European Commission embraces problematic “chemical recycling” technologies despite their harmful environmental impacts and low yields 

At the end of 2025, the European Commission announced its Implementing Decision laying down rules for recycled content in single-use plastic beverage bottles, including chemically “recycled” content. The Implementing Decision was presented as part of the Commission’s Winter Package on the Circular Economy Act. The Rethink Plastic Alliance is deeply concerned by the Commission’s decision to allow the use of certain problematic, so-called ‘chemical recycling’ technologies to achieve the EU’s recycling targets. The text is the first full recognition of ‘chemical recycling’  – an umbrella term for several methods, among which are pyrolysis and gasification – under EU legislation, and can set a dangerous precedent for future legislation. It accepts credit mass balance for accounting recycled plastic content for the first time, based on the so-called ‘fuel-exempt method’ worsened by the introduction of the questionable concept of ‘dual-use output’ (1), giving a worrying direction for other EU legal acts.

With this implementing decision, companies will be able to claim they’re using more recycled plastic content without changing anything at all. But it isn’t magic; it’s a bad mass balance calculation based on the wrong method. This won’t encourage businesses to use more recycled plastic, nor will it increase circularity – only a truly proportional attribution of recycled plastic content can do that, and the Commission missed the opportunity.

Fanny Rateau, Senior Programme Manager at Environmental Coalition on Standards (ECOS) on behalf of Rethink Plastic

The Commission intends for the adoption of these rules to enable ‘chemical recycling’ in the EU, hoping that it will help economic actors meet the recycled content targets set under the Single-Use Plastics Directive (SUPD). However, the concept of ‘chemical recycling’ relies on deeply questionable technologies, which is why we had urged the Commission not to promote these technologies in our Rethink Plastic response to the EC consultation (2).

The Implementing Decision under the Circular Economy Winter Package repeals a previous decision on mechanical recycling (3), a long-established and well-suited technology for recycling PET bottles. Instead, it promotes ‘chemical recycling’, especially pyrolysis, even if it cannot treat PET because its oxygen acts as a poison for the process, or needs very high dilution with virgin naphtha and very energy-intensive cleaning processes. Pyrolysis and gasification (4) are characterised by low yield, poor efficiency,  high energy consumption, and greenhouse gas emissions. They should be considered as recovery technologies (5) rather than recycling, as the thermocracking of plastics in most cases turns said plastics into fuel, which then gets burned. 

For all these reasons, we call upon Member States to reject the adoption of this Implementing Act and invite the Commission to ensure the method is developed in support of the Packaging and Packaging Waste Regulation to help meet EU’s recycling targets based on less energy-intensive technologies, such as depolymerisation, and a more trustworthy mass balance method.

Notes to the Editor

1. ‘Dual-use outputs’ means outputs, other than losses, that can be reprocessed either into fuels or materials other than fuels;
2. Rethink Plastic Alliance feedback to European Commission’s consultation: https://rethinkplasticalliance.eu/wp-content/uploads/2025/08/SUPD-ID-RPa-consultation-answer-and-draft-for-partners-1.pdf 
3. Previous Implementing Decion on Mechanical Recycling from 2023: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023D2683&qid=1701421859795 
4. Fifty years: chemical recycling’s fading promise:  https://zerowasteeurope.eu/library/fifty-years-chemical-recyclings-fading-promise/ 
5. Chemical Recycling and Recovery:  https://ecostandard.org/publications/joint-position-paper-chemical-recycling-and-recovery/

Our Experts

• Zero Waste Europe
  Lauriane Veillard, Chemical Recycling and Plastic-to-Fuels Policy Officer | [email protected]
• ECOS – Environmental Coalition on Standards
  Fanny Rateau, Senior Programme Manager | [email protected]
• Rethink Plastic Alliance
  Caroline Will, Communications Coordinator | +32 456 56 07 05 | [email protected]

About Us

Rethink Plastic is an alliance of leading European NGOs, representing thousands of active groups, supporters and citizens in every EU Member State. We are part of the global Break Free From Plastic movement, consisting of over 13,000 organisations and individuals worldwide demanding an end to plastic pollution. www.rethinkplasticalliance.eu

ECOS – Environmental Coalition on Standards is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies, and laws around the world. We ensure the environmental voice is heard when they are developed and drive change by providing expertise to policymakers and industry players, leading to the implementation of strong environmental principles. www.ecostandard.org

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards a better use of resources and the elimination of waste in our society. We advocate for sustainable systems; for the redesign of our relationship with resources; and for a global shift towards environmental justice, accelerating a just transition towards zero waste for the benefit of people and the planet. www.zerowasteeurope.eu