February 23, 2026 15:19
The European Commission has confirmed the rules governing the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles under the Single-Use Plastics (SUP) Directive.
The measure takes the form of a draft Implementing Decision approved on 6 February by the Committee for adaptation to scientific and technical progress and for the implementation of Directive 2008/98/EC (available in full in the attached document). The final version will be published in the Official Journal of the European Union.
As anticipated in recent days (read article), the document explicitly recognises chemical recycling as a technology complementary to mechanical recycling for treating plastic waste that is difficult or impossible to recycle mechanically.
PET derived from chemical recycling may therefore be counted towards the minimum recycled-content targets, subject to certain conditions, including allocation through a certified mass balance system. The ‘mass balance’ requirements are set out in Article 1 of the Annex. The key provision is the ‘fuel-use excluded’ clause, which prevents material destined for fuels and process losses from being counted.
Mass balance accounting is subject to a three-month time limit and must be carried out within each individual facility, with no possibility of transferring quotas between different plants or companies. The text also sets out rules for use in steam cracking, prohibits negative balances and requires full traceability of material flows (see Annex).
The Decision also confirms that, until 21 November 2027, recycled PET originating from non-EU countries cannot be counted towards the minimum recycled-content targets for bottles. After that date, two approaches will apply depending on the origin of the recycled material: recyclate from OECD countries may be counted, unless the Commission’s assessment identifies shortcomings in environmentally sound management.
Recyclate from non-OECD countries will be subject to stricter conditions. It may be counted only if agreements or arrangements with the EU are in place; the country of origin guarantees standards equivalent to the EU’s in environmental and health protection; it has a comprehensive waste management system; it applies schemes such as extended producer responsibility (EPR); and it can demonstrate the capacity to ensure environmentally sound waste management.
The document also provides guidance on broadening the calculation base for bottle weight to include closures, labels and sleeves. Any recycled plastic contained in labels and sleeves will also be counted.
It is clearly specified that, to be eligible, recycled plastic must originate exclusively from post-consumer sources, including packaging of products that have passed their expiry date before being sold to the consumer. Plastic generated during manufacturing processes, production scrap, processing waste, test residues and material stored or transferred prior to being placed on the market are explicitly excluded from the calculation.
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