Chemical Recycling Still Faces Regulatory Challenges in the EU

Chemical recycling of plastic is at a turning point in Europe, with several large projects poised to start but still facing regulatory and market challenges. As highlighted in the study recently published by consultants E-cube, regulations are playing a driving role in the sector’s development. 

Regulation (EU) 2025/40 of December 19, 2024, on packaging and packaging waste, the “PPWR”, sets ambitious requirements regarding recyclability and recycled content in plastic packaging. However, several key provisions of the PPWR still need to be clarified in upcoming implementing decrees, particularly concerning the “mirror clause”, which intends to allow non-EU recycled material on the EU market, provided such material is recycled in a facility abiding by environmental standards mirroring those applicable in the EU.

Sourcing of waste material will also be an issue in light of the growing demand and increasing prices for plastic waste in territories where waste collection and management are heavily regulated, and sometimes subject to stringent public tender procedures. Ongoing regulatory uncertainty makes negotiating long-term contracts necessary to secure sourcing especially difficult.

Finally, the end-of-waste status remains a major regulatory issue needing elucidation and harmonization throughout Europe. At this stage, a recycled product recognized as such in a member state may still qualify as waste in another member state, which triggers burdensome complications for the transport, marketing, and use of such products.