Single-Use Plastics Directive – Public consultation on rules for calculating, verifying and reporting recycled content in single-use plastic beverage bottles.
Brussels, August 19, 2025 – The Extended Producer Responsibility Alliance (EXPRA) and the European Association of Plastics Recycling and Recovery Organisations (EPRO) have submitted joint feedback to the European Commission’s draft Implementing Act on the Single-Use Plastics Directive (SUPD). This important regulation sets the rules for calculating, verifying, and reporting recycled content in single-use plastic beverage bottles.
Both associations welcome the Commission’s efforts to establish a robust methodology and confirm their support for the credit-based mass balance approach as the method for calculating recycled content from chemical recycling processes. They also underline their support for a fuel-exempt allocation method to create the right framework for achieving the SUPD’s recycled content targets.
Key Points from EXPRA & EPRO:
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Definition of post-consumer plastic waste (Article 1):
The draft expands the definition beyond “placed on the European market,” potentially allowing materials from outside the EU to count towards EU targets. EXPRA and EPRO stress that this risks creating unfair competition for European recyclers and undermining EU recycling capacity. They call for additional safeguards to ensure SUPD targets drive investment in European-sourced recyclates. -
Calculation methodology (Article 7):
While supporting mass balance, EXPRA and EPRO highlight the need for detailed guidance and practical examples to ensure consistent interpretation across diverse chemical recycling processes. They welcome the review clause allowing adjustments as technologies evolve, and stress the need to distinguish clearly between recycled content and recycling rates. -
Verification & enforcement (Article 8):
Stronger enforcement is critical. EXPRA and EPRO call for robust verification and certification mechanisms, with checks at EU borders and oversight by EU-recognised auditing bodies. They also recommend EU-level guidance to ensure a consistent approach across Member States.
Call for Swift Adoption
Both associations emphasise that legal certainty is crucial to unlock investment in innovative recycling technologies. Given the scale of investment and time needed to scale chemical recycling capacity, rapid adoption of the SUPD Implementing Act is essential to support the transition towards a truly circular plastics economy.