EU end-of-waste vote for recycled plastics: what packaging teams get

On 3 November 2026, EU member states voted in favour of harmonised end-of-waste criteria for recycled plastics. Of the day’s leads in our beat, this has the widest reach for anyone who buys, specifies or converts recyclate. This analysis, written on 8 November 2026, separates what the sources say from what we think it probably means.

A note on sourcing: much of the commentary comes from recycler and waste-industry associations, which favoured the criteria. They are the beneficiaries of the rules, so read their cost estimates as industry figures.

What happened, and what has not happened yet

Packaging Insights reports that member states voted in favour during a Technical Adaptation Committee meeting at the European Commission. Eco Plastics in Packaging dates the vote to 3 November, at the committee responsible for implementing the Waste Framework Directive.

The vote is not the end of the process. The criteria are to be adopted formally and published in the Official Journal, normally coming into force 20 days later. Packaging Insights adds that technical work began in 2022 and the criteria are expected to apply only around mid-2027.

Some web pages describe the rules as already applying from mid-2026. That contradicts the committee vote and the formal steps still pending, so treat those pages with caution and check the Official Journal.

What the criteria say, as far as reported

The text we have seen is the Commission’s draft, published with its 23 December 2025 package and open for feedback until 26 January 2026. We have not seen the final voted text, so the details below come from the draft and from reporting around the vote.

The draft covers thermoplastics. The proposed regulation covers thermoplastics recovered through mechanical or solvent-based recycling. Jones Day notes that chemical recycling and other types of plastic are not covered at this stage.

The requirements fall into three groups, per AGRINFO’s summary of the draft. On inputs, the plastic waste may not be hazardous waste and may not originate from healthcare waste or used absorbent hygiene products. Treatment and output quality follow, with a quality management system behind them.

Eco Plastics in Packaging reports one headline number: recycled materials must contain less than 1.9 per cent foreign materials by moisture-free weight. Foresight adds that, in the draft, a conformity assessment body or environmental verifier would assess the quality management system every three years.

Imports are covered too. The draft requires that non-EU suppliers of plastic from recycling facilities outside the EU implement a quality management system, verified by an accredited conformity assessment body or an environmental verifier.

Why the 1.9% threshold is contested

The threshold has been the main technical argument. FEAD welcomed the move to a single figure but questions the level, saying local demand exists for recycled plastics with more contamination than the proposed 1.9%.

The recycler associations EPRO and EXPRA argued in March that because of rounding conventions, the threshold effectively requires about a 25% reduction in permissible impurities against current operational reality. They add that for some input streams, especially household polyolefins, it may not be technically or economically feasible.

Our calculation: against the 2% limit discussed earlier, 1.9% is a nominal tightening of (2.0 − 1.9) ÷ 2.0 = 5%. The gap between that 5% and the 25% claimed by EPRO and EXPRA comes down to how foreign material is measured and rounded, which is why the measurement method matters more than the headline number.

FEAD also asked that recyclers be allowed to account for foreign material removed in the extrusion step, by direct measurement on the final product or by an abatement ratio. We could not confirm whether the voted text adopted that.

What this does not do for PPWR recycled content

End-of-waste status answers one question: when does recyclate stop being waste and become a product that can cross borders without waste-shipment paperwork? The PPWR answers a different one: what counts towards the minimum recycled content in plastic packaging. Our reading is that meeting the end-of-waste criteria is a likely precondition for easy trade in recyclate, but does not by itself make a tonne countable under Regulation (EU) 2025/40.

The PPWR counting rules are still open. RDC Environment lists the Article 7(8) implementing act on the calculation and verification methodology, due 31 December 2026. It also lists the Article 7(9) delegated act on sustainability criteria for recycling technologies, due the same date.

The minimums those acts will police are fixed in the regulation itself. They apply from 1 January 2030, or a set period after the Commission’s act, whichever is later.

PPWR minimum post-consumer recycled content in plastic packaging, 2030 and 2040. From 1 Jan 2030 (or later, see act timing): Contact-sensitive PET 30, Contact-sensitive non-PET 10, Single-use plastic beverage bottles 30, Other plastic packaging 35; From 1 Jan 2040: Contact-sensitive PET 50, Contact-sensitive non-PET 25, Single-use plastic beverage bottles 65, Other plastic packaging 65 (%) — PPWR minimum post-consumer recycled content in plastic packaging, 2030 and 2040
Source: Regulation (EU) 2025/40, Article 7

The chart shows the figures from Regulation (EU) 2025/40 as given in our background brief: for 2030, 30% for contact-sensitive PET, 10% for contact-sensitive non-PET, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. By 1 January 2040 these rise to 50%, 25%, 65% and 65%.

For beverage bottles, the Commission has already settled calculation under the Single-Use Plastics Directive. RDC Environment says that on 30 June 2026 the Commission adopted an Implementing Decision on calculating, verifying and reporting recycled plastic content in single-use beverage bottles (C(2026) 4381). S&P Global reported that it uses the fuel-use excluded approach for chemically recycled content via mass balancing. RDC Environment is explicit that it is not the PPWR methodology.

What it probably means in practice

The text says the criteria replace national rules with one EU set. In practice this probably means a recycler in one member state can sell end-of-waste recyclate into another without that country’s regulator re-judging its status. For buyers, the supplier’s quality management certificate and statement of conformity become the documents to ask for.

FEAD estimates, per Packaging Insights, that the lack of criteria costs EU plastics recyclers €120 million (US$134 million) a year. Packaging Europe put the same industry estimate at around €260,000 per recycler. Whether buyers see any of that saving in recyclate prices is unknown.

Plastics Recyclers Europe’s Mathilde Taveau flags a demand problem. Packaging Insights quotes her saying a principal challenge is that future recycled-content targets are not yet translating into sufficient demand today. Harmonised status removes a trade barrier; it does not create orders.

Role	What probably changes	Open point
Mechanical or solvent-based recycler in the EU	One rulebook across member states; a verified quality management system and statements of conformity become the route to product status	How foreign material is measured; audit costs for small plants
Importer or non-EU recycler	Imported recyclate faces a verified quality management system requirement in the draft	Which auditors will be accepted outside the EU (unconfirmed)
Converter or brand owner buying recyclate	Supplier documents to request and file; wider EU sourcing without national status checks	Whether grades with higher contamination remain tradable
Chemical recycler	Outside the criteria for now; national interpretations continue	Possible later extension; PPWR acts due 31 December 2026

Open questions

Final text. We have not confirmed whether the voted version differs from the draft on the threshold, the measuring point or the audit interval. The Official Journal text is the reference.

Chemical recycling. Cefic has urged harmonised EU-wide end-of-waste criteria for chemical recycling. Eco Plastics in Packaging says the Commission may review the regulation in future, potentially extending the criteria to chemical recycling, but no date is reported.

Review date. FEAD’s comments refer to a January 2029 assessment in the draft. If that review is retained, it is the first formal point at which the foreign-material limit could be revisited.

Food contact. End-of-waste status says nothing on its own about suitability for food contact. Our reading is that Regulation (EU) 2022/1616 on recycled plastic food-contact materials continues to govern that route, and Packaging Europe notes that stricter compliance documentation for imported recycled plastics is expected there.

What to watch next

Formal adoption and publication in the Official Journal, then the 20-day entry into force and the application date.
The PPWR Article 7(8) and 7(9) acts due 31 December 2026, which decide how recycled content is calculated and which recycling technologies count.
The Circular Economy Act, which Eco Plastics in Packaging reports is reportedly facing further delays.

What to do now

List every recyclate grade you buy and ask each supplier whether it is mechanical or solvent-based, and which member state’s national end-of-waste route it currently uses.
Request the supplier’s quality management certificate and the name of its conformity assessment body or environmental verifier.
Check your incoming specifications for foreign-material content, and how it is measured, against the 1.9% figure.
Flag SKUs whose recycled-content claim relies on chemical recycling or mass balance, since those depend on the PPWR acts due 31 December 2026 and sit outside these criteria.
Read the final Official Journal text when it appears. This analysis is information, not legal advice; confirm obligations in the official text or with counsel.

Sources

Header image: illustration, AI-generated.