Summary
EUMEPS welcomes the European Commission's work on sustainability criteria for plastic recycling technologies under Article 7 of Regulation (EU) 2025/40. The criteria should ensure that recycled
plastic used in packaging delivers a clear environmental benefit while creating the regulatory certainty needed to secure and expand European recycling capacity.
The Commission should use a technology-neutral and performance-based approach. Mechanical recycling should remain the preferred route where it can treat the waste efficiently and provide material
of the required quality. Physical purification, including dissolution, and chemical recycling should also qualify where they address waste streams or end-use requirements that mechanical recycling cannot
adequately serve and where their environmental performance is demonstrated through a consistent life-cycle assessment.
Dissolution can separate polystyrene from other materials while preserving the polymer structure. Depolymerisation and thermolysis can recover monomers or feedstock from streams that require
molecular conversion. The delegated act should assess these routes on evidence rather than place them in broad categories that predetermine their eligibility.
The criteria must also protect human health, ensure full traceability from collection to incorporation, and apply equivalent requirements to imported recycled material. Certification and verification should
be credible and proportionate, building on established systems where they meet the PPWR requirements.
EUMEPS recommendations
- Use common environmental criteria across recycling technologies and assess each process against verified performance for the relevant waste stream and recycled output.
- Give priority to efficient material recovery and avoid diverting clean waste from a proven lower-impact route, while preserving complementary routes for contaminated, mixed or technically
demanding streams. - Use a consistent assessment boundary beginning when sorted waste enters the recycling process, with collection and transport addressed through separate representative scenarios
where relevant. - Measure useful recycled output including yield, quality, substitution of virgin raw material, energy demand, greenhouse-gas emissions, pollution, resource use and the treatment of residues.
- Protect safety and sensitive-contact applications by ensuring full consistency with EU food-contact, pharmaceutical and dangerous-goods requirements.
- Require system-wide traceability and verification while recognising suitable existing schemes and limiting unnecessary administrative costs.
Apply equivalent conditions to imports supported by independent audits, market surveillance, reliable customs information and laboratory checks where documentary evidence is insufficient.
Review the framework periodically so that criteria and benchmarks reflect operational evidence, improved sorting and decontamination, and technological progress.
Download the full position paper to read it.