FEAD feedback to the evaluation of the Single Use Plastics Directive
FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to provide feedback on the evaluation of the Single-Use Plastics Directive (SUPD). From the perspective of waste management and recycling operators, the SUPD has played an important role in stimulating demand for recycled plastics, notably through the introduction of recycled content targets for beverage bottles. These provisions have helped create a more stable market for recycled PET and supported investments in recycling infrastructure.
At the same time, the European plastics recycling sector is currently facing significant economic challenges. In recent years, numerous recycling facilities across Europe have closed due to declining competitiveness of recycled plastics compared to virgin polymers and insufficient demand for recycled materials. This situation threatens the viability of European recycling capacity and risks undermining the EU’s circular economy and climate objectives.
In this context, the evaluation of the SUPD provides an important opportunity to strengthen policy signals supporting the use of recycled materials, reinforce the Directive’s contribution to circularity and improve its implementation.
Strengthening demand for European recycled plastics
The recycled content requirements for PET beverage bottles introduced by the SUPD have played an important role in creating demand for recycled materials and supporting investments in recycling capacity.
However, considering the scale of the current plastics recycling crisis in Europe, the existing targets may not be sufficient to support the recycling industry and ensure that adequate European capacity will be available to meet the 2030 targets. The evaluation should therefore assess the feasibility of increasing the 2030 targets and introducing intermediate targets before 2030, which would provide stronger and more predictable demand signals for recycled plastics and help stabilise investments in recycling infrastructure.
In addition, the effectiveness of recycled content obligations depends not only on the level of targets but also on the credibility of their implementation and enforcement. Currently, the implementation of recycled content obligations takes place at Member State level, which may lead to uneven uptake of recyclates by producers of SUP beverage bottles across the EU. The responsibility for meeting recycled content targets should therefore be clearly placed on the operators placing products on the market, at product level. This would facilitate implementation while ensuring level playing field between packaging producers and accross Member States.
Furthermore, enforcement mechanisms and penalties for non-compliance currently differ significantly across Member States. The evaluation should therefore consider the introduction of clear, dissuasive and harmonised sanctions for non-compliance with the recycled content targets, ensuring a harmonised enforcement of the targets across the EU and preventing regulatory fragmentation.
Most importantly, the evaluation should ensure that recyclates used to meet SUPD recycled content targets originate from post-consumer plastic waste that has been collected, sorted and recycled in Europe (EU, EFTA, UK). The European recycling sector currently faces increasing competitive pressure from imported recyclates produced under conditions that may not reflect the same environmental, climate and social requirements as those imposed on European operators. At the same time, the export restrictions for plastic waste to non-OECD countries introduced under the revised Waste Shipment Regulation will soon enter into force, leading to a greater share of plastics waste being treated within Europe and potentially increasing the availability of material for European recycling.
In this context, it is important to encourage the uptake of European recyclates and ensure that recycled content targets effectively support the development of domestic recycling capacity. The approach proposed in the Implementing Act on the calculation and verification of recycled content for PET bottles under the SUPD, which mandates to use plastics recyclates sorted and recycling in Europe to fulfill the recycled content targets, represents an important step in this direction and should be extended to 2030 for all targets of the SUPD. Without appropriate safeguards, recycled content targets risk being met through imports that do not contribute to strengthening Europe’s recycling capacity or the EU’s circular economy objectives.
Improving the functioning and transparency of EPR schemes
Extended producer responsibility schemes play a central role in financing the collection, sorting and treatment of single-use plastic waste. While FEAD has developed a comprehensive position on the harmonisation and improvement of EPR schemes in the context of the future Circular Economy Act (see here), several provisions specific to EPR schemes for plastic waste could significantly improve the management and recycling of these materials.
First, EPR fees should fully cover the costs associated with waste management operations. In practice, waste management operators often face situations where EPR contributions do not adequately reflect the real costs of collection, sorting, recycling and residual waste treatment linked to single-use plastic products. Ensuring full cost coverage is essential to guarantee the proper functioning of waste management systems, support investments in recycling infrastructure and avoid shifting the financial burden to municipalities or taxpayers.
In addition, EPR fee modulation should be used more effectively as a tool to support the transition to a circular economy. Eco-modulation should create clear economic incentives for producers to design products that are easier to recycle and that incorporate higher levels of recycled materials. Producers incorporating higher shares of recycled plastics in their products should benefit from lower contributions, while products relying entirely on virgin plastics should face higher fees. Such differentiation would encourage producers to go beyond minimum regulatory requirements and stimulate additional demand for recycled materials.
Finally, greater harmonisation of eco-modulation criteria at EU level would significantly improve the effectiveness of EPR schemes. Currently, modulation practices vary widely across Member States, creating fragmentation and limiting the impact of these mechanisms on product design decisions. Establishing common EU-level principles and criteria for eco-modulation would help ensure a level playing field for producers, increase the predictability of EPR systems and strengthen their contribution to circular economy objectives.
Strengthening separate collection systems
High-quality recycling depends on efficient and well-performing separate collection systems. The SUPD already establishes collection targets for beverage bottles, requiring Member States to ensure high collection rates for recycling. However, performance across Member States remains uneven and further improvements are needed to ensure that sufficient quantities of high-quality plastic waste are made available for recycling.
The evaluation should therefore identify ways to strengthen and harmonise separate collection systems across Member States, including through improved collection infrastructure where appropriate.
In conclusion, the evaluation of the SUPD provides an important opportunity to reinforce demand for European recycled plastics through stronger and more predictable recycled content targets, ensure credible and harmonised implementation of these obligations, and guarantee that recycled content requirements effectively contribute to strengthening European recycling capacity.
In particular, the evaluation should also consider enhancing separate collection systems and increasing transparency and effectiveness of EPR schemes. By addressing these issues, the Directive can continue to play a key role in supporting the development of a competitive and sustainable European plastics recycling sector.
FEAD and its members remain available to further contribute to the evaluation process and to share practical insights from waste management and recycling operators across Europe.
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 21 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 500,000 local jobs, fuelling €5 billion of investments into the economy every year. For more information, please contact: info@fead.be