Responses to consultations Archives

Evaluating the Single-Use Plastics Directive

As part of the Rethink Plastic Alliance (RPa), ZWE has co-drafted this response to the evaluation of the Single-Use Plastics Directive.
The Rethink Plastic Alliance calls to preserve and strengthen the Directive, which has already delivered clear environmental benefits, while avoiding a premature revision and instead focusing on improved implementation, monitoring, and regulatory stability.

Should a revision take place, we outline key priorities to reinforce its ambition and face the current gaps identified, including safeguarding definitions to prevent harmful material substitution, strengthening consumption-reduction and ban provisions, enhancing the prevention dimension of EPR by shifting funding toward reduction and reuse, and ensuring robust and credible rules on recycled content that promote genuine circularity, with ZWE contributing in particular to the latter two areas.

Response to the consultation | End-of-Waste criteria for plastics: Establishing an EU-wide framework

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the implementing regulation establishing EU-wide End-of-Waste (EoW) criteria for plastic waste.

The introduction of an EU-wide EoW framework for plastics is a positive and necessary step towards the development of a market for plastic recyclates in the EU. Currently, the low cost of primary fossil-based plastics and the variable quality of recyclates hinder such a development. Establishing EU-wide criteria can help address the situation. However, for the proposal to deliver meaningfully, it needs to be reinforced with stronger measures on chemicals, while supporting a broader vision for the circular economy that goes beyond recycling alone. Only by aligning waste, product, and chemicals legislation can Europe manage its resources strategically, close the loop, and ensure it remains closed and safe.

Available in English.

Response to the consultation | Aligning climate and circular economy objectives through an enhanced CBAM

As the European Union seeks to meet both climate and circular economy goals while boosting its competitiveness, the extension of the Carbon Border Adjustment Mechanism (CBAM) presents a unique opportunity to introduce financial incentives that simultaneously address carbon leakage and drive the transition toward a truly circular economy.

While the European Commission is preparing a Circular Economy Act announced for Q4 2026, the ongoing CBAM review offers a strategic pathway to integrate these two policy frameworks through market-based mechanisms that internalise environmental externalities. The current fragmented approach to environmental policymaking has largely overlooked the impact of absolute levels of resource consumption on climate, an omission that is increasingly dangerous as we continue to overshoot planetary boundaries.

Available in English.

Response to the consultation | Single-use plastic beverage bottles – EU rules for calculating, verifying and reporting on recycled plastic content

Zero Waste Europe provided feedback to the European Commission’s consultation on the implementing decision defining the methodology for recycled content as part of the Single-Use Plastic Directive (SUPD). The latter is the first of this type and will create a blueprint for other legislative pieces introducing recycled content targets for plastic, including within the packaging, automobile, and textiles sectors.

For the methodology to be relevant to the transition to a circular economy, it must ensure a high level of transparency and traceability, reward efficient technologies, and safeguard against greenwashing.

Available in English.