ECRN submitted its feedback to the European Commission on the draft Implementing Decision concerning the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles. The proposal aligns with the goals of Directive (EU) 2019/904 and represents a step forward in advancing Europe’s circular economy.
ECRN welcomes the initiative, particularly the integration of mass balance accounting (MBA) for chemical recycling, which it sees as essential for creating a harmonised, transparent, and traceable EU framework. The network stresses the need for clear definitions of “eligible material” and “attributed amounts” across recycling streams.
The feedback also highlights:
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Support for combining mechanical and chemical recycling, viewing them as complementary rather than competing approaches.
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The importance of including all bottle components—caps, labels, and sleeves—in recycled content calculations.
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The need to address harmful additives, calling for EU-level guidelines to promote safer, recyclable-friendly substances.
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Provisions that reduce verification burdens for SMEs, with recommendations for further support via funding, training, and technical assistance.
ECRN also urges the Commission to ensure digital traceability across Member States and to hold imported recycled materials to the same standards applied within the EU.
This contribution builds on ECRN’s broader advocacy for a circular and competitive chemical industry, as outlined in its recent Position Paper on Advancing Plastic Recycling in Europe.
