According to the EC, the European plastics recycling industry is facing an “unprecedented crisis”. Although recycling capacity grew by 17% in 2021, growth slowed to 6% in 2023 and a net decrease of one million tons of capacity is expected by the end of 2025, a figure equivalent to the entire recycling capacity of France.

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Short Term Measures: Pilot with plastic

The package of measures presented is structured in a two-stage approach, with immediate actions for the plastics sector serving as a testing ground for broader legislation.

The objective of this pilot is to alleviate the acute pressures facing the recycling industry and create an integrated market before the advent of horizontal laws.

• Market harmonization (“end-of-waste” criteria): The Commission proposes an implementing act for mechanically recycled plastic to cease to be considered “waste” and become “secondary raw material” under common European criteria.
• Boosting Chemical Recycling: The first “mass balance allocation” rules have been presented, allowing calculation of how much content recycled through chemical processes can be counted towards meeting the Single-Use Plastics Directive targets (such as 25% recycled content in PET bottles by 2025).
• Trade defense and customs control: To combat unfair competition, where imported virgin plastic is falsely sold as “recycled”, customs codes will be revised to prevent imported virgin plastic from being falsely sold as “recycled”.
• Transregional Circularity Hubs: A pilot will be launched to create hubs that leverage economies of scale, bringing together manufacturers, recyclers and waste operators to secure the supply of secondary raw materials within the EU.

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Forecasts and timeline for 2026

The year 2026 is shaping up to be the key moment for the institutional consolidation of the circular economy in Europe with the following milestones:

• Circular Economy Act: This will be the central legislative proposal of the year. Its purpose is to address structural barriers, create a Single Market for waste and encourage demand for circular products through horizontal measures that will go beyond plastics.
• Waste export ban: As of November 2026, a ban on the export of plastic waste to non-OECD countries will come into force to prevent the transfer of pollution to regions with lower management capacity.
• Relaunch of the Circular Plastics Alliance (CPA) with a joint work plan for 2026 and the initiation of a high-level competitiveness dialogue (first quarter).
• Presentation of the amendment to the Regulation on recycled plastics in contact with food and formal request for new specific customs codes for recycled polymers (second quarter).