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EU’s recycled plastic packaging strategy – explained

  • Packaging
  • Sustainability/Due diligence

Summary

The European Commission aims to accelerate the transition towards a circular economy for plastics by proposing a series of regulatory initiatives. The primary objectives are to increase recycling capacity within the EU, and to reduce the negative environmental impacts of the plastic industry. The key initiatives, which may also affect non-EU exporters, are as follows.

  • New “end of waste” criteria to allow plastic material not to be considered as waste when it is used in the manufacture of new goods.
  • A new methodology to calculate recycled content in single-use plastic beverage (polyethylene terephthalate, PET) bottles, allowing chemical recycling in addition to permitted mechanical recycling processes.
  • New customs codes to distinguish imports of virgin plastic from recycled plastics.
  • A review of the Single-Use Plastics Directive.

The EU’s strategy to boost use of recycled plastic packaging

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Accelerating Europe’s transition to a circular economy: a pilot for boosting the circularity of plastics

Update

The European Commission aims to accelerate the transition towards a circular economy for plastics by proposing a series of regulatory initiatives. The primary objectives are to increase recycling capacity within the EU, and to reduce the negative environmental impacts of the plastic industry. The key initiatives, which may also affect non-EU exporters, are as follows.

  • New “end of waste” criteria to allow plastic material not to be considered as waste when it is used in the manufacture of new goods.
  • A new methodology to calculate recycled content in single-use plastic beverage (polyethylene terephthalate, PET) bottles, allowing chemical recycling in addition to permitted mechanical recycling processes.
  • New customs codes to distinguish imports of virgin plastic from recycled plastics.
  • A review of the Single-Use Plastics Directive.

Background

The EU aims to transition from a linear economy, where products are made, used, and wasted, towards a circular economy that promotes the reuse of products and materials, and minimises waste and natural resource use. A circular economy is key to ensure that the EU reduces the intensive use of natural resources, stops biodiversity loss, and does not emit more greenhouse gas than it absorbs (climate neutrality) by 2050. This transition is part of the EU’s strategy to become more resilient and competitive.

In 2024, around 12% of the materials used in the EU were recycled or reused, the remainder being discarded (Eurostat 2025). The EU aims to double this amount to 24% by 2030 (Clean Industrial Deal 2025). To achieve this, in 2026 the EU will adopt a Circular Economy Act to harmonise the EU’s market for all recycled raw materials; increase the supply of high-quality recycled materials; and stimulate demand for these materials within the EU. This Act will be based on the second Circular Economy Action Plan (2020) that sets a sustainable product policy framework for different types of products and for food.

What is changing?

To accelerate the EU’s transition towards a circular economy for plastic packaging, the Commission has developed a strategy that includes the following initiatives.

Common criteria to identify when plastic is not waste

Specific EU legislation applies to plastic waste. When this waste is recycled and used to manufacture new goods, there is a point when it is no longer covered by the plastic waste legislation and is instead covered by legislation relevant to recycling operations and the manufacture of new goods.

The European Commission proposes new criteria (known as the “end-of-waste” criteria) that will allow recycled plastics to be no longer classified as waste and circulate more easily throughout the EU.

For more information, see Criteria defining when waste legislation stops applying to plastic waste.

New rules to calculate recycled plastic content in single-use plastic beverage bottles

The Commission proposes a methodology to calculate the recycled content in single-use polyethylene terephthalate (PET) bottles from all recycling technologies. This proposal extends the existing methodology for mechanical recycling (e.g. shredding and melting, Decision 2023/2683) to other recycling technologies, especially chemical recycling.

For more information, see Calculation of recycled plastic content in PET bottles.

New customs codes for recycled plastics

The Commission proposes to create separate customs codes for virgin and recycled plastics, including for food contact materials. Currently, all plastic and plastic products fall under the same Harmonized System (HS) code (Chapter 39) making it difficult for authorities to distinguish between virgin and recycled materials.

Review of rules for single-use plastic

In early 2026, the Commission collected evidence and feedback from a wide range of stakeholders, including stakeholders outside the EU, on their experience of the Single-Use Plastics Directive 2019/904 (SUPD). Operators placing packaged food or beverages on the EU market have had to comply with the SUPD since July 2021. PET bottles with a capacity of less than 3 litres must contain by 2025 at least 25% and by 2030 30% minimum recycled plastic.

The European Commission is evaluating the first years of implementation of the SUPD. The Commission is expected to publish the report by July 2027.

For more information, see Consultation on the Single-Use Plastics Directive.

Why?

Reusing plastic packaging through recycling is essential to reduce the negative impact of the packaging industry on the environment, including on greenhouse gas emissions and the pressure on natural resources. However, plastic recycling faces several challenges that hamper its development and discourage a shift away from virgin (unrecycled) plastic. These include low prices for virgin plastic and the high energy costs of the recycling process. Growth in the EU’s plastics recycling capacity has slowed, from 17% in 2021 to 10% in 2022 and 6% in 2023. The EU wants to ensure that it has the capacity to recycle enough plastic, as several laws – including the EU rules on packaging and packaging waste – require an increasing share of recycled content in plastics products over the coming years (see New EU packaging rules explained).

In 2026, the European Commission will propose a Circular Economy Act with additional measures to boost the use of recycled materials other than plastic.

What are the major implications for exporting countries?

Common criteria to identify when plastic is not waste: Under this proposal, non-EU operators supplying the EU food and beverage sector with recycled plastic packaging produced outside the EU will have to implement a quality management system according to the end-of-waste criteria.

New rules to calculate recycled plastic content in single-use plastic beverage bottles: Under the proposal, non-EU operators must:

  • provide a declaration stating the recycled plastic content of PET bottles with each batch of material exported to EU customers
  • keep declarations concerning recycled plastic content for at least 5 years
  • pass the declarations received from their suppliers along the supply chain to their customers in the EU (see Plastic (including recycled) food contact materials).

New customs codes for recycled plastics: Clearer HS codes will facilitate checks by EU authorities on imported plastics to ensure they comply with EU rules.

Resources

Online resources from the European Commission:

Eurostat (2025) Over 12% of materials in the EU come from recycling. News release, 19 November.

Sources

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Accelerating Europe’s transition to a circular economy: a pilot for boosting the circularity of plastics

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