The European Commission is redefining what constitutes recycled plastic under the Single-Use Plastics Directive (SUPD). A strategic decision that could strengthen or weaken the European recycling industry.
The European Commission is currently working on defining the method for calculating the mandatory recycled content under the Single-Use Plastics Directive (SUPD). This seemingly technical process could lay the foundation for a new category of recycled plastic, “Made in Europe,” with decisive implications for the industry.
In a context marked by depressed prices, accumulated inventories, and strong pressure from low-cost imports, the scope of this definition will be crucial: Europe could consolidate a robust recycling ecosystem or, conversely, see its industrial capacity eroded in the midst of its transition to a circular economy.
A sector under pressure, despite Europe’s leadership in PET recycling.
Although PET is the second most recycled polymer in the European Union, the sector is going through a critical period. The combination of low prices, high energy and labor costs, and increased imports is jeopardizing the viability of numerous European recycling plants, precisely when they are key to meeting EU recycled content targets.
In this scenario, the definition of recycled plastic adopted by the European Union’s Sustainable Development Policy (SUDP) is not a simple regulatory adjustment, but a structural decision with far-reaching industrial, environmental, and strategic consequences.
Legal certainty and protection of European recycling
A clear, consistent, and robust definition of recycled plastic—one that prioritizes recycling carried out in Europe or under conditions equivalent to those of the EU—would send an unequivocal signal to the market. It reinforces the EU’s commitment to its circular industry, its climate objectives, and its economic resilience.
Furthermore, it provides the necessary legal certainty to protect existing capacity, foster technological innovation, and anchor long-term investments in European recycling, preventing distortions caused by competitive practices that are misaligned with EU standards.
Over the past decade, the European plastics recycling sector has made significant investments in bottle-to-bottle PET recycling infrastructure, which now allows the EU to have sufficient capacity to meet its recycled content targets using its own resources, without structural dependence on third countries.
However, this progress is under threat. Around 50 recycling plants have closed in Europe in the last three years, and the capacity loss projected for 2025 is almost three times that of 2023. PET accounts for approximately 21% of the lost capacity, highlighting the competitive pressure exerted by imports that do not always meet equivalent traceability, environmental control, and quality standards.
Imports, Verification, and Consumer Confidence
The financial appeal of low-cost imports often overlooks long-term sustainability goals and the reality of European operating and regulatory costs. Without robust verification mechanisms, there is no guarantee that these materials meet the same health, safety, and environmental protection requirements as those recycled within the EU.
In the medium term, this dynamic could weaken local recycling capacity, reduce industrial employment, stifle investment, and increase dependence on foreign sources, without the economic benefits clearly reaching the end consumer.
A strategic decision for European industrial policy
The proposed definition of recycled plastic included in the European Commission’s winter package constitutes, in practice, an industrial policy decision in an environment marked by global overcapacity, international competition, and increasingly stringent environmental requirements.
Anchoring recycled content obligations into European value chains strengthens environmental credibility, prevents the diversion of waste collected in the EU to markets with lower standards or its disposal in landfills, and ensures that the economic benefits of circularity remain within the European industrial base.
For Member States, endorsing this definition means reinforcing industrial sovereignty, climate ambition, and the commitment to a genuine circular economy, as well as ensuring green jobs and strengthening consumer confidence in recycled content declarations, under verifiable frameworks that comply with current European legislation.