The European Commission (EC) has initiated a pivotal public consultation concerning a proposed draft act set to revolutionize the way plastic recycling content in single-use plastic beverage bottles is calculated, verified, and reported. This significant move, launched on July 8, 2025, aims to provide unparalleled legal clarity to European Union (EU) member states, enabling them to robustly implement existing EU regulations on single-use plastics and substantially boost the integration of recycled materials into the European economy, thereby mitigating plastic waste incineration and landfill impact.
The core objective of this draft act is to establish comprehensive rules that standardize the assessment of recycled plastic content. This initiative underscores the EC’s commitment to fostering a circular economy, where resources are utilized efficiently and waste generation is minimized. By setting clear guidelines, the EC intends to create a transparent and accountable framework that encourages greater investment and innovation in the recycling sector.
A notable aspect of the proposed legislation is its intent to repeal Commission Implementing Decision (EU) 2023/2683. The previous decision outlined the methodology for calculating and verifying recycled plastic content targets and the reporting format for beverage bottles. This new draft act signifies an evolution in regulatory approach, seeking to refine and update the existing framework to address contemporary challenges and technological advancements within plastic recycling.
Currently, under Regulation (EU) 2022/1616, only post-consumer mechanical recycling of polyethylene terephthalate (PET) and recycling from closed-loop product chains are recognized as suitable technologies for meeting recycled content targets. However, the new draft act acknowledges the need for broader inclusion, aiming to establish additional rules that would allow other innovative recycling technologies to contribute effectively to Directive (EU) 2019/904’s ambitious targets.
A critical innovation introduced by the draft act is the adoption of “mass balance accounting.” This sophisticated methodology, requiring substantial additions to the current framework, is designed to accurately track and allocate recycled content, especially from processes where recycled and virgin materials are mixed. This approach is crucial for integrating emerging technologies like chemical recycling into the mainstream waste management strategies, ensuring their contribution to recycling targets is properly recognized.
The draft act explicitly prioritizes recycling technologies that offer the greatest environmental benefits, emphasizing the reduction of negative impacts while considering the quality of the recyclate and economic viability. It articulates a preference for mechanical recycling, stating that waste suitable for this method should generally not be directed towards chemical recycling if mechanical processes can yield similar quality or performance characteristics.
Recognizing the dynamic nature of the recycling industry, particularly the scaling up of chemical recycling technologies, the draft act mandates a review of its methodology. This review will encompass the rules for allocating attributed amounts and aims to ensure alignment with provisions in Article 7(8) of Regulation (EU) 2025/40. This forward-looking approach ensures the regulatory framework remains adaptable and effective in promoting sustainable waste management practices.
