Recycling Industry and Environmental Associations urge EU Commission to correct SUPD Implementation

Joint letter warns of risks to the circular economy and to achieving environmental goals

A coalition of companies and associations in the recycling and packaging industry warns of risks to the European circular economy posed by the European Commission’s current draft of the implementing act on the Single-Use Plastics Directive (SUPD).

In a joint letter, the signatories –Werner & Mertz, ALPLA, REMONDIS and the associations BDE, bvse, VBS and VOEB – have addressed their appeal to the EU Commissioner for the Environment and other Commission members.

Their primary concern is the definition of “post consumer plastic waste” in the curent draft of the implementing decision. That definition is to be aligned in future with the one used in the Packaging and Packaging Waste (PPWR) Directive. According to the coalition, that decision would have serious consequences:

An alignment of the SUPD implementing decision with the PPWR without effective market-based safeguards would exacerbate the existing problems in the European plastic recycling industry.

European markets are increasingly exposed to imports of recyclate whose quality is doubtful and whose legal status as secondary raw material is not clear. Those imports, which are offered at dumping prices, lead to competitive distortions and replicate problematic practices previously seen in the textile sector.

Recycled content quotas under the SUPD and PPWR are intended to protect the environment and strengthen Europe’s resource sovereignty. Both goals are jeopardized by unregulated imports of low-grade recyclates.

The lack of reliable quality standards for imported recyclates leads to consumer confusion and diminishes trust in recycled content claims. The signatories therefore strongly advise keeping the definition of “post-consumer plastic waste” as stated in implementing decision (EU) 2023/2683. They suggest that an alignment with the definitions of the PPWR could be done if at the same time a legally binding mirror clause ensured that imported recycled materials had to meet the same quality and legal standards as those manufactured in Europe.

The signatories assert that the lack of clear rules threatens Europe and its recycling industry and weakens a central pillar of the circular economy. Furthermore, that would be a setback for the environment, climate and competitiveness.

The coalition asked the European Commisson and Member States to consider the competitiveness of the recycling industry in their upcoming discussions and not to endanger the ambitious climate goals of the EU.

You’ll find the joint letter here.

Werner & Mertz, ALPLA, REMONDIS
BDE – Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., Federal Association of the German Waste Management, Water, and Recycling Industry
bvse – Bundesverband Sekundärrohstoffe und Entsorgung e. V., Federal Association for Secondary Raw Materials and Waste Disposal
VBS – Verband der Bayerischen Entsorgungsunternehmen e.V., Association of Bavarian Waste Management Companies
VOEB – Verband Österreichischer Entsorgungsbetriebe, Association of Austrian Waste Management Companies