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ELV Plastics: Targets, Tension and Opportunity

John Mortell, Senior Policy Manager at Plastics Europe, discusses how proposed recycled plastic content targets in new ELV regulations could reshape investment, drive circular plastics, and test competitiveness across Europe’s automotive value chain, highlighting infrastructure needs, support for smaller recyclers and urgent, coherent policy to unlock circularity at an industrial scale.

Portrait of a bearded man in a blue suit and glasses, Senior Policy Manager at Plastics Europe
John Mortell

How will the proposed 15% recycled plastic content targets in the ELV regulations reshape investment strategies across the vehicle plastics supply chain?

What we see so far is a discussion between three proposals – the Commission’s original proposal, which includes 25% recycled plastic content targets with a 25% closed-loop requirement, and the Parliament and Council texts. It is still unclear exactly where the final targets will land. While the Council suggests starting at 15%, it quickly moves to 20%, and both the Parliament and Council suggest reaching 25% after 10 years. The final agreement could easily see a 20% target after 6 years, with 25% after 10 years.

The bigger questions, in many ways, are exactly which plastics are included, how high the closed-loop target will be, and whether bio-based plastics will also play a role. 

From our perspective, the proposal is a key one for helping plastics transition away from a solely linear economy, while helping drive investment in Europe and promoting circular plastics use in a major sector. Competitiveness and Circularity are not in conflict; with the right policy choices, they can be mutually reinforcing. The window of opportunity to restore our competitiveness and stimulate the necessary investment in circular infrastructure and innovation is narrow, and the time for bold policy action is now.”

According to Plastics Europe’s ‘The Plastics Transition’ roadmap, the European plastics system has the potential to reduce greenhouse gas emissions by 28% by 2030 and reach net-zero by 2050, with circular plastics meeting up to 65% of European demand by mid-century. However, realising this vision requires significant and sustained investments in circular infrastructure and innovation.

Investment in European recycling infrastructure and innovation should be encouraged to ensure high-quality and traceable recycled plastics while reducing dependence on external sources.

Like all organisations in the EU system, we spend a lot of time in dialogue with our members and feeding that back into the legislative process through our members’ expertise. Especially as we come towards a final agreed text, it will be key to ensure that our members are apprised of the legislation and its impacts. This is often an ongoing dialogue, especially as there will always be new technologies and approaches as companies innovate.

Is the 25% recycled plastic target for 2032 realistic, or does the 20% fallback offer a more practical balance between ambition and economic feasibility?

Plastics Europe believes, especially in the wider conversation around investment and sustainability of plastics, that ambitious targets are needed to help encourage and drive industry towards circularity. The 20% position being suggested in a staged step approach is still reasonably ambitious, and we would encourage certainty to allow businesses time to prepare to meet the targets and make those investments.

What infrastructure and policy support is needed to enable smaller recyclers to contribute to the ELV plastics recycling targets without being left behind?

Verification and certification are key to traceability and compliance, but fragmented implementation rules across Member States could lead to complexity. To cut red tape and support industry, including small and medium enterprises, we need user-friendly, automated systems and digital permitting and reporting to boost efficiency and strengthen traceability.

As outlined in the EU Commission’s Clean Industrial Deal, establishing Trans-Regional Circularity Hubs alongside national sorting and recycling infrastructure will unlock the full potential of the EU market and drive economies of scale in recycling.

Plastics Europe logo with the tagline “Enabling a sustainable future”

Background information:

https://www.ft.com/content/5d5a4641-f066-4b4a-a596-00f5ff9f0e2d

https://plasticseurope.org/media/plastics-europe-maintains-call-for-ambitious-recycling-targets-following-plenary-vote-on-amendments-to-end-of-life-vehicles-regulation/ 

https://plasticseurope.org/media/eu-green-week-industry-sounds-alarm-on-future-of-plastics-circularity/ 

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