Call for an ambitious Working Plan for the plastic recycling industry under the Ecodesign for Sustainable Products Regulation (ESPR)
On 19 and 20 February, the European Commission convened the Ecodesign Forum, its most ambitious stakeholder expert group in terms of size and responsibility, to define the sustainable requirements for large product categories in order to take a significant step towards sustainable product design and circularity in the European Union. The Working Plan of the ESPR, presented during the Ecodesign Forum, will define the priority product categories that will benefit from the development of sustainable requirements over the next 5 years.
The Commission just released the Clean Industrial Deal on 26 February, which includes circularity as a priority, with the aim of making the EU the world leader in the circular economy by 2030. The adoption of the Circular Economy Act by 2026 and the ambitious targets, such as doubling the circular material use rate (CMUR) from 11.8% to 24% by 2030, underlines the willingness to move quickly towards a circular economy and to make this shift a key part of European Union’s climate ambition.
Despite this ambition, the European plastics recycling industry is currently facing significant challenges that have led to a critical situation. In 2023, European production of mechanically recycled plastics fell by 7.8%, the first such decline since 20181. This decline is attributed to a lack of demand for domestically produced recyclates and increased imports of supposedly recycled plastics from third countries with less stringent environmental standards. As a result, many recyclers have been forced out of business, with numerous closures in 2023 and 2024.
Therefore, urgent action is needed to incentivise the uptake of recycled plastics produced in Europe and the EU should make use of all the tools at its disposal to increase plastics circularity in the EU, including the ESPR. While setting sustainable requirements for products placed on the EU market, the inclusion of post-consumer recycled (PCR) content in the ESPR is key to boost the circularity of products, ensure the uptake of recyclates, and therefore advance towards the CMUR 2030 target. The JRC, in its report aimed at supporting the design of the first ESPR Working Plan2, originally identified that ‘the consideration of a horizontal requirements on post-consumer recycled content could help increase the efficiency of ESPR requirements’ and proposed the plastic products scope under this requirement.
However, this proposal was not retained by the Commission and plastics were completely omitted from the ESPR Working Plan, sending a regrettable political message to the plastics recycling industry, which is in great need of support.
Recycled plastics are used in a wide range of sectors, from packaging and textiles to electronics, automotive and construction products3. A horizontal approach under the ESPR will ensure a uniform and consistent implementation of the PCR content across all product categories, thus providing the plastics recycling industry with predictability in the uptake of its secondary raw materials in new products and facilitating long-term planning and infrastructure development. Such approach would also ensure consistency with the establishment of mandatory PCR content provisions under recent or currently revised regulations, such as the SUPD, the PPWR or the ELVR. In addition, the ESPR is also the right framework to ensure that imported products comply with EU sustainability and environmental standards in a transversal and integrated manner.
Therefore, we urge the European Commission to take decisive action by incorporating post- consumer recycled content for plastic products as a horizontal measure under the first ESPR Working Plan. This integration is essential to ensure a harmonised and ambitious approach toward achieving the EU’s circular economy goals and reducing dependency on virgin fossil-based plastics.
1 Falling EU competitiveness threatens circular plastics transition • Plastics Europe
2 Ecodesign for Sustainable Products Regulation: Study on new product priorities
3 RMIS – Modelling plastic flows in the European Union value chain
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 20 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fuelling €5 billion of investments into the economy every year.
EuRIC is the voice of Europe’s recycling industries, representing 80 members across 24 EU & EFTA countries, and over 5,500 companies. We drive a 95 billion EUR contribution to the EU economy and support 300,000 green, local jobs. By turning waste into valuable resources and reintroducing materials into value chains, we are at the forefront of circularity and climate neutrality. As a catalyst in Europe’s green transition, EuRIC is driving the industrial shift that boosts EU competitiveness, resilience, and strategic autonomy.