Recommendations for amendments to the draft Implementing Act laying down rules for the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles

While FEAD has historically supported the ‘polymer-only’ allocation method, this document and the accompanying recommendations are framed within the version of the draft Implementing Act dated from 13 February 2024 and based on a ‘fuel exempt’ accounting approach.

FEAD’s recommendations emphasize the importance of a mass balance methodology that upholds transparency, traceability, and alignment with the goals of the Single-Use Plastics Directive (SUPD). These amendments advocate for precise definitions, and practical yet detailed reporting requirements. FEAD’s position focuses on ensuring that the mass balance methodology is applied only where physical traceability is lost, limiting reallocation to specific outputs that contribute to the circular economy.

By integrating robust operational controls and third-party certifications, FEAD seeks to guarantee the reliability of the calculation of recycled content and enhance trust across the value chain. These measures ensure alignment with Europe’s circular economy targets, promote sustainable plastic production, and provide clarity for economic operators while minimizing to the strict necessary administrative burdens.

FEAD’s position is rooted in advocating for a regulatory framework that respects the complexity and diversity of the European plastics value chain. Through these amendments, we aim to foster a level playing field that supports innovative recycling processes, maximizes the use of post-consumer plastic waste, and ensures that SUPD provisions drive meaningful progress toward a sustainable, circular economy.

Please find our recommendations for amendments to the draft Implementing Act laying down rules for the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles in the attached pdf.

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.