EU Commission targets imported recycled plastics in new PPWR evidence call

We are in July 2026, and the European Commission has just launched a critical call for evidence that strikes at the heart of the Packaging and Packaging Waste Regulation (PPWR). With the regulation's general application set to begin next month in August 2026, Brussels is urgently seeking data to regulate the calculation, verification, and increasingly controversial use of imported recycled materials.

The European recycling industry has been navigating turbulent waters. Throughout 2024 and 2025, a flood of cheap imported recycled plastics forced numerous domestic recycling facilities to close or scale back operations due to a severe lack of profitability. Now, as the PPWR mandates strict post-consumer recycled (PCR) content levels—such as 10% for food-contact plastics by 2030 and 25% by 2040—the origin and authenticity of these materials have become a strategic priority for the entire packaging value chain, including paper and corrugated converters who rely on plastic barrier coatings.

The data gap in imported recyclates

The Commission's call for evidence is driven by a glaring lack of precise market data. When attempting to quantify the estimated annual volume of recycled content imported to the EU from third countries, or the exact proportion of plastic packaging placed on the market originating outside Europe, the industry faces a statistical blind spot. While we know the EU generated 79.7 million tonnes of packaging waste in 2023, and exports of plastic waste to non-OECD countries reached 66 million kg per month by May 2026, the reverse flow of PCR resins lacks granular, polymer-by-polymer transparency.

Industry analysts and trade data suggest that Southeast Asia and the Middle East remain the primary third-country sources for these imported recyclates. These regions often supply materials at price points that severely undercut European mechanical recyclers, raising persistent questions about the true post-consumer origin and environmental footprint of the imported resins.

Traceability and the demand for a mirror clause

To verify the origin, traceability, and recycled content of recovered plastics, the market currently relies on a fragmented ecosystem of chain-of-custody systems. Within Europe, standards such as EN 15343, RecyClass, and EuCertPlast are widely recognized as the benchmarks for rigorous traceability. However, for materials sourced globally, supply chains frequently depend on the Global Recycled Standard (GRS) or the Recycled Claim Standard (RCS).

The disparity in auditing rigor between domestic and imported materials has prompted organizations like EuRIC, alongside corporate alliances including Werner & Mertz and Alpla, to demand a strict "mirror clause." This mechanism would legally ensure that plastic waste collected and recycled outside the EU complies with the exact same environmental, social, and quality standards applied within the Union.

Three acts of regulatory scrutiny

The Commission has divided this consultation into three specific areas:

• Calculation and verification: Establishing robust methodologies to prove the exact percentage of PCR in packaging.
• Sustainability criteria for recycling technologies: Addressing the ongoing debate over chemical recycling and mass-balance accounting.
• Import conditions: Setting the legal framework for bringing recycled plastics or articles with incorporated recycled content from non-EU countries into the single market.

Stakeholders across the global packaging, paper, and printing sectors have until September 16, 2026, to submit scientific research, market analysis, and relevant data through the "Have your say" portal. The outcome of this consultation will directly shape the implementing acts of the PPWR, determining whether Europe's circular economy will be built on domestic infrastructure or reliant on offshore materials.

The Commission's move to scrutinize imported recyclates is a necessary reality check for the PPWR; without a level playing field, Europe risks offshoring its circular economy while bankrupting its domestic recycling infrastructure. If third-country imports cannot be rigorously verified for true post-consumer origin, should they be excluded entirely from counting toward EU mandatory quotas? Follow The Paper for daily news, market signals and key updates from the global paper, corrugated and packaging industry. — Sigue toda la actualidad del sector en www.thepaper.ai