The authors place their proposals in the context of geopolitical tensions and ongoing supply risks for fossil resources. At the same time, they describe the current economic crisis in the European chemical industry as a structural challenge linked to the fossil-based business model. In their view, lower electricity prices may support competitiveness, but they do not address the fundamental issue of long-term feedstock security.
According to the paper, Europe needs alternative strategies to secure carbon supply for the chemical industry. Alongside electrification and efficiency measures, renewable carbon is identified as a central requirement for industrial transformation. The position paper therefore proposes a stronger role for waste management as a feedstock source for the chemical sector. While this approach has been discussed in research and scenario studies for years, the authors argue that practical implementation is still limited, particularly due to regulatory barriers.
A core focus of the paper is the legal framework required to link waste management and the chemical industry more effectively. The authors describe both fields as operating largely in separate regulatory systems, with limited interoperability. They argue that without coordinated EU legislation, recycling-based feedstock strategies will remain fragmented and investment conditions for industrial transformation will remain uncertain.
To address this, the paper outlines ten measures intended to support step-by-step defossilisation of the chemical industry and to improve integration between waste and chemical legislation at EU level. The authors highlight that a broad range of recycling technologies will be required, depending on waste fractions and target products. The measures cover mechanical and physical recycling as well as chemical recycling pathways. The paper also includes options such as waste-to-energy with CO₂ capture and utilisation, where appropriate, to increase renewable carbon availability for industrial use.
The proposals build partly on existing EU instruments such as substitution quotas in selected plastics sectors. They also refer to regulatory approaches currently discussed at member state level. In addition, the authors recommend reviewing and phasing out selected rules that may hinder the development of recycling as a feedstock pathway. The paper emphasises that the measures are designed as a coordinated package, with interlinked steps and a phased implementation approach. The authors also state that their model could reduce administrative complexity by aligning regulatory objectives across sectors.
The publication concludes that the EU debate on strategic autonomy and resilience is gaining traction, including within current European policy priorities. However, the authors argue that implementation will require regulatory clarity and coordinated action to translate circular economy objectives into a functional feedstock strategy for the European chemical industry.
