The priority for the Rethink Plastic Alliance is to ensure that the evaluation of the Single-Use Plastics Directive (SUPD) further reinforces—rather than undermines—the ongoing environmental objectives and pollution-prevention measures. Overall, the Directive has delivered clear and 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. At this stage, a broad revision would be premature, as more time is needed to gather consolidated, harmonised, and comparable implementation data across Member States. Preserving regulatory stability, while strengthening monitoring and reporting, is therefore essential to preserve legal certainty, maintain investment signals, and safeguard the environmental benefits already set in motion.

Article 15 regarding the evaluation framework is oriented toward improving effectiveness—through the possible introduction of binding reduction and collection targets—indicating that any future revision should logically reinforce, rather than weaken the Directive’s level of ambition.

In this response, we identify priority gaps – in line with Article 15 – that must be addressed in case the Directive is revised, in order to strengthen existing achievements. These include:

• safeguarding definitions to prevent harmful material substitution,
• reinforcing consumption-reduction and ban provisions,
• improving design and marking implementation,
• strengthening Extended Producer Responsibility toward prevention and reuse,
• and delivering independent, prevention-focused awareness-raising.

Targeted improvements in these areas would support a future-proof evolution of the SUPD while safeguarding its core environmental ambition.

Previous Rethink Plastic and Break Free From Europe evaluations of the SUPD

The Rethink Plastic Alliance, together with the wider Break Free From Plastic movement, has carried out five in-depth yearly assessments of the Directive’s transposition and implementation across EU Member States, which all answer this question at different points in time. The most recent of these reports was published in December 2024. 

• The first report was published in 2019 to provide guidance for the SUPD’s transposition;
• The second report in 2020 checked its adequate transposition;
• The third assessment report in 2022 assessed its proper implementation on the ground;
• The fourth one in 2023 focused on the implementation of EPR for tobacco products;
• The last one in 2024 evaluated the effectiveness of measures and possible gaps that should be closed through the upcoming revision process.

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

The European Commission must protect the integrity of the Packaging and Packaging Waste Regulation!

We are deeply concerned by the potential reopening of the Packaging and Packaging Waste Regulation (PPWR) as part of the upcoming Environmental Simplification Omnibus. That’s why we joined a coalition of 115 signatories, consisting of trade organisations, industry and national associations, reuse businesses and leading European NGOs & environmental groups to call on Executive Vice-President Stéphane Séjourné and Environment Commissioner Jessika Roswall to protect the integrity of the PPWR.

The PPWR is a cornerstone of the European Circular Economy and is a crucial step in establishing the necessary framework that enables truly reusable and recyclable packaging across the Single Market by 2030. While the legislation had already been watered down in response to intense industry lobbying, it provides crucial measures to help tackle Europe’s ever-growing consumption of throwaway packaging by setting binding rules for prevention, reuse and redesign.

That’s why our message to the European Commission is: Do not reopen the PPWR and other key environmental laws in the upcoming Environmental Omnibus!

Reopening this core law, even for minor amendments, risks:

1. Further worsening the EU’s packaging waste crisis, harming the environment and human health
2. Creating legislative uncertainty for businesses
3. Delaying crucial investments in circular solutions
4. Undermining the Clean Industrial Deal’s goal to double the EU’s circular material use by 2030

We urge the European Commission to act responsibly and maintain key environmental provisions that protect EU citizens and our environment. European businesses must have predictability so that they can seize the opportunity to transition to a truly circular economy.

The Rethink Plastic Alliance is advocating for a Circular Economy Act that truly rises to the challenge and reflects the urgent need to reduce, reuse and recycle materials. Concerningly, the Call for Evidence suggests that the Commission’s main focus is on downstream measures. While we acknowledge and support the need to improve recycling in the EU, we are calling for a CE Act that accurately reflects the waste hierarchy and therefore also includes strong measures on waste prevention and reuse, while ensuring material loops are toxic-free.

In line with this, the Rethink Plastic Alliance urges the Commission to:

• Use a dual legal basis: Establishing a dual legal basis under both environmental and Single Market provisions of the EU Treaty (Article 114 and 192 TFEU) for the CE Act will preserve environmental integrity while improving the coherency of the EU Single Market.
• Introduce binding EU-wide material footprint targets: The CE Act should be used as an opportunity to significantly decrease the EU’s material and consumption footprints to bring them into planetary boundaries as soon as possible.
• Reduce the number of polymers in plastic: The number of poorly recyclable and harmful polymers has substantially multiplied and this is fundamentally unsustainable. We therefore call for a reduction of polymers used in virgin plastics with the aim of phasing out those that are most harmful and those that impede recycling and reuse.
• Mandate EPR to fund prevention, repair and reuse: EPR is a key source of funding for waste management in the EU but it fails to support more resource-efficient measures such as waste prevention, reuse, repair, refurbishment, and remanufacturing. The CE Act should reform EPR schemes so that they effectively promote the scaling-up of circular processes beyond waste management, including the establishment and development of reuse systems.
• Leverage public procurement as a driver for reuse: The CE Act must deliver on setting mandatory and impactful criteria for public procurement of circular goods. In particular, it should be done in a way that creates predictable demand for reuse.
• Restrict substances of concern in plastic: The CE Act must promote clean manufacturing and toxic-free material cycles. This includes ensuring that all chemicals in plastic products are used more safely and sustainably, minimising and substituting chemicals that have a chronic effect on human health and the environment, and phasing out the most harmful ones for non-essential societal use.
• Ensure high-quality recycling: The CE Act should promote the redesign of plastic towards more mono-materials and safer chemicals so that it can be mechanically recycled in a way that delivers high-quality recyclates. The two main technologies promoted under the undefined concept of “chemical recycling”, namely pyrolysis and gasification, should not be considered as recycling technologies. Rather, these inefficient and highly polluting technologies should be considered as chemical recovery and they should not be promoted under the CE Act as a sustainable solution to the plastic waste crisis.
• Tackle illegal exports of WEEE: The implementation of export bans needs to be improved and sufficient resources for enforcement in both exporting and importing countries should be ensured to address this problem, including inspections for stronger border control.
• Develop well-designed End-of-Waste criteria: We are in favour of the EU developing EU-wide End-of-Waste (EoW) criteria that ensure recycled materials are safe, traceable, and used within a closed regulatory loop. It is crucial that EoW criteria developed under the CE Act are well-designed so that they provide a single standard for recyclates quality, ensure alignment with chemicals and product legislation, and prevent circumvention of waste-trade controls.

After 2 years of negotiations, the Regulation on preventing pellet losses to reduce microplastic pollution has finally been formally approved by the European Parliament, paving the way for its publication in the Official Journal and entry into force in the coming weeks. 

As pellet pollution is a daily reality for citizens – such as in Tarragona (Spain) or Ecaussinnes (Belgium) – Rethink Plastic alliance (RPa) welcomes this long-awaited Regulation which we have advocated for over a decade (see the note to the editor below).  

The final regulation marks a significant step towards a concrete “Zero Pellet Loss” objective and follows a comprehensive supply chain approach, introducing measures on prevention, adapted packaging, staff training, mandatory certification of conformity issued by an accredited certifier for medium and large operators. 

By mandating annual reporting on pellet losses for both EU and non-EU carriers, the European Union sends a strong global message that compliance and accountability are essential to tackling this major source of microplastic pollution. 

Still, RPa is disappointed that Small and Medium Enterprises (SMEs) managing fewer than 1,500 tonnes per year per installation will fall outside the regulation’s ambition, facing only reduced obligations, such as a one-off certification five years after the regulation comes into effect. This represents a major loophole that risks undermining ambition in the new Regulation. 

Quotes: 

• “This Regulation is a long-overdue course correction – with this groundbreaking law, the EU is finally treating plastic pellets as the major microplastic hazard they are. For decades, producers and handlers have been unaccountable for billions of pellets lost into the environment. This Regulation sets out a vital benchmark for accountability, establishing binding supply-chain obligations to protect the EU’s land and seas. Yet loopholes and delayed implementation risk weakening its impact, allowing tonnes more pellets to slip through the cracks. We urge Member States and industry to deliver on the EU’s zero-pellet-loss ambition with decisive action and stop plastic pellet pollution at its source.” 
  Amy Youngman, Legal and Policy Specialist for the Environmental Investigation Agency 

• “It is a huge relief to see EU decision-makers unite behind a binding regulation with a set of specific measures to fight plastic pellet pollution on both land and sea. The Commission got it right by choosing a supply chain approach, ensuring a uniform implementation of prevention and clean-up measures. Including maritime transport was a welcome addition, likely driven by recent container ship accidents, although an unjustified 3-year delay is disappointing. It is high time such binding rules replaced existing voluntary initiatives to ensure pellets are finally treated as the hazardous pollutant they are, not just another cargo”.  
  Frédérique Mongodin, Senior Marine Litter Policy Officer for Seas At Risk. 

• The situation in Tarragona is a prime example of why clear regulation is urgently needed. Plastic pellet pollution doesn’t only occur during maritime transport – it’s also a chronic issue on industrial sites, where responsibilities are too often blurred between actors. After years of monitoring pollution on the ground and bringing this issue to decision-makers, we know that challenges will remain even once the regulation is fully adopted. We’ve documented pollution coming from small and medium-sized companies, and although EU decision-makers haven’t fully reflected this reality in the final text, the responsibility will now fall on national and regional authorities. If the rules themselves aren’t strict enough, the on-the-ground inspections will have to be. 
  Lucie Padovani, Marine Litter Lobbying Officer for Surfrider Foundation Europe. 

For the Rethink Plastic Alliance, this regulation must be considered a basis which gives an essential tool to EU Member States to reach a Zero Pellet Loss Ambition. It belongs to them to make it effective, powerful, and to strictly follow its implementation. 

Notes to the Editor: 

• Plastic production pellets, around five millimeters in size, are the building blocks of all larger plastics and constitute the third largest source of microplastic pollution in the EU. These pellets are known to accumulate, especially in the aquatic and marine environment, where they have significant negative impacts on wildlife and ecosystems. 
• Plastic pellet pollution occurs across all stages of the supply chain in the EU (Plastic Giants report & Plastic Pellet value chain visual). 
• As many as 184,290 tonnes of pellets are lost in Europe every year (Impact assessment report from the European Commission). 
• The exponential expansion of the production of raw plastic materials since 2005 has resulted in increased waste generation and over 170 trillion plastic particles in the world’s oceans. (Tiny Plastic, Big Problem. The Case for Preventing Pellet Pollution.) 
• As on of the many examples of plastic pellets pollutions: in December 2023, a pellet spill on the Galician coast showed firsthand how poor pellet transportation at sea can have catastrophic consequences. This, combined with mounting research linking microplastic contamination to human health risks and a petition supported by over 90,000 Europeans, activated parliamentarians, who voted 538 to 32 in favor of adopting binding rules, seizing a last opportunity to protect the planet and people from harmful and toxic pellet pollution. 

Chronology of the regulation

• 16 october 2023: Proposal of a regulation to prevent pellets pollution by the European Commission The text gives priority to prevention, mandatory certification, transparency in reporting but the scope is incomplete, containing too much exemptions, especially for SMEs (our reaction here) 
• 16 january 2024: Rethink Plastic Alliance sends an open letter to the Members of the European Parliament, urging MEPs to consider a regulation with a broader scope, irrespective of a company’s size or a mode of transport, maritime included. (see here) 
• 23 february: Members of Rethink Plastic Alliance brings MEPs on the ground to consider Pellet’s Pollution in Ecaussinnes, 50kms from Brussels (see here) 
• 19 march 2024: The European Parliament’s Environment and Public Health Committee (ENVI) adopts its position by supporting the Commission’s approach to regulating the supply chain and go the extra mile by including measures on maritime transport (our reaction here)
• 22 april 2024: in the last plenary session of its mandate, European Parliament adopt its position, a missed opportunity to tighten the regulation by choosing to exempt businesses that handle less than 1,000 tonnes of pellets a year from mandatory certification, audits and staff training. (our reaction here)
• 17 december 2024: Council of the EU adopts its General Approach: it includes binding measure for SMEs handling more than 1000 tons of plastic pellets per year but in the same time, it extends delays for many operators, including SMEs and maritime transport (our reaction here)
• 8 april 2025: End of trilogue, the European Parliament, the Council and the European Commission find an agreement. If it confirms a true supply chain approach, addressing spills and losses from all actors, EU and non-EU carriers, across all stages, the majority of SMEs are finally exempted from measures, such as independent oversights. (our reaction here) 

Link to the whole procedure file here 

We remain at the disposal of journalists for any comment. 

About Rethink Plastic Alliance 

Rethink Plastic is an alliance of leading European NGOs, with thousands of active groups, supporters and citizens in every EU Member State. We bring together policy and technical expertise from a variety of relevant fields, and work with European policymakers to design and deliver policy solutions for a future that is free from plastic pollution. We are part of the global Break Free From Plastic movement, made up of 11,000 organizations and individual supporters from across the world who are demanding massive reductions in single-use plastics and to push for lasting solutions to the plastic pollution crisis. 

Contacts 

For Rethink Plastic Alliance 
Caroline Will | +32456560705 | [email protected]  

For Environmental Investigation Agency 
Amy Youngman | +44 20 4549 9015 | [email protected] 
 
For Seas at Risk 
Louisa Gray | +32 486 11 06 67 | [email protected] 

For Surfrider Foundation Europe 
Lionel Cheylus | +33 6 08 10 58 02 | [email protected] 

Input from the Rethink Plastic alliance on the Commission’s initiative to simplify and streamline administrative requirements related to the environment in the areas of waste, products, and industrial emissions.

The priority for the Rethink Plastic alliance is to ensure that the policy measures devised under this simplification initiative do not undermine the environmental objectives pursued by the legislation
in question. We acknowledge and strongly welcome the statement in the Call for Evidence that the
goal is not to lower the EU’s environmental objectives or the protection of human health granted by
EU environmental laws.

However, we are concerned that removing certain databases or reporting obligations would indeed
have such a negative impact, and we wish to stress the importance of maintaining existing
obligations that meaningfully contribute to the EU’s high standards of environmental protection. In
this regard, we detail why it is important to maintain reporting obligations related to the SCIP
(substances of concern in products) database, under the Waste Framework Directive, and the
Waste Shipment Regulation.

At the same time, we are supportive of targeted simplification and harmonisation in cases where it
is clear that fragmentation across Member States is resulting in major inefficiencies and when
targets have proven to be ineffective. To this end, we make concrete recommendations for
targeted simplification of certain EU rules, namely rules related to Extended Producer
Responsibility (EPR) and the EU Landfill Directive.

Input to the public consultation on the draft Implementing Decision laying down rules for recycled content in single-use plastic beverage bottles, including chemically-recycled content.

Recycled content should only come from post-consumer waste. The SUPD was developed and introduced to prevent and reduce the impact of certain plastic products on the environment, and to promote a transition to a circular economy. Ensuring a proper waste management system, which contributes to a more efficient use of resources, is an essential enabling condition to prevent litter in the environment. Introducing mandatory recycled content targets for bottles was used as a tool for the uptake of secondary material.

The Rethink Plastic Alliance and the Environmental Paper Network welcome the opportunity to
provide feedback on the development of a new EU Bioeconomy Strategy. We urge the
European Commission to ensure that the revised strategy actively supports a truly circular,
regenerative, and ecologically sound bioeconomy. This includes ensuring ambitious alignment
with European and global objectives on packaging, ecodesign for sustainable products, and
nature restoration. In particular, this new strategy must recognise the risks of unchecked
expansion of bio-based material production, addressing the full lifecycle impacts of bio-based
plastics and paper, and prioritising resource sufficiency, ecological resilience, and social equity
over simplistic assumptions of renewability or carbon neutrality.

A new report, commissioned by the Rethink Plastic alliance, ECOS  and Zero Waste Europe, exposes serious methodological failures in a recent study by the European Commission’s Joint Research Centre (JRC) on plastics recycling technologies. 

The new report, “Scrutinising Scientific Standards”, authored by Dr Andrew Rollinson and endorsed by leading environmental groups, challenges the JRC’s central claim that it is not possible to establish a clear hierarchy among recycling technologies. In doing so, it pushes back against what campaigners see as a worrying erosion of scientific standards in EU policy development.

Dr Andrew Rollinson, author of the report, states:

“It is deeply disappointing to see the JRC retreat from the responsibility to guide policy with science. The study lacks transparency, omits critical life cycle impacts, and produces results that simply do not hold up against real-world data.”

The JRC’s study, released in January, was expected to provide a foundation for determining the most sustainable recycling technologies under the EU’s Circular Economy agenda. Instead, it delivers a confused and opaque analysis that avoids drawing clear conclusions.

Fanny Rateau, Senior Programme Manager at Environmental Coalition on Standards (ECOS), added: 

“The idea that we cannot rank recycling technologies simply doesn’t hold up. Mechanical recycling is clearly the better option, in terms of environmental impact. Failing to acknowledge this weakens the EU’s ability to set strong standards and it opens the door to greenwashing.”

The report warns that by equating fundamentally different technologies, such as mechanical recycling and energy-intensive chemical processes, the JRC risks misguiding investments into certain technologies while legitimising other technologies under the label of ‘recycling’.

Lauriane Veillard, Chemical Recycling and Plastic-to-Fuels Policy Officer at Zero Waste Europe, emphasised the broader policy implications: 

“This isn’t just a technical issue. Without robust definitions and a bounded system, a clear hierarchy cannot be established. This is needed to bring environmental and circular economy commitments together. We need the Commission to set the record straight.”

The new report calls on EU institutions to discard the flawed JRC findings and instead adopt clear, evidence-based recycling criteria that prioritise environmental performance and material recovery.

The full report is available for download on the Rethink Plastic, ECOS and Zero Waste Europe websites.

ENDS

Notes to the editor

For the full JRC study, see here: 

• García-Gutiérrez, Pelayo, Andrea Martino Amadei, David Klenert, Simone Nessi, Davide Tonini, Davide Tosches, Fulvio Ardente, and Hans G.M. Saveyn. 2025. “Environmental and Economic Assessment of Plastic Waste Recycling and Energy Recovery Pathways in the EU.” Resources, Conservation and Recycling 215 (April): 108099. https://doi.org/10.1016/j.resconrec.2024.108099.

Media contacts

• Rethink Plastic alliance
  Caroline Will, Communications Coordinator | +32 456 56 07 05 | [email protected]
• Zero Waste Europe
  Sean Flynn, Media Outreach Officer | +32 471 96 55 93 | [email protected]
• ECOS – Environmental Coalition on Standards
  Alison Grace, Senior Press & Communications Manager | +32 493 19 22 59 | [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