The following statement was submitted on 26 January 2026 to the European Commission’s call for evidence consultation on the EU-wide End-of-Waste (EpW) criteria for plastic waste.
Introduction
In response to the European Commission’s public consultation on the EU-wide End-of-Waste (EoW) criteria for plastic waste, this statement outlines the Climate Leadership Coalition’s (CLC) position on the proposed initiative. The initiative aims to strengthen the single market for recycled plastics and secondary raw materials, reduce administrative burdens for recyclers, and ensure a stable supply of high‑quality recyclates across the Union while advancing the circular economy.
Need for Harmonised EU‑wide EoW Criteria
CLC supports the introduction of EU‑wide, harmonised EoW criteria for mechanically recycled plastic waste. Common criteria are essential to eliminate the current uneven playing field and divergent interpretations that hinder investment and industrial scale‑up. Harmonised rules enhance market predictability, improve the quality of recycled materials, and accelerate the development of a competitive circular economy in the EU.
Today, differing national interpretations mean that the same material may be considered waste in one Member State and a product in another. This inconsistency slows cross‑border trade, complicates compliance, and undermines investment certainty. Harmonised criteria remove these barriers and ensure fair competition across the Union.
They also guarantee that recycled plastics meet consistent quality and safety requirements, increasing trust in recyclates and supporting the scale‑up of high‑value recycling markets. A system‑level perspective is needed to move beyond recycling only what is easy and to start building markets for materials that are currently discarded.
A level playing field should also be ensured in relation to operators outside the EU. For this reason, imported material should likewise be required to undergo testing.
The preparation of an EoW criterion for chemical recycling should also begin as soon as possible
Due to the significant differences between various recycling technologies, it is appropriate that mechanical (and physical) recycling has its own dedicated End‑of‑Waste (EoW) criteria. However, equivalent criteria are also needed for chemical recycling as soon as possible. Achieving the EU’s plastic recycling targets requires chemical recycling to complement mechanical recycling: by utilising both methods, the largest possible share of plastic waste can be returned to circulation while simultaneously reducing the need for virgin fossil raw materials in plastic production. The recycling industry needs clear, harmonised EoW criteria to ensure smooth movement of plastic waste and recycled feedstock within the EU internal market and to support the realisation of a circular economy.
However, the EoW criteria for chemical recycling cannot be based on those for mechanical recycling, given the substantial differences in processes and in the structure of the respective value chains. The current proposal therefore cannot serve as a precedent for the EoW criteria of other recycling methods. The EoW criteria for chemical recycling must take into account the method’s ability to process different plastic waste fractions compared to mechanical recycling, as well as the differences across the recycling value chain.
Excessive administrative burden should be avoided
However, the documentation, certification and quality‑management requirements applied to the criteria should be proportionate and not excessive. An overly burdensome administrative process could result in only large operators being able to comply, thereby weakening the position of innovative SMEs. There is also a risk that the end‑of‑waste status will not be used in practice if the process becomes too complex.
The testing frequency of recycled material should depend on the feedstock. When the input is similar in composition (for example, separately collected packaging waste), less frequent testing is sufficient. Testing should be carried out much more often when the material comes from mixed waste, such as plastics that may contain harmful substances.
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