The European Commission is developing rules under the Packaging and Packaging Waste Regulation (PPWR) to determine how recycled content from outside the EU can count towards mandatory recycled content targets for plastic packaging.

In response to the Commission’s call for evidence, Cefic is calling for a framework that ensures imported recycled content meets requirements equivalent to those applied within the EU.

Accommodating global supply chains to the mandatory PPWR

The PPWR introduces mandatory recycled content targets for plastic packaging placed on the EU market. As global supply chains play an increasing role in the supply of recycled materials, all recycled content counted towards these targets should be subject to equivalent requirements, regardless of where it originates.

Without a robust verification framework, there is a risk of inconsistent requirements, unfair competition and reduced confidence in recycled content claims.

A practical, enforceable framework for compliant imports

A harmonized, outcome-based approach is key to maintain a level playing field and support investment in European recycling capacity while maintaining access to verified recycled materials from third countries.

Cefic recommends that the Commission:

• Apply equivalent requirements to all recycled content placed on the EU market, whether produced inside or outside the EU.

• Cover all entry points into the value chain, from recycled feedstocks and polymers to packaging components and finished packaging.

• Build on existing verification principles established under the Single-Use Plastics Directive.

• Use independent third-party verification and recognized certification schemes to demonstrate compliance.

• Strengthen enforcement through certification, declarations and auditable documentation linked to recycled content claims.

Such an approach would ensure a level playing field, protect the integrity of EU recycled-content targets and provide a practical and enforceable framework for compliant imports. A level playing field, trusted claims and consistent rules will be key to supporting Europe’s circular economy ambitions.