Plastic waste from outside the EU currently cannot count towards SUPD 25% target

LONDON (ICIS)–The European Commission has confirmed to ICIS that only recycled polyethylene terephthalate (R-PET) produced using plastic waste in the EU can currently count towards the 25% recycled content target set out under the Single Use Plastics Directive (SUPD).

In an email to ICIS, a spokesperson for the Directorate-General for Environment (DG-ENV) stated that the 25% target laid out in the SUPD can ‘only be achieved using post-consumer plastic waste generated from plastic products that have been placed on the EU market’.

This expands on Point 4 of Implementing Decision 2023/2683 having regard to Directive (EU) 2019/904 (the SUPD), which states:

‘Post-consumer plastic waste needs to be understood as waste generated from plastic products that have been placed on the market.’ 

The confirmation from the Commission clarifies what many R-PET market participants had already assumed – but not necessarily confirmed – that the 25% target can only be reached by using waste that has come from within the EU. It therefore rules out the use of plastic waste or material produced from plastic waste that has been placed on a market outside the EU.

FUTURE CHANGES
The Commission confirmed that it is currently preparing an implementing act, planned for Q4 2025, that will extend the calculation, verification and reporting methodology to cover all recycling technologies, including chemical recycling.

This will repeal and replace the existing act and contains a broader definition of ‘recycled plastic’ which will be the same as the Packaging and Packaging Waste Regulation (PPWR) and will cover recyclates ‘stemming from post-consumer plastic waste generated from plastic products that have been placed on markets outside of the EU’.

Article 7 of the PPWR sets out the 30% recycled content target for PET bottles by 2030, in which paragraph 3(a), among other things, states that recycled content shall be recovered from post-consumer plastic waste that:

“…has been collected within the Union pursuant to this Regulation or the national rules transposing Directives 2008/98/EC and (EU) 2019/904, as relevant, or that has been collected in a third country in accordance with standards for separate collection to promote high-quality recycling equivalent to those referred to in this Regulation and Directives 2008/98/EC and (EU) 2019/904, as relevant.”

R-PET market participants have welcomed the clarification although there are concerns that bringing the SUPD in line with the PPWR – in terms of allowing recycled produced from waste placed on markets outside of the EU – will open up the European market to cheaper imports of recycled material.

The Commission is currently drafting the methodology for calculation and verification of the PPWR’s recycled content targets due in December 2026.