Unlocking circular growth: a strategic imperative for Europe

The European association of plastic manufacturers, PlasticsEurope, recently published a position paper outlining its considerations regarding the public consultation launched by the European Commission, which closed on 6 November, on the Circular Economy Act. This new legislative framework on the circular economy could be enacted by 2026.

Plastics Europe reminds that plastics are integral to the European economy, serving a wide range of strategic industries such as automotive, packaging, construction, electronics, healthcare, renewable infrastructure and consumer goods. Although the European plastics value chain currently supports around 1.5 million jobs across more than 50,000 businesses, the warning signs are clear: production lines are shutting down, plants are closing, and manufacturing output in Europe continues to decline.

European plastics manufacturers are already committed to the “Plastics Transition” roadmap to accelerate the transition to make plastics circular, drive lifecycle emissions to net zero, and foster the sustainable use of plastics. However, circularity remains a policy ambition, not a business reality.

The European association believes that, without urgent intervention, escalating energy costs, unsupportive legislation, and fragmented policies will continue to weaken the sector’s foundations and undermine its ability to drive innovation and strategic autonomy. Therefore, Plastics Europe urgent asks for a circular and competitive European industry to ensure the effectiveness of the recommendations outlined below, and any resulting EU-level actions, it is essential that they are both legally enforceable and consistently implemented. Here they are in summary.

1 - Creation of a market pull for all circular feedstocks and technologies at sector level:
- certainty on sector-specific recycled content targets, alongside measures to promote broader adoption of circular feedstocks;
- additional mechanisms to stimulate demand for secondary raw materials: Public Procurements Frameworks and Extended Producer Responsibility eco-modulation;
- promotion of “European-made” plastics and plastic products; 
- verification and certification of equivalent requirements for imports.

2 - Nevelling the global field: a just transition to circularity:
- tracking global circular economy progress via robust data monitoring; 
- strengthening capacity for effective enforcement.

3 - Investing in the circular transition for a competitive European industry:
- reinvesting revenues from plastics to accelerating the plastics circular transition;
- establishing a dedicated circularity fund within the Competitiveness Fund;
- recognition of organic chemicals and polymers as carbon leakage sectors eligible for compensation under the EU Emissions Trading System (EU ETS).

4 - Enabling a well-functioning single market for plastic waste:
- end-of-waste criteria for all recycling technologies and their outputs; 
- enabling Flexibility in Intra-EU Waste Shipments under the Waste Shipment Regulation.

5 - Removing barriers: phasing out linear economies and illegal waste practices:
- ban on landfill and incineration of recyclable plastics; 
- eliminating subsidies that undermine circularity, with landfill taxes as a complementary policy measure; 
- incineration under EU Emissions Trading System (EU ETS);
- action on Illegal and unaccounted plastic waste volumes.

6 - Recognising the essential role of all stakeholders in the circular transition:
- extended producer responsibility – driving accountability and recycling; 
- connecting stakeholders through digital communication channels;
- transregional hubs for circularity: delivering more together;
- the power of education and engagement.