Policy Brief

February 2024

Mandatory Recycled Content in the EU

Overview of Policy
This briefing explores the 'Mandatory EU Recycled Content Target for Plastics Packaging' [1] within the EU Packaging
and Packaging Waste Directive. Aligned with SEPA's objectives, the policy targets a 30% recycled content in plastics
packaging by 2030, promoting resource efficiency and a circular economy. It complements broader EU sustainability
goals for vehicles. The urgency lies in global environmental concerns, and SEPA's alignment with this policy is critical
for strategic planning and regulatory compliance. Engaging with international initiatives amidst the current sustainability
focus presents a timely opportunity for SEPA to contribute to broader environmental objectives based on the policy
implemented in the EU initiative. [2]

Introduction
y.
The EU Commission staff assessed specific policies for
sustainable and circular vehicle manufacturing and
disposal. As part of their objectives, they analysed the
mandatory recycled content policy, leading to a
comprehensive policy package with various measures.
“Design Circular," anchoring circularity requirements for
new vehicles, and medium-term actions like revising
recyclability methodology. In "Recycled Content," it targets
25% plastics recycled content by 2030 and empowers the
Commission for steel targets. "Treat Better" enforces a
stricter recycling definition, a landfill ban, and medium-level
removal obligations to enhance ELV component recovery.
"Collect More" introduces ambitious measures for
increased legal ELV treatment and bans exporting non-
roadworthy vehicles. Finally, "Cover More Vehicles" adopts
a phased approach, requiring vehicle composition
disclosure and minimum treatment for additional categories
over time. The benefits of recycling instead of
manufacturing can be seen in Figure 1.
Impact of Policy
The EU's mandatory recycled content policy for vehicles, a
pivotal element in its preferred approach, significantly
reduces the automotive industry's carbon footprint by an
anticipated 12.3 million tons of CO2-equivalent annually by
2035. Focused on plastics, the policy aims for 25% recycled
content by 2030, aligning with circular principles and
generating a substantial value of 2.8 billion EUR. This
initiative not only benefits the environment but also supports
the material sector, promoting responsible consumption
and production in line with Sustainable Development Goal
12. The policy anticipates substantial annual revenues of
5.2 billion EUR in 2035 and the creation of 22,100 jobs,
particularly benefiting SMEs. Despite short-term costs, the
policy fosters economic growth, job creation, and industry
modernization.[1]
The success of the preferred option will be gauged using
indicators such as recycled materials in new vehicles, ELV
recycling rates, pre-shredding material removal, market
share of used spare parts, ELVs collected and treated per
ELV requirements, and exported used vehicles. For
"Design Circular" and recycled materials, adherence to 3R
criteria (reusability, recoverability, and recyclability) will be
verified during type approval. Monitoring circularity strategy
information will allow the Commission to track the
automotive sector's evolution towards circular business
models.[1]
automotive sector's evolution towards circular business
models.[1]
Balanced Critique
Pros: The policy presents positive aspects by
significantly reducing the automotive industry's carbon
footprint, aligning with sustainability goals. It promotes
circular economy principles through 25% plastics
recycled content target, fostering sustainability.
Anticipated economic benefits include substantial
revenues and job creation, particularly in SMEs. The
introduction of stricter regulations, like the landfill ban,
enhances the recovery of key components from End-of-
Life Vehicles (ELVs), contributing to improved resource
utilization.
Pros: The policy encounters challenges with short-term
costs for the EU automotive industry and potential
enforcement issues with the export ban on non-
roadworthy vehicles. Its complexity, including stringent
compliance measures, poses challenges for
manufacturers, particularly SMEs, with potential
unintended consequences for ELV treatment operators.
Careful consideration and adjustments are crucial to
mitigate these downsides and ensure effective policy
implementation.
Lessons Learned: Balancing short-term costs against
long-term benefits emerges as a crucial lesson,
emphasizing the need for future policies to carefully
consider economic implications. Effective enforcement
mechanisms are essential, particularly concerning
export bans, necessitating robust monitoring and
international collaboration. The policy's complexity
underscores the significance of continuous stakeholder
engagement, emphasizing the need for inclusive
policymaking. Furthermore, the call for continuous
monitoring and adaptation allows for the flexibility
needed to address unforeseen challenges,
emphasizing the importance of dynamic policymaking to
ensure sustained effectiveness in achieving
environmental and economic objectives. Thes
underscores the significance of continuous stakeholder
engagement, emphasizing the need for inclusive
policymaking. Furthermore, the call for continuous
monitoring and adaptation allows for the flexibility needed
to address unforeseen challenges, emphasizing the
importance of dynamic policymaking to ensure sustained
effectiveness in achieving environmental and economic
objectives. These lessons highlight the need for pragmatic,
adaptable, and inclusive approaches in shaping future
policies.
Stakeholder Views
PlasticsEurope, the voice of European plastics
manufacturers, fervently backs the shift towards a Circular
Economy for plastic packaging [3]. They see the Packaging
and Packaging Waste Directive approach as a chance for
collaborative policymaking with the European Commission.
PlasticsEurope pledges support for recycled content
targets, suggesting up to 30%, dependent on specific
enabling conditions. The association underscores
significant investments in chemical recycling and supports
the directive's overhaul, stressing the need for harmonized
implementation to achieve an ambitious EU Single Market
target. Companies [4] expressed their concerns and
recommendations, in a letter to Executive Vice-President
Timmermans, in respect to the packaging value chain
regarding the review of the Packaging and Packaging
Waste Directive. The signatories in the letter fully support
the Circular Economy Action Plan's objectives and believe
the directive's revision is a crucial opportunity. They
emphasize the need for robust legislation to drive
innovation, ensure stronger enforcement, and harmonize
practices across the EU. The letter expresses concern
about the limited stakeholder workshops and indicative
timeline, suggesting that rushed decision-making may lead
to poorly defined measures and delays, as observed in
previous directives. The signatories urge the allocation of
sufficient time and resources for a successful review and
express willingness to engage in further dialogue.
Recommendation
SEPA should actively support and advocate for the
endorsement of the proposed mandatory recycled content
policy for vehicles by the EU Commission. This policy aligns
with SEPA's commitment to environmental sustainability
and circular economy practices. SEPA should engage in
collaborative efforts with the EU Commission, emphasizing
the relevance of this policy to Scotland's environmental
goals. Additionally, SEPA should proactively participate in
discussions with stakeholders to ensure that the policy
aligns with local needs and challenges. By endorsing and
actively contributing to the implementation of this policy,
SEPA can play a pivotal role in advancing Scotland's
environmental objectives.
Headline Implications
SEPA should promptly endorse the EU's recycled content
policy, ensuring legal alignment and proactive adaptation of
waste management strategies. Financial considerations
necessitate a comprehensive assessment of short-term
impacts and potential budget adjustments. Collaborative
engagement with the EU Commission and stakeholders
requires resource planning for effective participation.
Implementing monitoring mechanisms ensures
transparency, and robust stakeholder engagement,
coupled with training programs, aids in local adoption.
Careful evaluation of the endorsed policy, including its
legal, financial, and operational implications, is imperative
for SEPA’s alignment with European standards and
fostering a sustainable waste management framework in
Scotland.

References
[1] E. C. Staff, “EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT,” European Commision,
Brussels, 2023.

[2] M. o. G. Skills, “Reforming the UK packaging producer responsibility system: Partial Business and
Regulatory Impact Assessment (BRIA),” SEPA, Edinburgh, 2023.

[3] PlasticsEurope, “PlasticsEurope’s position on Recycled Content for plastics packaging,” PlasticsEurope,
2021.

[4] ACE – The Alliance for Beverage Cartons and the Environment,AIJN – European Fruit Juice Association etc,
“Subject: The packaging value chain calls on the European Commission to dedicate appropriate time and,”
PlasticsEurope, Brussels, 2021.

[5] E. Bonnin, “How much CO2 is saved by recycling?,” Scrapp, 16 June 2022. [Online]. Available:
https://www.scrapprecycling.com/post/recycling-co2. [Accessed 12 02 2024].