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EU sets rules on recycled plastic content in disposable plastic bottles

Time：

2026-03-30

The European Union has issued a notice to standardize the calculation, verification, and reporting rules for the content of recycled plastics in disposable plastic beverage bottles (with a focus on PET bottles), and to abolish the EU Implementation Decision 2023/2683.

On March 9, 2026, the European Union issued a notification G/TBT/N/EU/1195 through the WTO, standardizing the calculation, verification, and reporting rules for the content of recycled plastics in disposable plastic beverage bottles (with a focus on PET bottles), and abolishing EU Implementation Decision 2023/2683.

Definition of recycled plastics and related products

Recycled plastics:

Only plastic waste generated after consumption and obtained through recycling (including sorting). Recycled plastics that meet environmental standards in OECD member countries and those from non OECD countries that have signed environmental agreements with the EU can be included after November 21, 2027.

Post consumer plastic waste:

Waste generated from plastic products that have been put on the market; Pre consumption waste generated during the production process is not included, and expired unsold product packaging is considered as post consumption waste.

PET bottle:

Disposable plastic beverage bottles (capacity ≤ 3L) mainly composed of polyethylene terephthalate, including bottle body, bottle cap, label, and bottle cover (non plastic components account for ≤ 5%, not affecting accounting), excluding plastic caps for medical special food bottles and glass/metal bottles.

Qualified materials:

Post consumer plastic waste and its derivative materials, as well as intermediate materials that have not been re polymerized in chemical recycling, are all classified as such.

Import verification and accounting requirements

Verification requirements:

Verification by a third-party verification agency recognized by the European Union is required. Regular enterprises are required to conduct on-site verification once a year, while small and medium-sized enterprises are exempt from conducting verification every three years. The verification content includes supply chain risk analysis, authenticity of accounting data, rationality of qualified material allocation, consistency between accounts and reality, etc. After verification, a certificate of EU mutual recognition will be issued.

Verification of imported materials:

Member states shall verify the accompanying accounting and verification documents of recycled materials imported from third countries to ensure compliance with the requirements of this regulation.

Accounting rules:

Select the corresponding accounting method (direct accounting or quality balance accounting) based on the type of recycling technology (mechanical recycling, chemical recycling), clarify the accounting nodes, and ensure accurate calculation of recycled plastic content. Mixed recycling needs to be accounted for separately according to the nodes.

Subject obligations:

Provide EU customers with a declaration of the regeneration content for each batch of products, and retain the supplier's declaration and compliance evidence for at least 5 years; Non polymer raw material/output processors are required to establish a complete accounting system and retain relevant vouchers.

Geographic scope and time nodes

Plastic waste export ban:

Starting from November 21, 2026, the European Union will ban the export of plastic waste to non OECD countries until May 21, 2029; Non OECD countries can apply for exemption.

Third country recycled plastic accounting time:

Starting from November 21, 2027, recycled plastics that meet environmental standards in OECD member countries can be included in the EU target. Non OECD member countries are required to sign environmental agreements with the European Union and meet standards such as extended producer responsibility and increased plastic recycling rates.

Effective Date:

The new regulations will come into effect on the 20th day after they are published in the official gazette of the European Union.

It is recommended that relevant export enterprises improve their compliance system, establish a sound accounting, data retention, and document management system for recycled plastic content, and ensure that the recycled content declaration and verification documents for each batch of exported products are complete and valid, with a retention period of no less than 5 years. Optimize product structure, increase the upgrading of mechanical recycling technology, reasonably layout the research and development of chemical recycling technology, improve the quality of recycled PET, and pay attention to the progress of EU environmental protection agreement negotiations. Strengthen customer communication, communicate new regulations and requirements with EU customers in a timely manner, confirm product accounting standards, verification processes, and document requirements, and avoid trade cooperation being affected by cognitive differences between supply and demand sides.

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