Welcome to the first edition of the Rethink Plastic Alliance Newsletter! If you haven’t signed up yet, you can subscribe to our newsletter here to receive our quarterly updates on all plastics-related EU policy developments. 

Why did we bring back the RPA newsletter? Access to well-researched and digestible information on policy and the environment is more important than ever. We want to make sure that our reports, blog posts, and policy briefings reach all those who are interested, irrespective of changing algorithms and the political affiliations of platform owners. 

What can you expect from the newsletter? The newsletter will be released on a quarterly basis and will bring you up to date with all the latest developments on plastics in EU policy. It will feature all the latest news and publications from Rethink Plastic and our member organisations. 

So let’s dive right in!

Is the Packaging Regulation ready to be implemented?

The EU’s Packaging and Packaging Waste Regulation (PPWR)  already entered into force at the beginning of last year and will be a cornerstone of the EU’s aims to minimise the quantities of packaging produced and waste generated. The Regulation will apply from August 2026, but uncertainty around the interpretation of certain provisions of the PPWR was threatening to delay its implementation. In response to this, we welcome the European Commission’s publication of  guidance to provide the necessary clarity for consistent interpretation of the Regulation across Member States. Implementation must now proceed without delay, as that would risk undermining the Regulation’s objectives. 

Rethink Plastic published our initial reaction to the guidance with our take on the interpretation: 

✅ We commend the Commission for upholding the restrictions on PFAS in food contact packaging;

❌ We strongly disagree with the interpretation that plasticised paper-based packaging containing less than 5% plastic would fall outside the ban on single-use plastic packaging for indoor dining;

✅ We welcome the Commission’s reaffirmation of the obligation to establish deposit return schemes for single-use plastic bottles and metal beverage containers by 2029;

❌ We are concerned that the Single Market harmonisation rationale may be misused to excessively restrict the ability of national and local authorities to go beyond EU minimum requirements on waste reduction and reuse.

Evaluating the Single-Use-Plastic Directive – a flagship law that delivered clear, positive outcomes

Can you believe that it’s been seven years since the Single-Use-Plastics Directive (SUPD) entered into force? The SUPD addresses ten common highly polluting single-use plastic items to prevent and reduce the impact of these plastic products on the environment and human health. To evaluate the impact of this law, the Commission launched a public consultation at the end of 2025, which the Rethink Plastic Alliance responded to. The SUPD is where it all started for the Alliance and throughout the years, we have conducted several of our own evaluations across Europe. They all showed that, while implementation was not perfect, the SUPD had clear and significantly positive outcomes – notably through effective product bans and design requirements such as tethered caps, which have proven implementable, visible, and impactful in reducing litter and preventing pollution at source.

In our feedback to the evaluation, we stress that a broad revision of the directive would be premature at this stage. However, if the Commission does decide to revise the Directive, we recommend certain targeted improvements to ensure that any changes reinforce, rather than weaken, its environmental objectives and pollution-prevention measures. 

European Commission embraces problematic chemical “recycling” technologies

In December 2025 (on the 23rd, to be precise) the Commission published, a package of short-term initiatives with the aim of “boosting the circularity of plastics” leading up towards the Circular Economy Act foreseen for late 2026. An early Christmas present? Unfortunately, the package was quite a mixed bag. Next to some positive elements (more about those later), the package saw the Commission fully endorsing chemical “recycling” for the first time. Concretely, the Commission’s Implementing Act of the Single Use Plastic Directive now allows for chemical “recycling” technologies to be used to account towards the Commission’s recycled content targets for single-use plastic beverage bottles.

So what is the problem with chemical “recycling” (and why do we keep using “recycling” in quotation marks)? Chemical recycling is an umbrella term for several processes that change the chemical structure of plastic waste (check out our blog post and reports for in-depth information). Chemical “recycling” has been suggested as the magical solution to the recycling crisis by vested interests (read: petrochemical giants), but many of the actual technologies are wholly unsuited to actually recycle plastic. Take pyrolysis, for example, a process that changes chemical composition through exposure to extreme heat. Not only does it emit a staggering amount of greenhouse gases, but its yields are also very low. Most yields are so contaminated that they cannot even be used to create new plastics, but are instead used as fuel. That is why we insist that pyrolysis should be considered a recovery process rather than a genuine recycling technology (hence the quotation marks around “recycling”). By endorsing such problematic technologies, as well as embracing the questionable mass balance accounting and dual-use output approach, the Commission sets dangerous precedent for future legislation, enabling greenwashing around recycling. 

End-Of-Waste criteria: When does waste stop being waste and when can it be considered a product again? 

To support its transition to a circular economy, the EU wants to boost the use of waste-derived materials, also commonly referred to as “secondary raw materials”. In practice, this means that new products should preferably be made using recycled materials to reduce extraction of primary materials. This goal makes a lot of sense, especially when considering that out of the approximately 58 million tonnes of plastic currently produced in the EU, only half is collected and sorted, and only around 13% is recycled into new plastics.

But the transition from waste to a resource fit to be used in new products is not as simple as it sounds. This is why the Commission looked into the legal implications of this process as part of its December package. It proposed so-called  “End-of-Waste (EoW) criteria” to legally define the moment when a material ceases to be waste and becomes a waste-derived material that can be used as a product. This legal change matters: once a material is no longer classified as waste, but as a waste-derived material meeting EoW criteria, another regulatory framework – the chemical and product framework – applies. The legislative regime governing products is usually less restrictive than the one regulating waste. The Commission’s proposal has many promising elements, but as it stands, the proposal has gaps, especially on chemicals, which will undermine the long-term circular economy in Europe and beyond. If you want more information on all things End-of-Waste, you can check out our FAQ blog on the topic, as well as our RPA briefing. 

Towards an Ocean free from plastic pollution – Rethink Plastic’s recommendations for the Ocean Act

Over a decade ago the shocking images of marine pollution and its impact on marine wildlife caused outrage among people and kickstarted awareness of the plastic pollution crisis. While the harmful impacts of plastic pollution are not limited to the ocean, ocean pollution still remains a deeply concerning issue. As part of its Ocean Pact, the EU is currently working on an Ocean Act, a critical opportunity to align climate, biodiversity and maritime policies under a coherent framework. We submitted our Rethink Plastic recommendations to the public consultation, calling on the Commission to enshrine existing 2030 targets on reducing plastic litter and microplastic emissions, as well as to add new 2040 targets, in the Ocean Act.  We advocate for the Act to set an holistic and systemic approach to ocean governance and protection, with prevention and precautionary principles at its core. 

Quo vadis, Plastics Treaty?

While we still don’t know when and where the next session of the negotiation round for a Global Plastics Treaty will be held, the election of Julio Cordano as new Chair might help drive the stalled process forward. However, his election will not fix the process in itself, reflects David Azoulay (Center for International Environmental Law), who stresses the need for the process to make more frequent use of voting, rather than being blocked by consensus: 

“While electing a chair keeps the process alive, it won’t fix what’s broken in and of itself. (The February) session was once again dominated by the same delay tactics and obstruction that have bogged down the negotiations from the beginning. The negotiations are in desperate need of a reset. For years, a small handful of States have told us that consensus is the only way to make decisions — today proved that when it matters, governments can and will use all the tools of multilateralism available to them, including voting. No more delays and no more excuses — Members of the Committee must show willingness to deliver an ambitious, legally-binding treaty that tackles plastic pollution starting at the source.”

Towards a future free from plastic pollution!

Thanks for reading, we will be back in a couple of months with some more updates! In the meantime, follow us on LinkedIn and BlueSky and keep an eye on our website to follow developments on EU plastics policy.

Caroline, on behalf of the Rethink Plastic Alliance

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The EU’s Packaging and Packaging Waste Regulation (PPWR), published in January 2025, introduces essential measures to prevent and reduce packaging waste.

Without strong standards, weak enforcement, loopholes, or fragmentation across Member States could occur. To ensure that they best serve society and the environment, these standards must be developed collaboratively by diverse experts, including industry and civil society.

This resource was developed by our member organisation ECOS

Why are we talking about this right now?

On December 23rd, the European Commission published a proposal for the introduction of EU-wide End-of-Waste (EoW) criteria for plastics as part of an overall Package to Accelerate Europe’s transition to a circular economy, with a specific focus on the circularity of plastics. The package aims to answer Europe’s plastic recycling industry’s struggles, and defines a first set of measures to accelerate Europe’s transition to a circular economy. Further proposals are expected in the upcoming Circular Economy Act, which aims to create a Single Market for waste and Secondary Raw Materials. The EoW criteria proposal from December lays the groundwork for transitioning towards a European market for recycled plastics. But as it stands, the proposal has gaps, especially on chemicals, which will undermine the long-term circular economy in Europe and beyond. To address these gaps, the Rethink Plastic Alliance made concrete recommendations in our RPA response to the Commission’s consultation. 

What is the idea behind this proposal? 

To support its transition to a circular economy, the EU wants to boost the use of waste-derived materials, also commonly referred to as “secondary raw materials”. In practice, this means that new products should preferably be made using recycled materials to reduce primary materials extraction. Currently, of the approximately 58 million tonnes of plastic produced in the EU, only half is collected and sorted, and only around 13% is recycled into new plastics. One way to achieve this ambition to become the global circularity leader is to double Europe’s circularity rate in the economy to 24% by 2030, by first and foremost championing reduction and reuse measures and by facilitating recycling and the uptake of recycled materials. The current proposal aims to establish a single, harmonised set of EoW criteria to determine when waste ceases to be waste and facilitate the trade and uptake of recycled content. 

What is the legal significance behind the End-of-Waste criteria?

EoW is a legislative definition setting the moment when a material legally ceases to be waste and becomes a waste-derived material that can be used as a product. This legal change matters: once a material is no longer classified as waste, but as a waste-derived material meeting EoW criteria, another regulatory framework – the chemical and product framework – applies. The legislative regime governing products is usually less restrictive than the one regulating waste. For example, the trade of products, within the EU and outside the EU, is much less regulated than waste trade. 

What are the criteria to transition from waste to product? 

For the legal change to happen, the material has to meet four criteria defined under Article 6 of the Waste Framework Directive: 

1. The substance or object is commonly used for specific purposes
2. A market or demand exists for such a substance or object
3. The substance or object fulfils the technical requirements for the specific purposes andmeets the existing legislation and standards applicable to products; and
4. The use of the substance or object will not lead to overall adverse environmental or human health impacts. 

Such criteria are material neutral, and the EU has defined, for a number of materials,  more specific EU-wide harmonised criteria applying across the EU. The current proposal focuses on EU-wide criteria for plastics. 

What does this mean in practice?

• Setting the ground for a European recycling market – the proposal puts an end to the different national interpretations of EoW rules and unifies them at the EU level, which simplifies cross-border trade, supporting the setting-up of EU plastics waste-derived markets. 
• Reducing economic costs – without harmonised criteria, the additional administrative and compliance costs for the EU plastics recycling sector are estimated at around €120 million per year, or roughly €260,000 per recycler on average.
• Clarifying legal responsibilities across the value chain – by defining when waste becomes a product, the proposal reduces legal uncertainty along the value chain, which supports the development of the new markets.

What does this proposal cover?

The proposed EoW framework applies to plastic waste that was addressed by either mechanical recycling or solvent-based processes. These processes do not change the chemical structure of the plastic material. Technologies falling under the umbrella concept of ‘chemical recycling’ remain outside the scope of the proposal, reflecting the need to further assess their respective efficiency and added value to the circularity of the plastics sector. 

How does it impact waste trade?

Waste-derived materials granted EoW status can be traded, within and outside the EU, with far fewer controls than waste and waste-derived materials not granted EoW status. If EoW criteria are too weak or not effectively enforceable and enforced, certain operators could exploit EoW policy to misdeclare waste as a product and escape plastic waste trade regulations, including the upcoming ban on plastic waste exports to non-OECD countries. It is therefore essential to set strong criteria, including waste input restrictions and strict contamination limits, so that facilitating the trade of recycled materials does not undermine regulation on harmful waste trade practices. 

A broader perspective on circular economy: going beyond recycling

Taking this proposal into the broader context of its proposal (i.e. Mini Circular Economy Act Package), the EoW proposal aims at transitioning from 27 national recycling markets for plastics waste towards a single EU market. The deepening of the EU level is mirrored by the introduction of Trans-Regional Circularity Hubs, in line with the deepening of the internal market. However, for these hubs to fully deliver their potential to transition towards a circular economy, theyneed to embed other economic activities like reuse, repair, refurbishment, and remanufacturing. Reducing waste generation in the first place will support closing the circle and reducing pollution. 

Equally important and necessary in the transition towards a circular economy is to urgently tackle the issue of toxicity. In other words, it means that actions should be taken at the upstream level to remove hazardous chemicals already at the design stage. It is worth noting that there is currently a lack of coherence between chemical and circular economy legislation. In this case, EoW acts as an interface between chemicals, products, and waste, which could either bridge or deepen the gap between these three fields of legislation. Therefore, it is key to focus on managing toxic chemicals through an improved product’s lifecycle, to ensure products’ safety and high-quality recycling. 

For EoW to bridge the above mentioned gap, it is important that the proposal has strong criteria for eligible waste input. However, the current proposal largely focuses on the output of recycling processes, implicitly assuming that hazardous substances can be removed or neutralised during recycling. In reality, this is often technically unfeasible or regarded as too expensive. Furthermore, emphasising the output of the process could create a counter-incentive: instead of phasing out toxic chemicals at source, producers may rely on recycling to “manage” contamination downstream. For these reasons, it is key to act at the production stage to support the redesign of plastic products that will support safer and more cost-effective recycling, while improving the coherence between circular economy objectives and chemicals legislation.

Introducing an EU-wide EoW framework for plastics is a welcome and necessary development. An EoW framework promises real benefits for recyclers, but to ensure that this progress is lasting, the proposal must be strengthened and complemented by stronger action on chemicals and a broader vision of circularity that goes beyond recycling alone. Only by aligning waste, product and chemicals legislation can Europe truly use resources effectively and strategically,  close the loop—and keep it closed. 

Notes:

To know more about why setting clear, effective, and enforceable EoW criteria is essential to not undermine waste trade legislation, you can read this blog from our member EIA. 

In July, the European Commission launched a public consultation on its proposed rules for calculating, verifying and reporting recycled content in single-use plastic (SUP) beverage bottles. 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,  more and more studies show that chemical recycling is a problematic technology. In our Rethink Plastic response to the consultation, we urge the Commission to be careful not to create a precedent for recycled content targets that relies on these questionable technologies.  

Not all recycling processes are equal 

The landmark Single-Use Plastics Directive introduced recycled content targets for plastics for the first time in the EU legislation, establishing that by 2030, plastic beverage bottles should contain at least 30% recycled content. In a previous Implementing Decision, the Commission had established that these recycled content targets should be reached exclusively through the use of mechanical recycling technologies. The term “mechanical recycling” refers to the process in which plastic waste is collected, sorted, broken down into smaller pieces, and then turned into new products without changing its chemical structure. This technology is long-established and well-suited to recycle the most prevalent types of plastic beverage containers – PET bottles. While reduction and reuse measures must be at the heart of the EU policies, mechanical recycling does have a place in a well-functioning circular economy.

Chemical Recycling – too good to be true?

The Commission’s 2025 proposal, however, repeals the previous restriction to mechanical recycling and aims to promote “additional and innovative recycling” methods, in particular chemical recycling. Chemical recycling is an umbrella term for several processes that change the chemical structure of plastic waste. The different processes can be classified into two main categories: depolymerisation and thermocracking. Depolymerisation relies on a chemical reaction in which polymers are chemically broken down to monomers. The second category – thermocracking – is based on a heating process that affects the chemical composition of plastic waste and should be seen as a recovery process rather than as a form of recycling. In limited instances, this plastic waste can be used to produce new polymers and plastics, but in most cases, plastic is simply turned into fuel and then burned, releasing greenhouse gas emissions into the atmosphere. The two main types of thermocracking are gasification and pyrolysis.

Even though the Commission’s proposal heavily promotes “Chemical Recycling”, it does not actually define what it means by this. However, many of the provisions in its proposal appear to be referring to pyrolysis, suggesting that the Commission is promoting this technology. This is problematic because the low yield and high levels of emissions associated with pyrolysis make it closer to a recovery process than a genuine recycling technology. It is therefore ill-suited to help Member States reach their recycled content targets while its associated pollution endangers the EU’s transition to a clean and toxic-free circular economy. 

The many issues with Chemical Recycling

While the (petro-)chemical industry has been heavily promoting chemical recycling as a viable and sustainable technology to boost the circularity of plastic, the reality is that its capacity to actually create new plastics is severely limited, and the safety of the process is yet to be assessed. Furthermore, the negative environmental impact of thermocracking processes, such as pyrolysis and gasification, is immense. These processes require high energy inputs, while generating a lot of losses, and they emit, on average, nine times more greenhouse gas emissions than mechanical recycling and more, even, than almost all forms of primary plastic production. 

Given these concerns, the Rethink Plastic Alliance’s feedback urged the Commission to:

• Ensure recycled content only comes from post-consumer waste in line with the principle of effectiveness.
• Ensure consistency with other EU legislation, including on waste and chemicals. Concretely, this means:
  • Complying  with the definition of recycling as established under the Waste Framework Directive by removing the possibility of recovering materials, as well as removing the concept of “dual-use output” and the definition of “recycling pathway”;
  • Changing the definition of “chemical building blocks” to “intermediates” as defined under REACH;
  • Enabling proper chemical traceability along the value chain to ensure a safe circular economy;

Civil society participation weakened in the face of strong influence from chemicals industry

This consultation was launched in early July and closed in mid-August, giving stakeholders only a few weeks in the middle of the EU summer break to respond to its proposal. This timing is not conducive to effective participation, especially for civil society organisations who must often internally consult their members for input. To ensure the robust participation of civil society in EU decision-making, future consultations should run for longer periods and not take place during the traditional holiday period.

The proposal was published in the context of the Chemical Industry Action Plan and presented as an enabling factor for the chemical industry to facilitate the “transition to circularity by encouraging the use of alternative feedstocks and reducing dependencies on virgin fossil resources”. It seems that the primary goal of the Implementing Act is no longer to address the plastic pollution crisis. Instead, the goal is now to explicitly support the chemical industry. This development reflects the growing prominence and influence of the (petro-) chemical industry that we have been witnessing in the past year in decision-making related to the environment and health, and it is a cause for concern. 

Next steps

The Commission is now assessing the feedback it received from various stakeholders in the consultation and will send a proposal to Member States’ experts for approval. The Rethink Plastic Alliance will follow the evolution of this proposal closely and continue to engage at every opportunity.

What you need to know about the Global Plastics Treaty 

For almost two weeks, country delegates from around the world met in Geneva to attempt to finalize negotiations on a new Global Plastics Treaty. But following a fraught negotiating process heavily influenced by petrostates and the petrochemical industry, the negotiation collapsed without an agreement. The resumed fifth meeting of the Intergovernmental Negotiating Committee (INC-5.2) was adjourned, but ended without a clear agreement on the path forward.

Petrostates and the fossil fuel lobby sabotage the process 

The talks were effectively held hostage by the vested interests of petrostates and the petrochemical industry. Despite only being a small group of countries within the UN plenary, delegates from a handful of oil- and plastic-producing countries—Saudi Arabia, Russia, and the United States, among others–refused to compromise. Instead, they used delay tactics, procedural stonewalling, and flat-out refusal to engage in substance to derail progress and block any attempt at advancing an ambitious treaty. Their obstruction was reinforced by the unprecedented presence of fossil fuel and petrochemical lobbyists that flocked to Geneva  (234+ registered lobbyists by conservative estimates), outnumbering the combined diplomatic delegations of all 27 European Union countries and the European Commission combined (233 delegates). Unfortunately, their sabotage attempts were successful as the negotiations fell flat without agreement on a path forward. 

It wasn’t all doom and gloom

Despite the stalemate, we witnessed some encouraging developments and reasons for cautious optimism. Undeterred by the destructive efforts of petrostates, the majority of countries came together and reached stronger alignment. Discussion documents submitted by countries during the negotiation sessions, known as “Conference Room Papers”, show that there is now more convergence on the text, specifically on the key issues of production, chemicals and products, finance, as well as future decision-making. Moreover, a majority of countries supported a stand-alone article on health, reflecting wide recognition of the impacts of plastics on human health throughout their lifecycle. 

“Courage for your communities. You hold the power. You have the duty. Protect our children and our future.” 

Despite lack of space for meaningful participation, or even interventions, and restricted access throughout the process, civil society, scientists, Indigenous Peoples, frontline and fenceline communities, waste pickers and workers made sure their voices were heard. Since the beginning of this process three years ago, they have been instrumental in shifting the narrative on plastic pollution – moving from a narrow focus on marine litter to a widespread affirmation that plastic pollutes throughout its entire life cycle. Their presence in Geneva highlighted countries’ duty to place human health and human rights at the core of the treaty negotiations.

What role did the EU play? 

The EU played an indispensable role in Geneva as part of the group of ambitious countries that held the line on ambition, rejecting the watered-down draft texts presented by the Chair that would have rendered the treaty toothless. Its leadership played a vital role in ensuring ambition was kept alive on provisions around production, chemicals and health. But the task ahead demands even more. The EU must take a stronger role sitting at the table with emerging ambitious leaders like China, while recognising that its true strength lies in partnership and collaboration with the leaders from the Africa Group, Pacific group and the Group of Latin American countries who have carried ambition from the start. By combining bridge-building with concrete proposals, the EU can help deliver the strong and operational treaty the world urgently needs. 

Next steps unclear, but ambition must remain high

At the current moment, it is still unclear what the next steps in the process are. Another INC session may be convened, though it has become clear this could only be successful if the process is changed. Some call on ambitious countries to leave the UN process and to take the negotiations further with a “treaty of the willing” outside the UN context. No matter which avenue is chosen, the EU must stand united and work towards ensuring unity within the group of ambitious countries. It has a key role to play, building bridges and not creating unnecessary rifts between ambitious countries. It must take the initiative to make concrete propositions on how to move forward, including on defining a process that is truly operational and achieves the goal of agreeing on an ambitious treaty. 

Read more from our members: 

• Civil society perseveres in the face of a deeply flawed Plastics Treaty negotiations process and demands that countries take decisive action 
• Petrostates torpedo Global Plastics Treaty – profits over planet as talks collapse again – EIA 
• CIEL Staff React to End of Resumed Fifth Plastics Treaty Talks – Center for International Environmental Law 
• The Global Plastics Treaty: to be or not to be* – Zero Waste Europe 

Catching up on the Commission’s Chemical Recycling plans 

In July, the European Commission launched a public consultation on its proposed rules for calculating, verifying and reporting recycled content in single-use plastic (SUP) beverage bottles. 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,  more and more studies show that chemical recycling is a problematic technology. In our Rethink Plastic response to the consultation, we urge the Commission to be careful not to create a precedent for recycled content targets that relies on these questionable technologies.  

Not all recycling processes are equal 

The landmark Single-Use Plastics Directive introduced recycled content targets for plastics for the first time in the EU legislation, establishing that by 2030, plastic beverage bottles should contain at least 30% recycled content. In a previous Implementing Decision, the Commission had established that these recycled content targets should be reached exclusively through the use of mechanical recycling technologies. The term “mechanical recycling” refers to the process in which plastic waste is collected, sorted, broken down into smaller pieces, and then turned into new products without changing its chemical structure. This technology is long-established and well-suited to recycle the most prevalent types of plastic beverage containers – PET bottles. While reduction and reuse measures must be at the heart of the EU policies, mechanical recycling does have a place in a well-functioning circular economy.

Chemical Recycling – too good to be true?

The Commission’s 2025 proposal, however, repeals the previous restriction to mechanical recycling and aims to promote “additional and innovative recycling” methods, in particular chemical recycling. Chemical recycling is an umbrella term for several processes that change the chemical structure of plastic waste. The different processes can be classified into two main categories: depolymerisation and thermocracking. Depolymerisation relies on a chemical reaction in which polymers are chemically broken down to monomers. The second category – thermocracking – is based on a heating process that affects the chemical composition of plastic waste and should be seen as a recovery process rather than as a form of recycling. In limited instances, this plastic waste can be used to produce new polymers and plastics, but in most cases, plastic is simply turned into fuel and then burned, releasing greenhouse gas emissions into the atmosphere. The two main types of thermocracking are gasification and pyrolysis.

Even though the Commission’s proposal heavily promotes “Chemical Recycling”, it does not actually define what it means by this. However, many of the provisions in its proposal appear to be referring to pyrolysis, suggesting that the Commission is promoting this technology. This is problematic because the low yield and high levels of emissions associated with pyrolysis make it closer to a recovery process than a genuine recycling technology. It is therefore ill-suited to help Member States reach their recycled content targets while its associated pollution endangers the EU’s transition to a clean and toxic-free circular economy. 

The many issues with Chemical Recycling

While the (petro-)chemical industry has been heavily promoting chemical recycling as a viable and sustainable technology to boost the circularity of plastic, the reality is that its capacity to actually create new plastics is severely limited, and the safety of the process is yet to be assessed. Furthermore, the negative environmental impact of thermocracking processes, such as pyrolysis and gasification, is immense. These processes require high energy inputs, while generating a lot of losses, and they emit, on average, nine times more greenhouse gas emissions than mechanical recycling and more, even, than almost all forms of primary plastic production. 

Given these concerns, the Rethink Plastic Alliance’s feedback urged the Commission to:

• Ensure recycled content only comes from post-consumer waste in line with the principle of effectiveness.
• Ensure consistency with other EU legislation, including on waste and chemicals. Concretely, this means:
  • Complying  with the definition of recycling as established under the Waste Framework Directive by removing the possibility of recovering materials, as well as removing the concept of “dual-use output” and the definition of “recycling pathway”;
  • Changing the definition of “chemical building blocks” to “intermediates” as defined under REACH;
  • Enabling proper chemical traceability along the value chain to ensure a safe circular economy;

Civil society participation weakened in the face of strong influence from chemicals industry

This consultation was launched in early July and closed in mid-August, giving stakeholders only a few weeks in the middle of the EU summer break to respond to its proposal. This timing is not conducive to effective participation, especially for civil society organisations who must often internally consult their members for input. To ensure the robust participation of civil society in EU decision-making, future consultations should run for longer periods and not take place during the traditional holiday period.

The proposal was published in the context of the Chemical Industry Action Plan and presented as an enabling factor for the chemical industry to facilitate the “transition to circularity by encouraging the use of alternative feedstocks and reducing dependencies on virgin fossil resources”. It seems that the primary goal of the Implementing Act is no longer to address the plastic pollution crisis. Instead, the goal is now to explicitly support the chemical industry. This development reflects the growing prominence and influence of the (petro-) chemical industry that we have been witnessing in the past year in decision-making related to the environment and health, and it is a cause for concern. 

Next steps

The Commission is now assessing the feedback it received from various stakeholders in the consultation and will send a proposal to Member States’ experts for approval. The Rethink Plastic Alliance will follow the evolution of this proposal closely and continue to engage at every opportunity.

But how “clean” can the Commission’s plan really be if it fails to properly address one of the highest emitting and polluting sectors, and fails to consider toxicity and pollution? Addressing the petrochemical and plastic industry and preparing for a managed phase-down must be part of any serious plan to promote a “clean” European industry. 

The plan presented today does none of this, and coincidentally – or not -it was presented in Antwerp, the largest petrochemicals hub in Europe and the second in the world. It was launched in a closed-door event with some of Europe’s biggest polluters, including the biggest chemicals industry lobby, CEFIC. Civil society and communities that have to live every day with the pollution caused by these same industries, were not invited to the meeting. This is an affront to democratic and participatory processes, as well as the impacted citizens.

The Commission has accurately identified the need to decarbonise – and therefore reduce emissions – in key European industries, a crucial step towards reaching the EU’s climate targets and boosting EU competitiveness. Yet the proposal foresees hardly any action to curb Europe’s pollution and toxic contamination crises. In fact, it does not address one of the highest-emitting and highest-polluting sectors at all – namely the plastics and petrochemicals sector. 

By designing policies that reduce the production and consumption of plastics and petrochemicals, the EU can take a significant step toward curbing both pollution and GHG emissions, staying on track for its Green Deal commitments while also reaching its stated goals of decarbonisation and competitiveness. 

Plastic production is the most energy-intensive sector in Europe

Plastic polymer production is fueling oil and gas demand as 99% of plastics are made from fossil fuels such as oil, gas, and coal. Plastic production has seen major growth over the past decade. The industry’s current growth trajectory is exponential and plastic production is expected to double or triple by 2050. Plastic polymer production could consume up to one-third of the remaining global carbon budget by 2050, even in a decarbonized scenario.

In the EU, plastic production is by far the largest industrial oil, gas, and electricity user, even ahead of energy-intensive industries such as steel, automobile manufacturing, and food and beverages. In 2020, plastic production was responsible for nearly 9% of the EU’s fossil gas consumption and 8% of EU’s oil consumption. 

The plastic industry in the EU is looking at pathways to decarbonise its processes, but it is heavily relying on not-proven technologies, such as carbon capture and storage, and chemical recycling. Yet even if the plastic industry were to decarbonise its energy supply, that would not significantly reduce the emissions associated with the plastic industry as 70% of fossil fuels used in plastic production stem from raw material production rather than energy use for processing. Reducing the overall production and consumption of plastics and petrochemicals is the only way to significantly reduce the greenhouse gas emissions linked to plastics.

Plastic production – a pollution nightmare

Increasingly, the building blocks of plastic come from fracked gas in the United States. The pollution and impacts on communities associated with fracking are well evidenced, including water supply depletion, drinking water contamination, air pollution and habitat destruction.

In addition, many chemicals used in plastic production and products are known to be hazardous to human health and the environment, impacting workers and users. For example, exposure to PVC widely used in flooring, pipes, and medical devices, is associated with an increased risk of liver, brain and lung cancers. Several in-depth investigations have revealed the scale of the PFAS pollution crisis across Europe. Next to being an acute danger to public health and the environment, cleaning up this pollution will cost the staggering number of €100 billion each year. Microplastics, and the chemicals in them, reach everywhere in the environment and our bodies, with increasing evidence on the impacts associated. 

Why stick to single-use when innovative, cleaner solutions already exist? 

The majority of plastics produced are short-lived products and packaging, even though more durable and reusable options are available. At the end of their short yet very harmful life, these single-use plastics create further air, soil and water pollution through inadequate disposal and landfilling, as well as incineration. The plastics industry presents plastics as a circular material, promising recyclability. Yet most (single-use) plastics are not recycled, and contain hazardous chemicals that impair recycling, and end up incinerated. 

Even when recycling is possible it is not a closed-loop method as the addition of virgin materials is very often necessary, plastics can only be recycled a short number of times and are often downcycled in another product. Only 30% of plastic produced in Europe is actually recycled – and on a global level, only 9% of all plastics ever produced have been recycled. This shows that the “lifecycle” of plastics is neither circular nor clean and that drastic plastic production reduction is urgent for the EU to achieve its climate and zero-pollution objectives. 

What the EU can do to build a fossil-free, toxic-free and resilient Europe 

Europe, and the rest of the world, can drastically reduce its production and consumption of plastic in various sectors, as alternatives are already widely available.

Close to 40 % of plastic produced in the EU is used for packaging, most of which for  single-use applications, significantly contributing to the staggering 190kg annual packaging waste generation per inhabitant in the EU. The mainstreaming of packaging-free practices and reuse systems across the EU could drastically reduce plastic production and consumption associated with packaging. This is in line with the packaging waste reduction mandated by the recently adopted Packaging and Packaging Waste Regulation and would reduce emissions associated with plastic production and plastic and plastic feedstock imports.

To be “clean”, any deal must aim towards the zero-pollution ambition of the EU; this requires detoxifying production processes, products (including plastics), and our economy overall. Yet, the Clean Industrial Deal presented by the European Commission does not mention any intention to tackle (chemical) pollution, aside from referring to a future Chemical Industry package scheduled for the end of the year which appears to largely aim at giving the sector a significant boost. Instead, a strong implementation of the zero pollution action plan and Chemicals Strategy for Sustainability could actually move the EU further away from a toxic-free society. 

Reuse has always been part of life, in various forms, allowing products and packaging to be used multiple times for the same purpose. Mainstreaming reuse would maximise its benefits, including reducing resource use, water use, energy use and emissions, while bringing economic value and creating jobs. And we already know they work, because several EU member states have implemented well-functioning systems, for example in the shape of deposit return schemes. In line with the PPWR, member states should invest in the development of these innovative services – an opportunity that could create hundreds of thousands of jobs in the next few years according to the European Commission’s projections. 

A strategic use of resources puts an end to dirty deals

The EU imports most of the feedstock for plastic production, notably oil and (fracked) gas from the US and, until recently, a considerable amount of gas from Russia. Europe’s dependence on energy imports became painfully obvious in the wake of Russia’s invasion of Ukraine. Now, the threat of a “trade war” is looming over the EU and exposing its reliance on foreign imports once more. Reducing plastic production and consumption, by supporting the reuse economy, and improving toxic-free recycling, would also reduce the EU’s dependency on unstable partners and support its resilience. 

In a context where we have no other choice than to reduce our overall use of resources to remain within planetary boundaries, we have to find a strategic use of those resources. Producing millions of avoidable short-lived single-use plastics is not one. Increasing recycling and recycled content integration and substituting fossil-based feedstock with bio-based feedstock will not do the trick if it is not preceded with drastic reduction in plastic production and accompanied with a shift from short-lived and single-use to long-lasting and reusable products.  

There is no financial case for producing this much plastic

Data shows that petrochemical production in Europe has been stagnating, and in the case of plastics has shown signs of decline. This is due to a number of factors, among which are high energy prices, but it is chiefly caused by overcapacity, overproduction and a lack of demand. In addition, consumer attitudes are shifting away from single-use disposable plastic to more durable, less toxic options. 

Even though there is no business case for investments in the petrochemical and plastics sector, the Clean Industrial Deal foresees 100 billion-Euro-subsidies to energy-intensive industries. However, a new investigation reveals that these companies already have substantial access to capital. Their financial issues actually stem from a misallocation of resources. These companies, among which petrochemical producers BASF and TotalEnergies, are funneling the bulk of their profits – over 75% –  into shareholder payouts instead of investing in making their businesses fit for the green transition.

A “clean” deal should not fuel the profits of highly polluting corporations. Instead, the EU should support real solutions to protect the health of people and the planet.  

The EU needs to plan a just transition for the petrochemical industry

According to the industry itself, Europe’s petrochemical market share has been declining: this should be the EU’s opportunity to prepare for and initiate the transition of the petrochemicals and plastic sector in Europe and manage declining production and the already ongoing closure of facilities in a way that is just and fair, especially for workers. 

The plastic sector is a poster child of a model based on high resource use, high energy consumption, and intensive chemical use. It is at the intersection of the climate, waste, and pollution crisis, fueled by harmful subsidies and with major impacts on human rights. Yet, it can also serve as a model for a planned and just transition of an industry. By designing this transition with workers, communities, scientists and civil society, supporting reskilling and trainings, the EU has the opportunity to ensure a truly just transition.

Supporting plastic production reduction in Europe and on the global stage

Successfully managing the transition of the plastics and petrochemicals industry in Europe would reaffirm the EU’s support for plastic production reduction on the global stage. As part of a group of 100 countries, the EU and its member states supported a dedicated provision to control and eventually reduce plastic production in an international legally binding instrument, the Plastics Treaty. 

By supporting a strategic use of resources by industries through decarbonisation and reduction as well as regulating what is allowed to enter the EU market, the EU can significantly reduce pollution and harm to human health caused by plastic production, in Europe and elsewhere. Supporting reduction measures in the plastics and petrochemical sector could allow the EU to, once again, inspire a leveling up of environmental and social requirements across the world. 

Further Resources:

• The Clean Industrial Deal hides dirty concessions” – EEB press release
• Zero Waste Europe calls for stronger circularity measures in the Clean Industrial Deal 
• EU Clean Industrial Deal: Some opportunities with few guarantees
• Joint CSO and business demand A “Clean” Industrial Deal that works for the planet and its people  
• Clean Industrial Deal – ECOS recommendations 
• Can the EU’s Clean Industrial Deal Deliver for the Planet? – Center for International Environmental Law 
• EU Commission’s Omnibus proposal is full-scale deregulation designed to dismantle corporate accountability – Corporate Europe Observatory
• Lawyers condemn the Omnibus proposal – a threat to the environment and EU competitiveness | ClientEarth

Briefing by ECOS and Rethink Plastic. Brussels, Autumn 2024

Plastic has quickly become one of the most ubiquitous materials used in consumer products. Since the 1950s plastic boom, it has replaced steel in cars, glass and paperboard in packaging, cotton in clothes, and wood in furniture. Plastic is cheap to produce, persistent in the environment, and very versatile; it can be rigid or made to bend and stretch, and can be inherently durable.

The way we currently design, produce, consume, and dispose of plastic is, however, highly unsustainable and inefficient. It is crucial to rethink the place of plastic in our society, prevent the evergrowing pollution it generates as well as develop the necessary tools and initiatives to for a responsible approach to plastic. To minimise the environmental and health footprint of one of the most widely used materials in countless products, plastic requires a comprehensive ecodesign approach.

Plastics and polymers need to be included as an intermediate product in the first working plan under the EU Ecodesign for Sustainable Products Regulation (ESPR) – foreseen for early 2025. By prioritising plastics and polymers in the first ESPR working plan, the EU will take a major step in addressing the plastic pollution crisis, and work towards minimising the environmental footprint of plastic and polymer production.

EU Ecodesign for Sustainable Products Regulation framework

The new ESPR establishes a comprehensive ecodesign framework, giving the European Commission the authority to implement stricter sustainability requirements across various product categories. This regulation is a key tool to accelerate the European transition to a sustainable, toxic-free, and circular economy. Ultimately, the success of the ESPR will depend on its implementation, including many upcoming activities, secondary legislation, and the role of standardisation. Prioritising products and horizontal measures will reduce potential delays and ensure that the most polluting products are dealt with first.

The first working plan, covering at least three years, is expected to come out in the Spring of 2025. It will likely include the sectors, listed below, which were included in the ESPR text (Article 18(5)). The Commission has already carried out some preliminary work on these and other sectors, including plastics and polymers. The Commission is empowered to adapt the list for the first working plan, provided that it gives justification. The legislation specifies the following sectors to be prioritised:

• Intermediate products: iron, steel, aluminium, lubricants, and chemicals.
• Products: textiles (notably garments and footwear), furniture (including mattresses), tyres,
  detergents, paints, energy-related products, and ICT products/other electronics.

Plastics and polymers sector

Plastic has an outsized impact on human health and the environment (1) , yet the ESPR regulation did not specifically include the plastics and polymers sector as a priority for the first working plan.

The ESPR is intended to improve the environmental impacts of many different product streams and plastics is significantly present in many of them, e.g. paints, textiles, electronics, furniture. Plastics and polymers should therefore be addressed as an intermediate product to ensure these other products are well-designed from the foundation.

By prioritising plastics and polymers, the EU will take a major step in addressing the plastic pollution crisis, working to minimise the environmental footprint of plastic and polymer production. There are many reasons for addressing the plastic and polymer sector in the first working plan:

• It is projected that plastics production and consumption will grow considerably over the coming decades, with deleterious effects (2). By prioritising the sector under the ESPR, some of these impacts could be mitigated.
• It would align several EU policy priorities, providing regulatory certainty to an industry under much scrutiny. The Packaging and Packaging Waste Regulation (PPWR) will also create requirements for plastic products in delegated acts (delivered by 2028), including this sector under the ESPR will ensure that work is not unnecessarily duplicated.
• The EU and its Member States are playing a key role in the UN negotiations for an International Plastics Treaty – a new international legally binding instrument to address plastic pollution. By addressing the plastics and polymers sector under the ESPR, the EU will continue to take the lead in improving the environmental performance of this sector. Establishing performance and information requirements for plastics and polymers in the EU market would provide a roadmap for work at the global level.
• Other intermediate products will likely be addressed in the working plan, including the chemical sector, which has clear overlaps with plastics and polymers. It is therefore a unique opportunity to set up minimum requirements for plastics and polymers, which ECOS has advocated since 2019. There are drawbacks and risks associated with each part of the entire lifecycle of plastic. To minimise the environmental footprint of one of the most widely used materials, in countless products, plastic requires a comprehensive ecodesign approach.

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For a more comprehensive overview, read our position paper: Making the case for a holistic plastic strategy: Addressing polymers and plastics under the ESPR

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(1) The Minderoo-Monaco Commission on Plastics and Human Health, The Minderoo-Monaco Commission on Plastics and Human Health | Annals of Global Health, 2023.
(2) Global Plastics Outlook, Policy Scenarios to 2060. 3. Plastics use projections to 2060 | Global Plastics Outlook: Policy Scenarios to 2060 | OECD iLibrary (oecd-ilibrary.org), 2022

Community screening of the new film by Eleanor Church featuring a 3-week sailing expedition to the Great Pacific Garbage Patch on the hunt for microplastics, to find out about the sources and solutions to this global challenge.

The film will be followed by a questions and answers exchange with the public, with speakers including the film director, the European Commission, scientists and NGOs working on microplastics.

The screening is part of this year’s Ocean Week in Brussels, organised by Rethink Plastic members Seas At Risk, ClientEarth, Surfrider Foundation Europe, as well as BirdLife, Oceana and WWF.

Programme:

7PM: Screening of X TRILLION

8PM: Debate

Please note, tickets must be purchased on the Cinema’s website

Costs: €8 – €10

After yet another container loss, the shores of Galicia, Asturias and Cantabria (Spain), along the Atlantic coast, are under siege from a relentless tide of microplastics. Those small particles washing ashore are plastic pellets, which are the raw material used to manufacture all plastic items.

As a coalition of NGOs, we are raising our collective voice to call for action to stop this environmental catastrophe stemming from the systemic poor handling of plastic pellets throughout the value chain. And this can be achieved with the adoption of ambitious EU legislation.

The Galician NGO, Noia Limpa, was the first to sound the alarm, unveiling the shocking dimension of this plastic pellet pollution. The scale of this issue, resulting from a ship losing several containers at sea, is staggering. Out of over a thousand lost bags, over one hundred filled with pellets have already been found on the Spanish shore, each potentially containing up to a million pieces of plastic pellets. Some bags were torn and leaking small plastic particles – composed of polyethylene and UV stabilizers – into the environment. The greater concern is that the vast majority of the lost bags have not yet been found – they will either drift away and contaminate other regions or remain in the ocean and release their hazardous load.

Once in the ocean, pellets float widely, causing widespread harm to flora and fauna. Their small size makes them nearly impossible to clean up. Moreover, the pellets contain harmful additives, such as UV light stabilizers, and act as toxin magnets and transport mediums for toxic substances, adding to the risks posed to human health and the environment.

This crisis is not isolated to Galicia; it is a European and even a global problem. NGOs have been increasingly reporting plastic pollution cases for years, and as plastic production is expected to rise, this will only escalate dramatically.

This crisis is also not solely a maritime transport issue. It is an illustration of the careless handling of plastic pellets by an entire industrial sector. Plastic pellets are spilled at each stage of the value chain, from production and conversion sites to recycling installations and during transportation. In the European Union alone, an estimated 160,000 tons of plastic pellets are lost annually.

The current events only stress the need for bold EU measures to prevent this pollution and finally hold polluters accountable. It is appalling that, as of now, taxpayers are the ones bearing the cost of the countless incidents of pollution across the EU.

The good news is that European legislation is currently under review, following a proposal for a regulation from the European Commission tabled in October 2023. However, as it stands, the text will be too weak to make a significant difference. Shockingly, while being responsible for the Galician catastrophe, maritime transport is simply exempted from any requirements. Another major flaw is that smaller enterprises from the plastic value chain benefit from symbolic measures which will not be sufficient to prevent pellet spills.

The EU must urgently address this regulatory gap, and the culture of impunity must be crushed. An ambitious and comprehensive regulation is needed.  Thus, prioritizing prevention should be non-negotiable, and accountability for all pellet handlers must be a universal demand – irrespective of a company’s size or a mode of transport, maritime included.

Real change can only be achieved with Members of the European Parliament stepping up and showing political courage under the current mandate. With the EU elections happening only in a few months, current Members of the European Parliament will be judged on their ability to respond in practical terms to the problems faced by European citizens. The time for half-measures and empty promises is over; the citizens demand decisive action now.

We call on the European Parliament to step up in the fight against microplastic pollution by adopting a comprehensive and ambitious regulation.

Signatories