In July 2025, the European Commission published a new draft Implementing Decision establishing the practical application of Directive (EU) 2019/904 – the so-called SUP (Single-Use Plastics) Directive – with regard to the calculation, verification and reporting of data on the recycled plastic content in single-use plastic beverage bottles.
Among the key updates: the inclusion of chemical recycling as a recognised technology for determining recycled plastic content. This move marks a significant step forward for materials innovation in the beverage packaging sector. The new proposal also repeals Implementing Decision (EU) 2023/2683, making way for a more up-to-date and inclusive approach.
Chemical recycling: a strategic complement to mechanical recycling
As highlighted in Recital 5, the Commission acknowledges the role of chemical recycling in processing plastic waste that is difficult or impossible to recycle mechanically. This technology can deliver higher quality recycled materials with superior technical performance. However, it is emphasised that mechanical recycling remains the environmentally preferable option when it can provide sufficient material quality and performance.
New rules for calculating recycled content
The proposal introduces specific methodologies for calculating recycled plastic content in the different parts of beverage bottles:
- Mechanically recycled PET used in the bottle body should be calculated in accordance with Regulation (EU) 2022/1616;
- Components such as caps made of chemically recycled polyolefins may be accounted for using the mass balance accounting method (Recital 14).
The choice of recycling technology should aim to minimise environmental impact, while also considering required material quality and economic feasibility. Mechanical recycling remains the preferred option overall, yet the Commission recognises the importance of staying responsive to technological advancements – including the commercial-scale development of chemical recycling – and has committed to reviewing the methodology in light of future progress.
A changing landscape
The recognition of chemical recycling represents a strategic shift for the packaging industry, which must now align innovation, regulatory compliance and environmental responsibility. This new proposal reinforces the EU’s vision of a technologically advanced and inclusive circular economy, where each recycling method has a clearly defined role within a regulated, transparent, and results-driven system.
