On 23 December 2025, the European Commission put a priority on the table that is no longer just environmental for packaging: making recycled plastics competitive. The message is straightforward: if the market keeps rewarding virgin polymers (and if low-cost imports slip through weak controls), the circular transition risks remaining a promise. That’s why the Commission is advancing a set of measures that will feed into the Circular Economy Act expected in 2026, while tackling three immediate bottlenecks: market fragmentation, regulatory uncertainty, and unfair competition.
Why Brussels is accelerating now
The backdrop is a value chain under pressure: high energy costs, inconsistent demand for recycled content, and a price gap that often still favours virgin resin. In the European debate, import controls have also returned to centre stage. The concern, voiced in multiple forums, is that some materials declared “recycled” may in fact be virgin, taking advantage of the attractiveness of mandatory recycled-content targets.
The Commission’s own figures highlight how much ground remains to cover: with around 58 million tonnes of plastics produced in the EU, only about half is collected and sorted, and roughly 13% ends up as “new plastics” again.
EU-wide “end-of-waste” criteria for recycled plastics
The first initiative may sound technical, but it could be transformative: an implementing act to introduce EU-wide end-of-waste criteria for mechanically recycled plastics, allowing recycled material to circulate as a product (rather than as waste) more consistently across the 27 Member States. The stated objective is to create the conditions for a real Single Market for recyclates, reducing administrative burden and costs, especially for SMEs in recycling.
This is not a footnote. The Commission cites industry estimates suggesting that the lack of harmonised criteria generates additional costs of around €120 million per year for the European plastics recycling sector. According to the Commission note, the public consultation on the draft is open until 26 January 2026: a short window, but a critical one for anyone producing, converting or using recycled plastics in packaging.
Chemical recycling: more room (but with rules) to count recycled content
The second pillar is about de-risking investment in chemical recycling, by moving toward mass balance allocation rules, the accounting rules that determine what share of an output can be counted as “recycled content” for compliance purposes.
The immediate perimeter is the Single-Use Plastics Directive (SUPD): the Commission references recycled-content targets for beverage bottles (25% recycled PET by 2025 and 30% recycled content in all beverage bottles by 2030). In parallel, it notes that industry is planning up to €8 billion of chemical recycling investments “in the coming years”, provided the regulatory framework becomes clearer and more predictable.
Customs and traceability: separate codes for virgin vs recycled plastics
The third chapter is likely to matter more than many brand owners realise today: the Commission points to the introduction of separate customs codes for virgin and recycled plastics, aimed at improving the traceability and verifiability of what enters the EU market strengthening enforcement for customs and market surveillance authorities.
This is paired with additional monitoring actions in 2026 and the possibility, if evidence emerges, of assessing trade defence tools. In other words, recycled content is increasingly treated not only as a sustainability attribute, but also as a market integrity issue.
Rebuilding governance: relaunching the Circular Plastics Alliance
The Commission also intends to revitalise the Circular Plastics Alliance, with a 2026 work plan and a high-level dialogue to address the sector’s current difficulties and align priorities between institutions and industry from recyclate flows and demand, to market controls.
What this means for brand owners and converters in packaging
For packaging players, the key point is not simply “more rules”: it’s a shift in the centre of gravity. The Commission is trying to turn circularity into a Single Market, quality, and competitiveness agenda where data, documentation and verification will increasingly decide who wins (and who gets stuck).
Five practical implications to put on the Q1 2026 agenda:
- Track the end-of-waste file closely. If harmonised criteria go through, cross-border availability and movement of mechanically recycled plastics could improve materially.
- Get ready for “proof by documentation.” With tighter import controls and more granular customs classifications, traceability (material origin, declarations, certification) becomes part of risk management.
- Understand how chemical recycling will be “counted.” Mass balance rules can influence sourcing strategies and claims, especially in segments tied to bottle targets and food-contact discussions.
- Reassess PCR roadmaps. Between PPWR dynamics and existing targets, the Commission is signalling a push to strengthen confidence in recycled plastics via clearer quality and market rules.
- Engage with consultations. The consultation window until 26 January 2026 on end-of-waste criteria is one of those rare moments when industry input can shape rules that will affect costs and time-to-market for years.
