030 compliance mandates.

    While clarifying non-compliance penalties would be extremely helpful, allowing recycled content purchased before 2030 to count towards those obligations (and beyond) is crucial to maintaining existing chemical recycling production capacity as well as to finance additional capacity.

• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Prioritize mechanical recycling over chemical recycling and reserve chemical or dissolution methods only for non-mechanically recyclable waste.

    Mechanical recycling should be prioritized over chemical recycling technologies, with chemical or physical (dissolution) methods reserved only for waste that cannot be mechanically recycled.

  • Assess recycling technologies across relevant value chain stages based on waste stream and intended application.

    Recycling technologies should be assessed according to the waste stream and intended application, covering the relevant stages of the recycling value chain, including sorting, recycling, transport and conversion into new plastic products.

  • Cover overall environmental performance including energy, climate impact, material efficiency, yields, and residues.

    Sustainability criteria should cover the full environmental performance of the technology, i.a. energy and climate performance followed by material efficiency, yields, rejects and residues.

• Food Packaging Forum Foundation Academic or research institution, CHE; register: Think tanks and research institutions model reads as: wants changes source
  • Include chemical safety explicitly among the sustainability criteria used to evaluate plastic recycling technologies.

    Therefore, the chemical safety of highly complex and non-inert materials such as recycled plastics deserves to be explicitly included among the sustainability criteria used to assess plastic recycling technologies.

  • Improve the traceability and transparency of chemicals across the packaging value chain.

    Considering the current lack of available data, FPF would like to highlight the need for improved traceability and transparency of chemicals throughout the packaging value chain.

  • Provide guidance for identifying and managing non-intentionally added substances in recycled plastics.

    Guidance is further needed for the identification and management of potentially problematic non-intentionally added substances (NIAS) in recycled plastics, of which experts estimate there may be tens of thousands of additional chemicals.

• Thailand PPWR Consortium - All sectors Business association, THA model reads as: wants changes source
  • Establish a technology-neutral, performance-based, and improvement-oriented framework using clear and measurable criteria.

    The Consortium therefore encourages a technology-neutral, performance-based and improvement-oriented framework, based on clear and measurable criteria.

  • Allow recycling operations to demonstrate actual performance, address performance gaps, and improve rather than being excluded by technology category.

    Recycling operations should be able to demonstrate their actual performance against the relevant criteria, identify performance gaps and, where necessary, improve their processes and subsequently demonstrate compliance, rather than being permanently included or excluded solely on the basis of a technology name or category.

  • Clarify the operational relationship between Articles 7(9), 7(10), and 7(8).

    The relationship between Articles 7(9), 7(10) and 7(8) should be clear and operational.

• EDANA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Incorporate maximum flexibility into the methodology, including plant-level averaging and a workable interpretation of plastic parts.

    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 a technology-neutral framework that enables chemical recycling and mass balance accounting.

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

  • Focus Article 7(10) equivalence on outcome-based environmental, health, quality, and traceability metrics for non-EU PCR.

    For Article 7(10), the focus should be on demonstrating equivalent environmental, health, quality and traceability outcomes.

• Micro company, ZAF Business association, ZAF model reads as: wants changes source
  • Avoid requiring identical national legislation in third countries to demonstrate equivalence, allowing bilateral agreements instead.

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

  • Establish intermediary measures for non-EU recyclate until the EU sets its own criteria.

    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.

  • Ensure Article 7(9) sustainability criteria are technology-neutral, outcome-based, and recognize South Africa's environmental legal framework.

    Make the Article 7(9) criteria technology-neutral and outcome-based, recognising South Africa's environmental-law framework and not penalising national grid factors.

• CO2 Value Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Systematically integrate carbon capture and utilisation technologies into EU recycling legislations.

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

  • Introduce mass balance accounting rules to distinguish feedstocks.

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

  • Ensure consistency across existing and upcoming legislation to provide clarity for companies and investors.

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

• Suzuki Motor Corporation Company, JPN model reads as: supports source
  • Recycled material usage should be promoted alongside high standards for environmental and health protection.

    We support the objective of promoting the use of recycled materials while ensuring a high level of environmental protection and protection of human health.

  • An equivalence framework should be developed for recycled materials coming from third countries.

    We also welcome the development of an equivalence framework for recycled materials originating from third countries.

• Cabot Company, BEL model reads as: wants changes source
  • Adopt outcome-based, technology-neutral sustainability criteria for plastic recycling under the PPWR.

    Cabot recommends the European Commission to adopt outcome-based, technology-neutral sustainability criteria for plastic recycling under the PPWR.

  • Ensure black plastics and difficult-to-recycle packaging technologies are recognised within the circular economy framework.

    Black plastics should not be excluded from the European circular economy simply because conventional near-infrared sorting systems cannot reliably identify them.

  • Apply equivalent sustainability, traceability, and verification requirements to imported recycled plastics.

    Equivalent sustainability, traceability, and verification requirements must apply to EU-produced and imported recycled plastics.

• FEDIAF EuropeanPetFood Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure criteria are outcome-based and technology-neutral so chemical recycling is recognised on its merits.

    We therefore ask that the criteria be outcome-based and technology-neutral, so that chemical recycling is recognised on its merits

  • Do not calibrate criteria on mechanical PET recycling.

    that they not be calibrated on mechanical PET recycling, which would exclude the very technologies our sector depends on without environmental gain

  • Assess technologies on a life-cycle basis against an incineration counterfactual rather than virgin polymer.

    that they be assessed on a life-cycle basis against a realistic counterfactual of incineration, not virgin polymer.

• Detergents Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish science-based, performance-driven, and technology-neutral sustainability criteria supported by a single harmonised and simplified comparative LCA methodology.

    Establish science-based, performance-driven and technology-neutral sustainability criteria, supported by a single harmonised and simplified comparative LCA methodology, to assess recycling technologies based on their environmental performance, GHG emissions, resource efficiency and output quality.

  • Recognise mechanical and chemical recycling as complementary and permit a fuel-use-exempt mass balance accounting approach.

    Recognise mechanical and chemical recycling as complementary technologies and allow a fuel-use-exempt mass balance accounting approach for the allocation of recycled content;

  • Provide flexibility to accommodate future technological developments and emerging recycling solutions.

    Provide sufficient flexibility to accommodate future technological developments and emerging recycling solutions.

• The Association of European Self-Care Industry (AESGP) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure implementing measures fully respect existing exemptions for medicinal products and certain medical device packaging.

    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.

  • Maintain the availability of suitable recycled plastics for packaging applications that remain within scope.

    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.

  • Develop implementing measures that are proportionate, practical, and consistent with PPWR objectives while safeguarding patient safety and product availability.

    AESGP therefore encourages the Commission to develop implementing measures that are proportionate, practical and consistent with the underlying objectives and exemptions established in the PPWR, while safeguarding patient safety, product integrity and the continued availability of self-care products across the European market.

• United States Government Public authority, USA model reads as: opposes source
  • Align sustainability criteria with proven frameworks instead of adding new bureaucratic burdens.

    aligning sustainability criteria with proven frameworks rather than creating new bureaucratic burdens;

  • Ensure the equivalence methodology reflects actual supply chain operations rather than an EU-centric compliance model.

    ensuring that the equivalence methodology reflects how supply chains actually operate, rather than assuming a single, EU-centric compliance model;

  • Recognise credible third-party or supplier certification schemes as alternatives to government-to-government audits.

    recognizing credible verification schemes, such as third-party certification or through suppliers certification, as a viable alternative to government-to-government audits.

• MONOMERIS CHEMICALS Company, FRA model reads as: wants changes source
  • Allow economic operators to allocate eligible material using process-specific yield factors when feedstocks have distinct output distributions.

    To address this limitation, we propose amending Article 7(5)(a) (reference of the SUPD) of the relevant mass balance methodology by adding the following provision: By derogation, where input materials differ in their chemical compositions resulting in distinct output distributions, the economic operator may determine the allocation of eligible material attributed to the outputs by applying process-specific yield factors, provided such factors are independently verified.

  • Introduce a dedicated transition-support mechanism to assist investment and industrial scale-up ahead of mandatory targets.

    A dedicated transition-support mechanism should therefore be considered to facilitate investment and industrial scale-up before mandatory recycled-content targets fully enter into force.

• Rethink Plastic Alliance NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Apply the Do No Significant Harm principle across seven un-aggregated environmental areas.

    The sustainability criteria under the PPWR should apply the Do No Significant Harm (DNSH) principle across seven un-aggregated areas: carbon footprint (via Product Environmental Footprint/PEF without credit mass balance), human toxicity, energy use, water use/pollution, localized pollution, biodiversity, and fossil resource use.

  • Follow a strict hierarchy prioritizing mechanical recycling over solvent-based stripping and chemical recycling.

    They should follow the hierarchy of Mechanical Recycling Solvent-Based Stripping Chemical Recycling, reflecting the thermodynamic realities.

  • Assess full process steps including pre- and post-treatment and require full disclosure of chemical impacts.

    They should thus require full disclosure of chemicals and solvent processing impacts, including their impacts on human toxicity and freshwater ecotoxicity, to ensure a comprehensive environmental assessment.

74 more analysed submissions on the consultation page.