Ensuring European plastics waste is recycled in Europe
European plastics waste that should be recycled in Europe is being burned, buried or exported instead. Not because recycling is impossible, but because it’s cheaper not to. This is one of the great paradoxes of EU legislation on waste and the circular economy. While there are references to waste hierarchy, proximity principles, and supporting the transition towards a circular economy, this theory is complicated to translate into practice.
Indeed, the linear economy, which is structured around the model of ‘take, use, throw away’ remains mainstream, making the transition to a circular economy, which favours a ‘reduce, reuse, recycle’ model difficult. As a result, there is a growing mismatch between circular economy legislation and economic incentives to transition to this system, which contributed to a loss of approximately 1 million tonnes of plastics recycling capacity between 2023 and 2025.
The causes of this loss are structural; the petrochemical industry, which produces plastics, is continuously (over)expanding. This expansion floods the market with virgin plastics, driving down their prices and making recycled plastics seem expensive in comparison. This price disparity means that there is no economic incentive to use recycled plastics, and thus no economic incentive to transition to a circular system, prompting fears of a plastics recycling ‘crisis’.
The European Commission has made an effort to increase the uptake of recycled plastics. The Single-Use Plastic Directive (SUPD) implemented recycled content targets at Member state level, which imposes the use of recycled plastics, making it more desirable and more commercially viable. The development of the plastics recycling sector began in Europe, and expanded to Asia, which is now the primary exporter of plastics recyclates to Europe. Although recycled content targets created a positive push for global circularity, it came at the expense of the proximity principle, which aims to ensure that those who generate waste are responsible for it.
Recycling European plastics waste in Europe would not only support the European plastics recycling sector but have a positive impact on circularity and the environment as a whole. The following actions are needed to ensure that waste is recycled locally:
1.Uphold environmental standards and the waste hierarchy
To make recycling the default-option for waste that cannot be avoided or reused, and to ensure we follow the waste hierarchy (a framework created to manage waste sustainably, and prioritise prevention, reduction and reuse) various incentives should be introduced. First, in order to increase economic incentives for plastics recycling, the European Commission should introduce waste incineration (burning waste) within the EU Emissions Trading System, a current proposal that is not implemented across the EU, and requires polluters to pay for the greenhouse gas emissions they produce.
This would highlight the real carbon cost of burning plastics waste and encourage this waste to be recycled instead by reducing the cost difference between the two operations. Additionally, enforcing the plastics waste export ban to non-OECD countries, due to take effect in November 2027 under the Waste Shipment Regulation, is non-negotiable. Europe cannot continue outsourcing the environmental, health and social costs of European consumption to third countries. Responsibility must stay where waste is generated.
2.Build a sustainable circular economy with toxic-free and transparent cycles
A sustainable circular economy only works if the materials circulating within it are toxic-free. This is especially important for food contact materials and other sensitive applications, where contamination is not an abstract risk but a direct public health concern. This is not a niche technicality, but the backbone of the circular economy transition.
The EU should continue to develop its commitment to toxic-free materials by expanding traceability and transparency measures. This requires following through with the implementation of the End-of-Waste framework, a criteria that decides when waste stops being waste and is again considered to be a product. The End-of-Waste framework should act as a quality gatekeeper before recycled materials re-enter the supply chain. A full application of the Digital Product Passport (DPP) should also be introduced, which would allow materials to be traced from their collection point all the way to the final product. This transparency is also necessary in trading practices. Currently, there is still no distinction between virgin and recycled materials as they are under the same custom code – making it virtually impossible to track what is actually moving across borders.
3.Harness recycling as a pathway to Europe’s strategic autonomy
The move away from incineration towards local waste management practices, including recycling, abide by the proximity principle, which would result in more than 20,000 jobs created in the EU.. Strategic autonomy has become a central priority in EU decision-making, and should be implemented across all sectors, including waste management. Supporting local recycling infrastructure is not just the right thing to do for the climate, it is also a way to support Europe’s strategic autonomy and industrial strategy.
What’s next?
The European Commission’s legislative agenda is still evolving and it is now increasing its support for the European recycling industry, as shown in the recently adopted SUPD secondary legislation. The upcoming Packaging, Packaging Waste Regulation (PPWR) secondary legislation on the equivalent rules for import of recyclates will be key. This, along with the upcoming incentives to support the development of the ‘secondary raw materials market’ as part of the Circular Economy Act (CEA), will play a crucial role in cementing this support. Zero Waste Europe will continue working towards the transition to a toxic-free circular economy by advocating for European plastics waste to be recycled in Europe.