Lack of environmental benefits and high implementation costs determined the exclusion of the

As EuPF points out, the EC's recent decision is a 'pragmatic recognition of economic realities'. It was underpinned by the findings of a Deloitte feasibility study commissioned by the European Commission's Directorate-General for the Environment (DG ENV). It showed that switching to reusable stretch films and pallet strapping tapes involves a significant increase in investment and operating costs, with no environmental benefit.

It should be emphasised that the exemption applies only to obligations under Article 29(2) and (3) PPWR regulation. EuPF reported that the decision has already been confirmed and will soon be formally adopted by means of a delegated act. The question of Article 29(1) is still open., which mandates the reuse of 40% of transport packaging in cross-border trade by 2030 and as much as 70% by 2040.

MEP intervention and EC position on the application of Article 29.

The problem of the impending implementation of the mandatory reuse of stretch film and strapping tapes was also recognised by MEP Piotr Müller (ECR), who sent an enquiry to the EC regarding the planned exemptions as early as mid-August 2025. As he stressed, maintaining the current obligations "would mean eliminating common solutions such as stretch film and PET tape, despite their low carbon footprint and high logistical efficiency, as confirmed by independent studies (e.g. IFEU 2025)". In his view the failure to fully exempt stretch film and binding bands from Article 29(1), (2) and (3) of the PPWR is promoting less environmentally friendly solutions, which in turn runs counter to the objectives of the PPWR Regulation. Müller also pointed out that the process of developing the delegated act, which could introduce possible exemptions, was taking place without sufficient transparency and without consultation with the packaging industry.

19 September 2025. The EC responded to the enquiry by stating that it was investigating the possibility of exempting certain packaging formats from Article 29(2) and (3) of the PPWR and awaiting the results of the study to make a final decision. While, in the case of the above provisions, the EC's final decision turned out to be in line with the wishes of the industry and with environmental performance in the broadest sense, already at Article 92(1), the positions of the industry and the EC differed significantly. In the aforementioned response to the enquiry, the EC made it clear that:

"the targets for the re-use of transport packaging formats listed in Article 29(1) of the Packaging Regulation are feasible, do not worsen environmental performance and do not lead to negative economic impacts for the economic operators concerned."

In view of these reports the exemption of stretch film and PET/PP tapes from Article 29(1) of the PPWR has been called into question.

IFEU and RDC data: reuse not always greener

Introducing mandatory reuse in cross-border transport (i.e. no change to the provisions of Article 29(1)) would mean that two palletising systems would have to be used - separately for the EU market (reusable packaging) and export (non-reusable packaging) - and this could undermine the competitiveness of European industry. Moreover, transporting empty reusable packaging over long distances, which is typical of cross-border trade, would significantly increase CO₂ emissions..

According to EuPF head Thomas De Meester, scientific and economic data support that Article 29(1) should also be exempted:

IFEU analysis shows that in many applications, reusable packaging leads to as much as 1700% higher greenhouse gas emissions, and the RDC study shows an annual cost increase of almost €5 billion in eight key sectors. With longer transport distances, emissions increase, making reuse less environmentally beneficial.

Importantly, in considering the legitimacy of the exemption, the EC is relying on the same set of scientific data, a fact that clearly resonated in its response to Peter Müller's query.

At the same time, the Commission announces a "realistic and pragmatic approach" to the development of an Article 30 implementing act that will define the methodology for calculating re-use rates. The industry looks forward to seeing what specific criteria will be adopted therein.

Industry awaits implementing act and public consultation

The European Commission's decision to exempt pallet wrapping film and strapping tape from the 100 per cent reuse target is an important signal for the plastics industry across Europe - also in Poland. Many Polish companies are active on the export market and the potential reuse obligation could force a costly reorganisation of packaging and logistics processes.

EuPF announces further efforts to harmonise the Commission's approach to all paragraphs of Article 29 and to actively participate in the consultation on the Article 30 implementing act. The organisation stresses that regulations should be based on science and not solely on political assumptions, so that they realistically support environmental objectives and a circular economy.

Sources:

1. The exclusion of stretch wrap and PET tape from the reuse obligation in the draft packaging and packaging waste regulation (PPWR) and the transparency of the consultation process, https://www.europarl.europa.eu/doceo/document/E-10-2025-003229_EN.html
2. Answer given by Ms Roswall on behalf of the European Commission, https://www.europarl.europa.eu/doceo/document/E-10-2025-003229-ASW_EN.html
3. EuPF welcomes EU reuse exemptions, https://www.recyclingtoday.com/news/eupf-plastic-film-pallet-wrap-strap-reuse-mandate-exemptions-europe/
4. Stretch films and tapes exempt from reuse. What's next for PPWR?, https://www.plastech.pl/wiadomosci/Folie-stretch-i-tasmy-zwolnione-z-ponownego-uzycia-Co-21346

The scale of the crisis in the plastic recycling industry - production declines and a wave of closures

The latest figures on the state of the European plastics recycling industry are not encouraging. Representatives of Plastics Recyclers Europe speak plainly about the deep crisiswhich could even lead to the collapse of the entire industry.

• In 2023, there is an 8.3% decrease in the volume of plastics production.
• Between 2006 and 2023 the European industry's share of the global plastics processing market fell from 22% to just 12%.
• According to forecasts, by the end of 2025 alone, plastics recycling plants with a total capacity of almost 1 million tonnes will have disappeared from the old continent.
• In H1 2025 alone, plant capacity fell by almost as much as in the whole of 2024.
• Chemical recycling scale grows slower than expected, which could jeopardise the goal of chemical recycling 3 million tonnes of plastics by 2030.

The countries that have hitherto been European leaders in plastic recycling, i.e. the Netherlands, Germany and the UK, are most affected by the crisis. Analysts forecast that Plastic recycling industry to close 2025 with zero growth. Such an abrupt deceleration calls into question the further possibilities of developing a local circular economy.

See also: Commission gives green light to chemically recycled materials >>

European industry bowing to pressure from imported recyclate

Plastics Recyclers Europe sees the reasons for the growing crisis mainly in the lack of mechanisms to protect the domestic market from an influx of cheaper imported recyclate. Also of significance are steadily rising operating costs (e.g. the cost of purchasing green energy), high raw material prices and excessive bureaucracy, which makes it difficult, for example, to obtain and renew permits. All these factors make locally produced recyclate is significantly more expensive than imported recyclatewhose quality sometimes raises serious concerns.

As it turns out, the obstacles to building a competitive European plastics industry are also regulatory uncertainty and regulatory fragmentation across Member States. This is mainly about the EPR regulations, under which each Member State has created its own separate and different system. Plastics Recyclers Europe also draws attention to the insufficient enforcement of these EPR requirements under Community legislation.

Market and legislative uncertainty is a barrier to investment in new plastics recycling plants and technologies. In mid-September 2025, the US company will ExxonMobil announces investment halt in the chemical recycling centres being set up in Antwerp and Rotterdam, which were expected to collectively process up to 80,000 tonnes of waste per year. EU policy, which, according to ExxonMobil senior vice-president Jack Williams, discriminates against the use of existing petrochemical plants over stand-alone recycling facilities, was cited as the main reason.

Joint industry appeal to EU decision-makers

Faced with a catastrophic situation in the industry, representatives of the 28 largest players in the European plastics value chain have launched an appeal to EU decision-makers, urging them to take immediate action. In a joint letter, the recycling industry outlined 6 demands to address the sector's most pressing problems.

1. Implement effective mechanisms to protect the market from imports of cheaper raw material, including strict enforcement of quality requirements and standards, including for imported recyclates.
2. Create incentives to invest in infrastructure for collecting, sorting and recycling plastics.
3. Harmonisation of EPR regulations across the Community.
4. Reviving demand for European plastics, e.g. by introducing eco-modulation of charges based on the content of high-quality recycled raw material.
5. Facilitating access to cheap, clean energy.
6. Reducing bureaucracy, especially related to obtaining and renewing permits.

Jobs in green industry and EU climate goals are at stake

According to representatives of the plastics recycling industry, the failure of the European institutions to react quickly will lead to a further decline in production and reduction in the scale of recycling, resulting in more bankruptcies and closures of processing plants. It will also derail decades of investment in innovation and the circular economy and lead to the loss of thousands of green jobs.

The collapse of the European plastics recycling sector will also mean serious delays in meeting the EU's environmental and climate goals. Without a stable local recycling base, Europe will not be able to deliver on the European Green Deal nor maintain its leadership position in the transition towards a circular economy.

Experts stress that the window of time to take the necessary action is closing fast. If the European Union does not introduce immediate systemic solutions, the effects of the current crisis will be irreversible - for both the economy and the environment. The industry therefore appeals to decision-makers: the time to react is now.

Sources:

1. Plastics Value Chain Demands Immediate Action to Save EU Industry, https://www.plasticsrecyclers.eu/news/plastics-value-chain-demands-immediate-action-to-save-eu-industry/
2. Wave of Surging Plastic Recycling Plant Closures Hits Europe, https://www.plasticsrecyclers.eu/news/wave-of-surging-plastic-recycling-plant-closures-hits-europe/
3. Is the European recycling industry truly doomed?, https://packagingeurope.com/news/is-the-european-recycling-industry-truly-doomed/13334.article
4. Blenkinshop, Exxon pauses European plastic recycling plans over draft EU rules, https://www.reuters.com/sustainability/land-use-biodiversity/exxon-pauses-european-plastic-recycling-plans-over-draft-eu-rules-2025-09-17/

Reasons for expiry of the waste management decision

Waste management decisions are the cornerstone of the waste industry. As early as 31 December 2025, however, many of them may expire. This follows from the provisions of the Waste Management Act (Article 226a) and the Environmental Protection Act (Article 193(1c))which indicate this very date as the cut-off date, and this even for entrepreneurs who have applied for new permits and licences at least three months before the expiry of the period for which the earlier decisions were issued.

From 2022. the Marshall Offices, which handle the majority of such cases, cannot cope with the flood of applicationsand decision-making procedures drag on for years. Meanwhile, the deadline for the expiry of decisions is approaching inexorably - all entrepreneurs who fail to obtain new permits and approvals must expect to have to suspend their activities after the New Year.

Amendments to laws will extend the validity of decisions. Until when?

Following appeals from, among others, representatives of the steel industry, the Ministry of the Environment drafted an amendment to the Waste Management and Environmental Protection Acts, which envisaged the following automatic renewal of expiring decisions. By how much? The SME Ombudsman called for postponing the deadline by 3 years, i.e. until 31 December 2028. In the first version of the bill, the Ministry of Climate and Environment proposed a 2-year period (until 31 December 2027). In the course of the legislative work, the Ministry of Climate and Environment withdrew from this idea and instead of 2 years gave entrepreneurs only 6 additional months to obtain a new decision. The law currently under way extends the validity of permits and authorisations only until 30 June 2026.

As the explanatory memorandum to the bill reads:

As of 31 December 2024, there were approximately 1,410 applications pending to bring administrative decisions into line with the Fire Act. This represents approximately 13 % of all applications submitted. The largest number of administrative proceedings is on the part of provincial marshals (according to the aforementioned state, these bodies had 1,070 applications pending). Taking into account the scale of the proceedings conducted by the provincial marshals, a detailed analysis of the adaptation stage was carried out, which shows that as of 1 January 2026, approximately 307 applications for adaptation of the decision will remain to be considered.

Will we have time to adopt the amendment?

The bill, which is being processed under the number UDER39, did not reach the Council of Ministers until the end of September 2025. At this point, therefore, there is no certainty that the new legislation will be adopted and enter into force on the planned date (i.e. 1 December 2025). If the parliament does not deal with the matter soon, the spectre of an interruption in waste collection will become real after 1 January 2026. Experts predict that the need for some waste companies to suspend operations may cause serious waste management problems at the municipal level - The cost of transport and thus the charges for residents may increase. In the worst-case scenario, waste will cease to be collected from properties.

It is not only entrepreneurs, but also local authorities, who are already calling for the legislative work to be speeded up and the deadline for previous decisions to be extended not by six months, but by a minimum of one year. However, the Ministry of the Environment is closing the door to any conjecture:

30 June 2026 is the cut-off (final) date for the extension of existing administrative decisions. After this date, it will no longer be possible to extend the aforementioned decisions. In the event that the time for which the existing decision was issued has expired and the procedure for issuing a new decision is not completed before 1 July 2026, the earlier decision will expire by operation of law on that date. This effect will take place irrespective of the date of the application for a new permit.

Paralysis of Marshal Offices main cause of problems

The massive influx of applications for permits and licences is due to several factors. Firstly, in 2024 and 2025, the 10-year expiry date of many decisions issued in 2014-2015 was coming to an end. Secondly, the introduction of the Fire Act forced waste management operators to adapt their decisions to the new fire protection requirements. In both of these situations the number of pending applications has increased exponentially, which, combined with the ongoing handling of first-time applicants, has led to a prolonged paralysis of marshal offices.

Faced with this situation the validity of previous decisions has already been extended once. In 2022, the aforementioned Article 226a was introduced into the Waste Act and Article 193(1c) was introduced into the Environmental Protection Law, which automatically postponed the expiry date of all decisions to 31 December 2025, provided that the entity concerned applied for a new decision at least 3 months before the expiry of the previous one. Will the additional 6-month period planned by the Ministry of the Environment prove sufficient? And will the parliament accept the ministry's proposal in this shape and timeframe?

The fate of the ministerial bill can be followed on the website of the Government Legislation Centre.

Lack of unanimity and deep divisions the results of the latest round of plastic treaty negotiations

A summit was held in Geneva, Switzerland, from 5-13 August 2025, during which the Representatives of almost all UN states were to conclude negotiations on the so-called 'Plastics Treaty' - global agreement to reduce plastic pollution. The INC-5.2 session, however, did not result in a breakthrough, and the national delegates present remained deeply divided, and not only on how to address the plastic pollution crisis, but also on the legitimacy of establishing regulations at the international level.

The August summit, held at the United Nations headquarters, was attended by more than 180 national delegations. More than 100 of them clearly supported the introduction of limits on the production of plasticswhich would be binding on all UN countries. Many delegates also urged action to eliminate or at least reduce the use of toxic chemicals that are present in the composition of some plastics. Unanimity was not achieved on any of these aspects - such radical demands were met with opposition from countries whose economies rely heavily on oil and gas production.

After the talks broke down, the negotiating committee stated that the session was only adjourned, not terminated, and work on the treaty will continue in the future. UN states must, however, "work to find a date and place" where talks can resume.

Why was no agreement reached? Conflicting interests of states and lobbyists at the Geneva summit

As originally envisaged, The plastics treaty was to address the entire life cycle of plastics, with a particular focus on reducing their production. During the negotiations, however, major oil-producing countries (including Saudi Arabia and Russia) sought to marginalise potential restrictions and bans and redirect attention to recycling, reuse and eco-design plastic products. As estimated by the organisation CIEL (Center for International Enviromental Law), during the last round of negotiations in Geneva a minimum of 234 lobbyists from the chemical and fossil fuel industries turned up. Their numbers exceeded that of the delegations of all EU Member States combined. 19 lobbyists also secured seats in the national delegations of Egypt, Kazakhstan, China, Iran, Chile and the Dominican Republic, among others.

The strong representation of the petrochemical lobby was one of the key factors that led to the failure of the talks. As Colombia's Delegate Sebastián Rodríguez said:

"Negotiations have been consistently blocked by a small number of countries that simply do not want an agreement."

The chair of the negotiating committee, Vayas Valdivieso, presented two drafts of the treaty text to delegations, but neither met with acceptance. Countries seeking to impose limits on plastic production argued that the proposed content of the treaty has been significantly watered down and now deviates from the original intentions. Indeed, the draft did not include provisions on the need to reduce the production of plastics, but only described current levels of plastic production as 'unsustainable'. Although most of the rejectionist countries' demands were taken on board, their representatives did not accept the draft treaty either. In their case, the bone of contention was the aforementioned word 'unsustainable' used in the context of plastic production levels. This nomenclature was vociferously opposed by negotiators from Kuwait and Saudi Arabia, considering it to be beyond the intended scope of the treaty.

Read also: Will the US support a plastics treaty?

International disappointment after talks over plastics treaty broke down

The Geneva meeting was to be the last round of international negotiations held since 2022. Many governments and NGOs hoped to build a consensus to curb plastic pollutionmainly by imposing restrictions on the production of plastics. Faced with the failure of the talks, many national delegations did not hide their indignation.

French Minister for the Ecological Transition, Agnès Pannier-Runacher, said she was "disappointed" and "irritated" that several countries driven by "short-term financial gains" had blocked the adoption of the landmark treaty. France, other EU countries and more than 100 countries from all continents had "done everything in their power" to reach an agreement on the issues of reducing plastic production, banning hazardous substances and protecting human health, she added.

In a similar vein were statements from representatives of international organisations. Sarah Baulch, senior official at the Pew Charitable Trusts said:

By failing to meet yet another deadline related to the escalating plastic pollution crisis, countries are putting people's health and the planet at risk.

In contrast, a slightly more balanced position was taken by the Chinese delegation. According to the representatives of the Middle Kingdom, The fight against plastic pollution is a long and gruelling marathon, and the temporary difficulties in reaching an agreement should be a prelude to the next round of talks. China has called on all countries to work together to leave future generations with a planet free of plastic pollution.

Sources:

1. Paddison, Global plastic treaty talks end in failure as countries remain bitterly divided over how to tackle the crisis, https://edition.cnn.com/2025/08/15/climate/global-plastics-treaty-pollution-failure-un
2. The Guardian, Plastic pollution talks fail as negotiators in Geneva reject draft treaties, https://www.theguardian.com/environment/2025/aug/15/plastic-pollution-talks-geneva-treaty

Key objectives of the new law on packaging and packaging waste

Draft law on packaging and packaging waste developed by the Ministry of Climate and Environment aligns Polish law with EU legislation, mainly the SUP Directive and the PPWR Regulation. Both of these acts impose a number of obligations on Member States to put in place effective systems to reduce the amount of packaging waste generated and to increase recycling levels.

One of the main objectives of the Act is to shifting the costs of collecting and managing packaging waste from municipal residents to packaging producers. The IOC anticipates that this will consequently lead to a reduction in the fees paid by residents for the collection of municipal waste from their properties, while not translating into an increase in the price of packaged products.

In order to be able to fully implement the obligations imposed by the PPWR regulation, the ROP Act will also introduce a a new definition of producer, which will replace the existing definitions of introducer of packaging and introducer of packaged products.

What will the Polish ROP look like on packaging?

The main tool of the extended producer responsibility scheme will be a packaging fee levied on the producer and charged per kilogram of packaging (including the packaging of packaged products) entering the Polish market. With regard to packaging, it will replace the currently applicable product charge. As required by the PPWR Regulation, the rates of the fee will be differentiated for individual packaging materials and adapted to the requirements of the the eco-modulation system. As at present, the rates will be set by regulation by the minister responsible for climate matters, based on criteria submitted by the IOŚ-PIB.

How much will the ROP packaging charge amount to? At this point, we know that the basis for its calculation will be data from the quarterly ROP reports submitted by producers via the BDO system. The rates is to be sufficient to cover the operating costs of the ROP system, including the net costs of selective collection and processing of packaging waste, the costs of developing the collection and processing system, the costs of environmental education and the costs of tasks carried out within the scope of the ROP by NFOŚiGW and IOŚ-PIB.

ROP fees will be paid quarterly to the account of the provincial marshal, who will be responsible for controlling the correctness of the calculation and payment of fees, and then for transferring them to the NFOŚiGW (National Fund for Environmental Protection and Water Management).

Monopoly instead of competition - NFOŚiGW will take on the role of producer responsibility organisation

The collection and redistribution of funds from the packaging levy will be handled by the state fund NFOŚiGW. According to the ministerial bill, NFOŚiGW will act as an Extended Producer Responsibility Organisation (EPO) and carry out its obligations under the ROP within a closed financial circuit. In practice, this means that the activities of packaging recovery organisations will be extinguished and their place taken by a state-owned monopolist.

The funds collected will be transferred by NFOŚiGW:

• to the municipalities - for the maintenance of the collection system for packaging waste from properties/alleys (for a fixed amount) and for the collection of municipal packaging waste (per tonne),
• to entities collecting municipal waste from non-residential properties - per tonne of municipal packaging waste,
• to collectors of non-municipal packaging waste - for each tonne of packaging waste sent for recycling,
• to sorting plants, MPBs and other recyclers of packaging waste - for sorting and recycling each tonne of this waste,
• to recyclers - for recycling each tonne of waste with a negative market value.

NFOŚiGW will also be tasked with entering into agreements with these entities and spending the proceeds of the packaging fee exclusively on ROP-related activities. NFOŚiGW will not, however, own the waste or select the waste managers.

The draft new law also gives producers the option to carry out their ROP obligations themselves (i.e. organising waste collection and recycling, conducting public education campaigns, etc.). Any producer who chooses to do so must obtain a permit issued by the Minister for Climate Affairs.

Other assumptions of the planned ROP system

The draft of the new Packaging Act runs to as many as 150 pages, where the Ministry of the Environment has also detailed the other issues related to the functioning of the Polish extended producer responsibility model.

• The source of funding for the ROP system will be revenue from the packaging levy.
• Producers who pay the packaging levy will not have to reach recycling levelsand the recycling documents (DPR, EDPR) will be replaced by other reporting instruments. They will be requested by waste managers on their own behalf.
• The functioning of the BDO will be aligned with the objectives of the ROP - Among other things, there will be new document templates, such as packaging record sheets and reports.
• The duties of preparing analyses for the purpose of determining product fee rates and preparing reports (e.g. for ministries, the EC) will be taken over by IOŚ-PIB.
• The ROP system and the activities of NFOŚiGW and IOŚ-PIB will be supervised by the minister responsible for climate.
• The provincial marshals will exercise control over recyclers, exporters and intra-community suppliers of packaging waste.
• The market surveillance authority for matters covered by the PPWR will be the Trade Inspection.
• The supervisory authority in matters concerning, inter alia: waste management will be the Environmental Protection Inspectorate.

When will the ROP system be introduced for packaging?

New The law is due to enter into force as early as 1 January 2026.However, only selected provisions will apply from that date. The draft provides for 2-year transitional period, during which the rates of the packaging levy will be gradually increased to cover the costs of compensating municipalities and the investment costs of preparing the system. Full implementation of the ROP model is scheduled for 1 January 2028. when the current product levy on packaging will be abolished and the proceeds of the packaging levy will fully cover the costs of operating the ROP system.

As the IOC predicts in the Regulatory Impact Assessment:

the implementation by obligated entities of the requirements established in the PPWR, as well as the introduction of the new ROP model, will contribute to a reduction in per capita packaging waste generation of at least 1% by 2027, 2% by 2028 and 3% by 2029, so as to achieve by 2030. 5% decrease in packaging waste generation per capita and at least 10% and 15% by 2035 and 2040 respectively.

Ministerial draft ROP law under fire from producers and recovery organisations

The ROP model proposed by the Ministry of the Environment has caused considerable controversy among producers, who may be covered by the new regulations in a moment, and among representatives of the recycling industry. The main objection to the solutions presented is the cancellation of more than 20 years of experience of specialised packaging recovery organisations and their replacement by a state-owned entity that will act as an administrator in the transfer of funds from businesses to municipalities and waste management companies.

According to environmental law experts, the law is contrary to the provisions it was intended to implement. The PPWR obliges EU Member States to ensure that producer responsibility organisations can function and allows for the operation of multiple such organisations. In contrast, the new law is intended to extinguish the activities of competing recovery organisations and prevent the establishment of new producer responsibility organisations alternative to the NFOŚiGW. Moreover, the centralisation and restriction of market competition outlined in the ministerial ROP model may lead to a failure to achieve EU recycling levels and the imposition of heavy financial penalties on Poland. Such was the effect of the introduction of a centralised ROP scheme in, for example, Hungary and Croatia. At the same time, ROP schemes based on competing producer responsibility organisations are successfully operating in many Member States.

In the business community, the new packaging levy is referred to as a para-tax. Central ROP model with top-down levy rates does not ensure that the financial burden on producers is linked to the real costs of waste management packaging. The ICC denies these rumours and unequivocally indicates that the packaging levy is not of a tax nature. However, the producers' representatives point out that ROP levies structured in this way exhaust the definition of a tax, with only one difference - they will not be derived from the tax act, but from the packaging act. They also add that such a ROP model is not able to react flexibly to the market situation, including dynamically changing raw material prices. Additionally deprives producers of a real influence on the amount of fees and how they are spentand especially on the efficiency and quality of separate collection of packaging waste.

Recycling decline and production growth as key figures in CEPI 2024 report

The pulp and paper industry ended 2024 on a positive note. Compared to the previous year production increased by 5.9% (from 74 374 thousand tonnes to 78 742 thousand tonnes), exceeding the values forecast in the CEPI provisional statistics for 2024. Thus, after the declines recorded in 2021-2023, there has been quite a recovery. Although the sector is still far from the production levels reached at the peak of the COVID-19 pandemic, the noticeable rebound is definitely encouraging. In parallel with the increase in productionpaper and board consumption also increased at a rate of 7% y/y. Increases in production and consumption were recorded in each of the main categories, even in the hitherto declining graphic paper category.

In 2024. there has also been a noticeable decrease in the recycling rate of paper and cardboard - After a great year in 2023, when we recorded a recycling rate of almost 80 per cent, the paper industry closes 2024 with a decrease in by 4.2% y/y. The CEPI explains, however, that this is not a cause for concern - 2023 was an exceptional year in many respects, with noticeably lower consumption and the trend of de-stocking translated into such a high result.

In the words of Valeria Salvadori, President of the European Paper Recycling Council (EPRC):

The European recycled paper market is performing well and we are on track to meet our 76% recycling target in Europe by 2030. Paper is the most recycled material in the EU and the European paper sector is setting global standards for recycling rates, something I am very proud of.

Growth in the packaging and paperboard sector in 2024.

The growth leader in the paper industry remains the packaging sector, which in 2024 recorded a 6.7% increase in production and 7.8% increase in consumption y/y. This was driven by increased production in each of the packaging categories:

• corrugated board - 4.5%,
• cardboard - 10.9%,
• wrapping paper - 19.7%,
• other types of packaging paper and board - 3.1%.

Paper and cardboard packaging also has the highest recycling rate of all packaging materials, amounting to 83.1% in 2024.

The increase in demand for paper-based packaging is likely to be strongly linked to the transformation of the e-commerce market and the impending regulation under the EU PPWR (PPWR). Packaging and Packaging Waste Regulation). The rise in popularity of subscription models and online shopping across Europe has made the cardboard packaging sector one of the key drivers for the industry as a whole.

High circularity of materials and dominance of locally sourced raw material

CEPI data shows that in 2024, after two years of decline, the use of recycled paper (Paper for Recycling, PfR) increased by 4.1%, indicating a rebalancing of demand for recyclables. The data also means that the whole sector is moving ever closer to GOZ. A key role is played here by layered cardboard (cardboard boxes, packaging for collection, transport and shipping, shop displays), which can be described as the most circular product produced by the paper industry - the the recycling rate for cardboard packaging is as high as 95%. At the same time, the production of corrugated packaging is responsible for the consumption of as much as 66% of recycled raw material. This means that corrugated packaging is not only driving the growth in recycling volumes, but is also becoming one of the most important consumers of recycled raw materials.

Figures from the CEPI report also highlight the growing competitiveness of the European industry in international markets. In 2024. Paper and board exports increased by 4.6% y/y, although it still remains as much as 19% lower than in the record year 2020. At the same time, the sector stands out for its very high degree of self-sufficiency - the as much as 94% of the wood and 96% of the recycled material used in European paper mills comes from within the European Union. Such a high proportion of local raw materials reinforces the independence and autonomy of the industry, and increases the raw material security of the industry as a whole.

Paper industry at the forefront of decarbonisation in Europe

The 2024 report also includes information on energy and water consumption and atmospheric emissions for the entire paper and pulp sector in 2023. The paper industry has long been regarded as one of the greenest. Over the past few years, it has steadily reduced its energy requirements and shifted away from the use of gas, coal and fuel oil to increasing the share of green energy from biomass. In 2023. the share of biomass energy in the sector's total demand exceeded 65%. Total energy demand, on the other hand, fell y/y by 12.2%, from 86,741 GWh to 76,160 GWh.

Carbon dioxide emissions were also reduced over the same period: direct emissions by 15.3% y/y and indirect emissions by 13.8% y/y.

As the CEPI press release reads:

CO2 emissions in the European pulp and paper industry have fallen by 50% compared to 2005 levels, effectively decoupling their level from production growth. CO2 emissions per tonne of paper and board produced fell by 6.3% in 2024, reaching 0.24 tonnes of CO2 per tonne of production. This is the result of investments in cleaner technologies, greener fuels and more energy-efficient operations.

CEPI members in 2024.

The data cited in the CEPI report is based on information from the organisation's 19 members, namely Austria, Belgium, the Czech Republic, Finland, France, Germany, Greece, Italy, the Netherlands, Norway, Hungary, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK.

Sources:

1. Key statistics 2024. European pup & paper industry, https://www.cepi.org/press-release-resilient-in-uncertain-times-pulp-and-paper-sector-continues-to-lead-on-sustainability-and-decarbonisation-new-data-shows/
2. CEPI, Press release: European Paper Recycling Council Reports Strong Recycling Rates for 2024, https://www.cepi.org/press-release-european-paper-recycling-council-reports-strong-recycling-rates-for-2024/
3. CEPI, Press release: Resilient in uncertain times, pulp and paper sector continues to lead on sustainability and decarbonisation, new data shows, https://www.cepi.org/press-release-resilient-in-uncertain-times-pulp-and-paper-sector-continues-to-lead-on-sustainability-and-decarbonisation-new-data-shows/

PPWR: mandatory ecomodulation, optional criteria

Ecomodulation is a mechanism that makes the amount of extended producer responsibility (ROP) payments conditional on the amount of the ROP. EPR) on the environmental impact of the product or packaging in question. Under the term environmental impact, there are various criteria on the basis of which charge rates are set. The PPWR provides for an obligation to modulate producers' financial contributions based on the criterion of recyclability of packaging. This is a minimum requirement to be applied by Member States as early as 1 January 2030. 5 years later, the assessment of recycling performance will also be joined by a mandatory assessment of large-scale recycling.

The PPWR provides for the possibility of applying additional eco-modulation criteria. The EU system of modulated charges can therefore take into account:

• recycled content,
• reusability of packaging,
• presence of hazardous substances,
• other criteria, where these are in accordance with Directive 2008/98/EC.

If these criteria are used to develop a Community ecomodulation system, entrepreneurs introducing packaging and packaged products will need to high-quality secondary raw materials, such as those produced by the Recycled-Resource process.

The preamble of the PPWR regulation makes it clear that the criteria applicable in individual EU countries should be harmonised. Importantly, only the criteria themselves will be harmonised, not the rates of packaging fees. This is because the fees paid by producers are intended to cover the costs of separate collection, transport and treatment of packaging waste, labelling of packaging waste containers, analysis of the composition of mixed waste and information and reporting obligations, and these may vary from one Member State to another.

Fees depending on recycling efficiency class

From 1 January 2030. all packaging put on the Community market will undergo an assessment of its recyclabilitywhich will enable them to be assigned to one of the recycling efficiency classes:

• Class A - rating 95% or higher,
• Class B - rating 80% or higher,
• Class C - rating 70% or higher,
• technically unsuitable for recycling - rating below 70%.

Extended producer responsibility fees will be modulated according to this classification, i.e. Class A packaging will be subject to the lowest fee and Class C packaging to the highest fee.. Packaging that does not meet the requirements of the recycling performance classes and scores below 70% will not be allowed to reach the market. In this way, the EU wants to encourage manufacturers and marketers to eco-design of packaging. The manufacturer of the packaging will be responsible for carrying out the assessment of recyclability and will also have to draw up a written declaration of conformity for each type of packaging.

The PPWR regulation makes it clear that introducers cannot be exempted from paying packaging levies - This means that no packaging, even of the highest recyclability standards, will be zero-rated.

Criteria for assessing recyclability according to PPWR

The appendix to the PPWR contains a non-exhaustive list of parameters on the basis of which design criteria for recycling will be established:

• additives - Their presence can contribute to incorrect sorting of waste in the sorting plant and contaminate the secondary raw materials obtained,
• labelling - The material of the label, the impact of the label size on the sorting process of the packaging waste and the type of adhesive or binder used will be assessed, among other things,
• wristbands - bands that cover a large part of the packaging, are difficult to separate and are made of a material other than packaging can make waste sorting and recycling difficult,
• closures and other small packaging items - can make sorting and recycling more difficult if they are not made of the same material as the packaging; in addition, unattached items can increase litter and be lost at the sorting or recycling stage,
• binders - should not affect the ability to separate the fasteners from the packaging; the presence of non-removable binders may contaminate the recovered raw materials,
• dyes - heavily coloured paper and plastic packaging can be difficult to sort and adversely affect the quality of recyclables,
• material composition - monomaterials or combinations of materials that are easily separable and do not affect the recovery process are preferred,
• barriers and coatings - can make recycling difficult, so barriers and coatings that ensure high recovery will be preferred,
• inks, varnishes, method of printing and application of codes - paints and varnishes may prevent recycling, contaminate the raw material or impair the transparency of the recycling stream,
• ease of emptying - the packaging should be capable of being completely emptied,
• ease of disassembly - understood as the ability to easily separate components made of different materials.

Read also: What kind of packaging do consumers want? Find out the key findings of the EKObarometer report >>.

In addition, from 2030, all packaging must be:

• recyclable in a cost-effective manner,
• designed with material recycling in mind,
• collected separately and sorted for specific waste streams,
• without affecting the recyclability of other waste streams

The development of detailed design criteria for recycling will be handled by the European Commission, taking into account standards developed by European standardisation organisations. These criteria will then be used to develop the calculation methodology determining the different recycling performance classes. Both the criteria and the methodology will be known no later than 1 January 2028. - within this timeframe, the EC will issue the relevant delegated acts to supplement the provisions of the PPWR.

Tightening of criteria: scale recycling and a ban on class C packaging

From 1 January 2035, packaging entering the Community market must not only be recyclable, but also recycled on a large scale. Recycling of scale will become another criterion on the basis of which ROP charges will be modulated. Implementing acts establishing the methodology for assessing large-scale recycling will be issued no later than 1 January 2030. The PPWR assumes that a separate methodology will be developed for each of the packaging materials.

At this point, we know that the three-tier classification of recycling efficiency will still apply between 2035 and 2037 - only the criteria will change. In addition to the parameters mentioned above, preference will be given to packaging that can be recycled using existing infrastructure and proven methods and technologies. Consideration will be given to methods and technologies that are capable of ensuring EU-wide recycling of 30% or more by weight of wood packaging waste and 55% or more by weight of packaging waste of other materials. The exact thresholds for each material will coincide with the recycling targets set by the Regulation.

From 1 January 2038, the assessment criteria will remain the same (However, the minimum thresholds for individual packaging and packaging materials may change). However, packaging meeting the requirements of class C will be removed from the catalogue of recyclable packaging. This means that all packaging placed on the EU market will have to achieve a recycling efficiency rating of 80% or higher (equivalent to class B or better). Other packaging will be banned.

Extended liability for textile producers getting closer

Soon, all businesses placing textiles and footwear on the EU market will be obliged to bear the costs of collecting them separately, sorting them, preparing them for re-use and recycling them. Adopted by the European Parliament the revision of Waste Directive 2008/98/EC will introduce an obligation to establish a Community-wide ROP system for textiles.

The content of the act had been agreed with the EU Council a few months earlier. Both legislative bodies will have to sign off the new directive before it is published in the Official Journal of the European Union. From the date of entry into force of the new legislation, Member States will have 20 months to transpose it and an additional 10 months (i.e. a total of 2.5 years) to put the ROP systems in place for textiles.

Under the terms of the amendment, companies bringing in textiles and footwear will bear the costs of separate collection, sorting, preparing for reuse and recycling of textile and footwear waste. As EU projections indicate, the majority of financial contributions from producers will go towards waste prevention and preparing for re-use.

Who will be covered by the ROP for textiles? Personal scope of extended producer responsibility

The obligations arising from the ROP will include all manufacturers of textile products, products incorporating textile materials and footwear products. In the absence of previous regulations, the amendment to the Waste Directive will introduce a definition of such a producer.

Any manufacturer, importer, distributor or other natural or legal person who:

• manufactures textiles or footwear under its own name,
• commissions the design or manufacture of textiles or footwear and markets them under its own name,
• resells textiles or footwear manufactured by another entity and not bearing a name or trademark,
• sells textiles and footwear directly to end users through distance contracts.

The Directive allows Member States to set up ROP systems also with regard to mattresses. However, the following will be excluded from the ROP obligations: self-employed tailors producing customised textiles, introducing second-hand, repaired, upcycled textiles, etc., and producers of textile products made from textile waste.

New responsibilities and new players - ROP for textiles will create space for new producer responsibility organisations to operate

Producers covered by the textile ROP scheme will be able to fulfil their obligations through a producer responsibility organisation. The revision of the Waste Directive allows for multiple organisations (also state-owned) in a single Member State.

The preamble of the amendment clearly states:

"Member States are encouraged to consider allowing multiple producer responsibility organisations as competition between them can benefit consumers, increase innovation, reduce costs, improve the separate collection of textiles and provide producers with a greater choice of operators with whom to contract."

The main task of the producer responsibility organisation will be to setting up textile waste collection and management systems. The amendment defines this activity as:

organising financially or financially and operationally the fulfilment of extended producer responsibility obligations.

In addition organisations will be able to take over the information obligations imposed on textile producers, which include the provision of information and information campaigns on sustainable consumption, waste prevention, reuse, preparation for reuse, including repair, recycling, other recovery and disposal of textile and footwear waste. Thus, it appears that the ROP will solve numerous problems for municipalities and their residents related to mandatory separate collection of textiles.

Importantly, producers or organisations will not have to reach the collection, preparation for re-use or recycling percentagesThe amendment stipulates that by the end of 2029, the European Commission may set targets for the prevention, collection, preparation for re-use and recycling of textile waste.

See also: Contemporary challenges in textile recycling - an interview with Barbara Kądziela from WWF Poland >>

Ecomodulation of charges in the ROP for textiles

The proposed ROP scheme provides for the introduction of eco-modulation of charges, which will give preference to manufacturers producing high quality textiles. Fees are to be modulated according to a product's environmental impact, recyclability, durability, presence of hazardous substances and recycled content.

The detailed criteria for setting product charge rates for textiles will be specified in Commission implementing acts. However, it is known that they will be adapted to the product category and the state of the art. As noted in the EP press release, When setting the level of charges, Member States should also take into account the phenomena of fast fashion and ultra fast fashion.

Producers will pay the ROP fees to producer responsibility organisations operating in the Member State into which the producer introduces its textiles. As the EU points out, this is because it is in that country that textile products are likely to become waste. At the same time, the directive implies the creation of mechanisms to prevent the charging of fees for textiles for which the producer has already paid fees in another Member State.

Why textiles? Motives for establishing a ROP scheme for textiles and footwear

In the preamble to the amendment the textile sector has been identified as one of the most resource-intensive with negative environmental impacts. EU authorities have also pointed out that companies in the sector often fail to comply with waste management rules and the waste hierarchy, which puts waste prevention first.

Read also: Polish fashion e-commerce drowns in plastic bag waste >>

Currently most textiles are not designed with recycling and circularity in mind, and as much as 78% requires separation of raw materials before processing. As a result less than 1% of the 12.6 million tonnes of clothing waste is recycled generated each year in the EU. The aim of the amendment is to create an economy based on collection, sorting, reuse, preparation for reuse and recycling, in particular fibre-to-fibre recycling. fiber-to-fiber), as well as encouraging manufacturers to design textiles and footwear in line with circularity principles.

Sources:

1. Parliament adopts new EU rules to reduce food and textile waste, https://www.europarl.europa.eu/news/pl/press-room/20250905IPR30172/parlament-przyjmuje-przepisy-ue-o-ograniczeniu-marnowania-zywnosci-i-tekstyliow
2. Content of the Directive adopted: https://data.consilium.europa.eu/doc/document/ST-6978-2025-REV-2/pl/pdf

Yes to chemical recycling in PET plastic bottles

The draft proposed by the Commission for the first time allows raw material treated by chemical recycling methods to be counted to meet the ambitious targets set by the SUP Directive. Its provisions oblige producers to use recyclates in PET bottles - from 2025 their content must be min. 25%, and from 2030. - 30%.

The new regulations aim to complement the current methodology for calculating the recyclate content of mechanical recycling. Due to its lower environmental impact and energy consumption mechanical recycling will continue to be the preferred treatment technology for plastics waste. Chemical recycling, on the other hand, will find application in situations where mechanical methods cannot be used or where a higher level of purity is required - such as for food packaging.

New methodology for calculating recyclate content

According to the draft, the share of recycled plastics in SUP bottles is to be counted as the ratio of the weight of the recyclate to the weight of all the plastic parts of the bottle placed on the market in the Member State concerned. This means that to the weight of beverage packaging introduced will include not only the bottles themselves, but also their caps and labels (traditional and sleeve type). Provision is also made for data correction in the case of import, export or movement between EU countries.

Entrepreneurs will additionally be obliged to report the weight of plastic packaging and the share of recyclate in the different parts of the bottles on the basis of the declaration of conformity. Verification will take place on an annual basis (or every three years for SMEs) and responsibility for data compliance will rest with the entrepreneurs and the national control authorities.

The "no fuel use" principle

The new methodology for calculating the chemical recycled content of PET bottles is based on the principle of 'fuel-use exclusion'. This means that waste treated for fuel production or energy recovery must not be added to the recycling balance. Only those fractions that have actually been turned into new recyclables will be counted.

It should be recalled that chemical recycling technologies make it possible to convert plastics not only into new plastics, but also into fuel (e.g. pyrolysis, gasification). Find out more about chemical recycling methods and technologies >>

Changes for investment and increased competitiveness

The establishment of clear criteria and unambiguous definitions is intended to create a a level playing field for all players in the EU market and ensure greater legal certainty and stability for investors. We are, of course, referring to investments in new chemical recycling plants and technologies, which have so far been held back due to a lack of sufficient regulation. The proposed legislation is part of a broader action plan for the EU chemical industry, which aims to increase the competitiveness of the sector and its sustainable transformation. They also provide opportunities for the wider use of recycled chemical plastics and the development of the industry across the EU.

The Commission further points out that the development of a common methodology is important to further reduce landfilling and incineration of plastic waste and the promotion of a circular economy.

Restriction - EU recyclate only until new legislation is adopted

In parallel with the launch of the public consultation, the Commission confirmed the existing interpretation of the SUP Directive - from 2025 to meet the 25% target of rPET content in PET bottles only material derived from waste collected in the EU may be included. In practice, this means that cheap PET recyclate imported from Asian countries, among others, will not be included in the calculation.

The EC's interpretation will be binding until the new rules come into force, which are intended to allow imported raw material to be included, provided that EU environmental and quality standards for waste collection and treatment are met.

Growing importance of chemical recycling as an answer to the waste crisis

In an era of ever-increasing waste generation, The EU wants to support all technologies that return raw materials into circulationand at the same time are more beneficial to the environment than incineration and landfilling. In the wave of this trend Interzero and OMV join forces to create Europe's largest sorting plant for raw materials for chemical recycling. The start-up of the plant in Walldürn, Baden-Württemberg, is planned for 2026.

The new reporting and calculation system is intended to provide transparency throughout the value chain, especially in its most complex stages. The proposed methodology is intended to serve as a model for future regulations on the share of recycled materials in other sectors - such as packaging, automotive or textiles - as well.

Public consultation

Comments on the draft implementing act could be sent until 19 August 2025. The adoption of the act is likely to take place later in the autumn of 2025.

Transformation towards GOZ correct, but not fully effective

In its report, the NIK assessed the degree of implementation of the circular economy, taking as a benchmark the data and activities planned in the Roadmap for the transition towards a circular economy, adopted by the Polish government in September 2019. The NIK analysis, however, covered the period from 2018 to 2022.

In the opinion of the Supreme Audit Office:

• Action by state and local authorities have contributed to the fundamental objectives of contained in The GOZ roadmap.
• Due to insufficient cooperation between ministries and the lack of coordination and monitoring of activities by the Minister of Development and Technology, activities were not fully effective or timely.
• Of the 41 planned actions by the end of November 2023, only 28 had been completed. The remaining 13 actions had not been implemented, including four that had not even started.

What's more, Map was not properly updated. The original plan covered the period 2021-2023, after which it ceased to be a valid government document.

Delays in the implementation of EU law and a decline in the circularity index the main allegations in the NIK report

The main reasons for delays in the implementation of GOZ, the NIK report sees, among other things, in the untimely implementation of EU environmental legislation. These include 3 key directives from the point of view of the country's waste management:

• Waste Directive 2008/98/EC (as amended by Directive 2018/851),
• Packaging Directive 94/62/EC (as amended by Directive 2018/852),
• plastic directive (SUP) 2019/904.

To date, we have not seen the full transposition of the aforementioned acts - the law on ROP is only in the early stages of the legislative path, and the SUP regulations require several key amendments, which the EC called on Poland to implement in June 2025.

The introduction to the NIK report also includes information on a decrease in the circularity index of the Polish economy from 10.5% in 2018 to 7.5% in 2023. Over the same period, the EU indicator remained stable at 11.6% in 2018 and 11.8% in 2023. Reasons cited as reasons for this include. significant decrease in the use of recycled materials (from 76 million tonnes in 2018 to 46 million tonnes in 2023), the lack of full transposition of EU environmental legislation and the failure to accelerate the process of successive elimination of waste with adverse environmental impact. As a consequence, Poland has not met the EU targets for GOZ implementation.

Local authorities' actions are correct, but tangible results are lacking

The NIK audit took place not only at government level, but also at local government level. No major irregularities were found in the 8 municipalities visited - local authorities have been active in implementing GOZ by fulfilling the obligations imposed on them by legislation, mainly in the field of municipal waste management. Despite this in 4 of these municipalities the required level of preparation for re-use and recycling was not achievedand most of them were dominated by forms of municipal waste management less favourable from the point of view of the GOZ: landfilling and incineration.

The NIK report also reveals that the area of municipal waste management at municipal level requires financial support from the state. It is currently in deficit in most municipalities.

The local problems were also reflected in the waste management of the country as a whole, with Poland failing to achieve the minimum recycling and PDPU (Prepare for Reuse) levels for paper, metal, plastic and glass waste between 2020 and 2022. NIK also points out that there is a high risk of not achieving the target minimum in subsequent years. What's more, it is becoming increasingly real that the EU's required maximum landfill rate for municipal waste will not be met.

9 billion tax on plastic - costly lack of plastic recycling

Failure to meet EU targets for recycling, preparation for re-use and landfilling of municipal waste may give rise to penalties imposed by the CJEU in the future. NIK also points out that Poland's realistically achieved recycling levels may be lower than shown. This is all due to the poor quality of the data collected and obtained from the BDO, which form the basis of the calculations.

Poland is already paying high fees from the so-called plastic tax calculated on the weight of plastic packaging waste that has not been recycled. According to the Ministry of Finance, between 2021 and 2024, Poland paid around PLN 9 billion to the EU budget from the plastic tax.

What does the EU review of environmental policy implementation 2025 say about this?

The publication of the NIK report coincided with the release of the results of the fourth review of the implementation of environmental policy (EIR) in EU Member States. The most important event for Poland was identified as a significant reduction in the use of plastic bags for purchases per capita. This rate fell from 23 units per capita per year in 2019 to 6.6 units in 2022.

The review highlighted that since joining the Community, Poland has made significant progress in environmental protection. However, our country still faces many challenges, the key ones being the improvement of air quality and the gradual implementation of GOZ.

• The current air quality raises a number of issues and concerns, mainly due to exceedances of the limit values for NO2 and PM10 concentrations and the target values for ozone, arsenic and benzo(a)pyrene.
• Poland is at risk of failing to meet the targets set out in the Framework Directive, i.e. 55% PDPU and municipal waste recycling and 65% packaging waste recycling.

European Commission intensifies action to support transition to GOZ

2 July 2025. The European Commission has announced the launch of a series of initiatives to accelerate the European Union's transition to the GOZ. These are a prelude to the development of a circular economy act, scheduled for adoption in 2026, the Commission said in its communication:

The future act will support the EU's goals under the Competitiveness Compass and Clean Industrial Order to double the share of recycled materials in the EU economy by 2030 and become a global leader in the circular economy.

The new package of activities includes:

• digitisation of the EU waste shipment system - going completely paperless from 21 May 2026,
• Consultation on the harmonisation of the classification of the so-called green list of waste,
• an evaluation of the WEEE Directive on waste electrical and electronic equipment and the gaps in collection and recycling of electro-waste that were perceived after the introduction of the Directive.

Sources:

1. NIK, Implementing the circular economy. Information on the results of the audit, https://www.nik.gov.pl/plik/id,30907,vp,33980.pdf
2. Review of the implementation of the Environmental Policy 2025, https://op.europa.eu/webpub/env/eir-country-reports-summaries/en/poland.html
3. Key actions initiated to develop a circular economy, https://ec.europa.eu/commission/presscorner/detail/pl/ip_25_1710