The forthcoming calculation methods under the Single Use Plastics Directive (SUPD) are therefore of central importance. The way recycled plastic is defined for regulatory purposes will influence whether recycled content targets are met through European recycling operations or through material sourced from outside the Union.
A clear and enforceable definition of recycled plastic that recognises recycling carried out within the EU or under equivalent conditions would provide regulatory certainty for market participants. Such an approach would align recycled content obligations with European environmental, traceability and compliance requirements. In practice, this would support existing recycling infrastructure, facilitate long-term investment decisions and provide a stable framework for technological development in plastics recycling.
Over the past decade, European recyclers have invested substantially in high-quality bottle-to-bottle PET recycling capacity. These investments are now reflected in available data. Current assessments indicate that the EU has the technical capacity to meet recycled content targets using domestically recycled PET, without structural dependence on imports.
Preliminary estimates for 2025 indicate that approximately 3.3 million tonnes of PET bottles were placed on the EU market, while installed PET recycling capacity reached around 3.2 million tonnes. These figures point to a relatively mature recycling system, even before accounting for further efficiency improvements and recent capacity upgrades.
At the same time, capacity losses are increasing. Over the past three years, around 50 recycling plants have ceased operations. Capacity losses recorded for 2025 are almost three times higher than those observed in 2023, with PET accounting for roughly one fifth of the lost capacity. These closures reflect sustained competitive pressure on European recyclers, including competition from imported recyclates that may not be produced under environmental and traceability standards equivalent to those applied in the EU.
Price-based competition from imported recycled plastics does not reflect the cost structure faced by European operators, which includes higher energy, labour and compliance costs. Without a robust verification framework, it is not possible to ensure that imported recycled materials meet EU requirements related to product safety, environmental protection and consumer health. This raises concerns about fair competition and market transparency.
Although lower-priced imports may appear to reduce costs in the short term, there is limited evidence that these price advantages are consistently passed on to end consumers. Over time, continued pressure on domestic recyclers risks reducing European recycling capacity, employment and investment, while increasing dependence on external supply sources.
Within this context, the proposed definition of recycled plastic under the SUPD, included in the Commission’s Winter Package, represents an industrial policy instrument with implications beyond technical implementation. By linking recycled content obligations to recycling activities carried out within European or equivalent regulatory frameworks, the definition supports environmental integrity, reduces the risk of waste exports to lower-standard destinations and helps retain the economic value of recycling within the EU.
For EU Member States, supporting the implementing decision would contribute to maintaining industrial capacity in plastics recycling while reinforcing regulatory oversight and consumer confidence in recycled content claims. European and OECD-equivalent recycling systems provide the basis for verifiable origin, environmental controls and compliance with relevant EU legislation, including food contact requirements that depend on separate collection systems and certified pre-processing steps.
Delays or failure to implement the proposed definition would increase uncertainty for the recycling sector and could further weaken investment conditions. In a market environment characterised by global overcapacity and rising production costs, regulatory clarity remains a key factor in maintaining a competitive and resilient European plastics recycling industry.
