On 8 July 2025, the European Commission released a new Draft Implementing Decision on the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.
This act under the framework of the Single-Use Plastics Directive (EU) 2019/904 aims to provide a methodology for the calculation of the recycled content of PET bottles made from materials that have been either mechanically recycled, or chemically recycled. The methodology is accompanied by certification obligations as well as an enforcement system.
While an act addressing mechanically recycled PET was already adopted back in 2023 (Implementing Decision (EU) 2023/2683), chemical recycling was not included at that stage – the adoption of an act addressing chemically recycled PET was subject to more hurdles. A first attempt at addressing chemical recycling was made in a draft Implementing Decision from February 2024, which was withdrawn following opposition notably from the European Parliament’s ENVI Committee.
This new attempt maintains general principles from the previous February 2024 version – the choice to rely on the “fuel-use exempt” mass calculation model is included, but with many more specificities for when reattribution of credits is allowed. The restriction on reattribution between different facilities of a company or between different companies is maintained.
Modifications compared to the previous draft on the other hand include the introduction of “calculation points” with a view to adapt the method of calculation to the different stages of the supply chain concerned. The first point, where the input material is present in a liquid form, is thereby distinguished from other points down the line.
The Commission further explicitly confirms the possibility to rely on the use of post-consumer recycled materials coming from outside the EU.
The draft act is currently subject to a public consultation that runs until 19 August 2025. Should the process go swiftly, the act could be adopted by the end of 2025.