Plastics: recycling and secondary material markets

In December, the European Commission presented a package of measures aimed at supporting the EU plastics recycling sector and improving the functioning of the Single Market for recycled plastics. 

The initiative responds to mounting pressure on EU recyclers, including high energy costs, volatile virgin plastic prices and fragmented markets for secondary raw materials.

A central element of the package is the publication of a draft implementing regulation establishing EU-wide end-of-waste criteria for plastic waste under the Waste Framework Directive. 

The initiative seeks to define when recycled plastic ceases to be classified as waste and can be placed on the market as a secondary raw material. 

According to the Commission, harmonised end-of-waste criteria are intended to: 

• reduce administrative burden for operators 
• improve legal certainty, and 
• facilitate cross-border trade in recycled plastics

The draft regulation applies primarily to thermoplastic polymers and sets out detailed requirements for input materials, recycling processes and output quality.

It includes limits on foreign material content, obligations to implement certified quality management systems, and the use of statements of conformity for plastic recyclates.

The rules are designed to align with existing EU waste shipment restrictions and to prevent circumvention of export controls for plastic waste.

A level playing field

Alongside the end-of-waste initiative, the package also addresses level-playing-field concerns.

The Commission announced plans to introduce separate customs codes for virgin and recycled plastics and to strengthen monitoring of imports and exports, with a view to improving enforcement and market transparency.

Public feedback on the draft end-of-waste regulation was open from 23 December 2025 to 26 January 2026, with adoption expected later in 2026.

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