SUPD update: clarity on PCR quotas and import regulations in the EU
The regulatory framework for packaging in Europe is currently undergoing dynamic development. As an internationally active packaging and recycling specialist, ALPLA continuously monitors these developments, classifies them and actively participates in the dialogue. This article provides an overview of current regulatory adjustments within the framework of the Single-Use Plastics Directive (SUPD) and shows how ALPLA assesses the planned regulations - particularly with regard to imports of recyclates.
SUPD remains the key legal framework for PCR targets
Even though the Packaging and Packaging Waste Regulation (PPWR) will be gradually applied from August this year, the Single-Use Plastics Directive (SUPD) is still fully in force. It currently forms the central legal basis for binding post-consumer recyclate quotas in the EU.
A recent development now provides important clarifications - in particular on the eligibility of recyclates from third countries.
New calculation methodology and adjusted definition
On 6 February 2026, the European Commission's Technical Committee gave its positive approval to the Implementing Decision on the calculation methodology for the recycled content under the SUPD. The formal publication of the final legal text is still pending, but is expected shortly. A central component of this legal act is the adaptation of the definition of post-consumer plastic waste. This clarification directly affects the question of the extent to which recycled plastics from non-EU third countries may be counted towards the European recyclate quotas.
In concrete terms, recycled plastics from non-EU third countries may not be counted towards the SUPD recycling targets until 21 November 2027. This is due to different standards, control mechanisms and infrastructures in the area of waste management and traceability outside the EU. From November 2027, recycled plastic from certain third countries can be recognised as post-consumer material under defined conditions. This applies to materials from:
- third countries to which the OECD Decision on Transboundary Movements of Waste applies, or
- third countries with which the EU has concluded corresponding agreements or arrangements.
This gradual approach is intended to ensure the environmental integrity of the recyclate quotas and at the same time create legal certainty.
Implementation at Member State level
As the SUPD is a directive, practical implementation will take place at Member State level. The extent to which the new implementing act will have direct effect or whether additional national implementation measures are required has not yet been finalised. Further clarity is expected with the publication of the final text. Coordination with national authorities, system participants and industry associations will then be necessary to ensure the most harmonised application possible within the EU.
Strengthened monitoring of recyclate imports
Parallel to adapting the definition, the European Commission is working on additional measures to improve the monitoring and transparency of recyclate imports as part of the so-called "Winter Package".
An import monitoring tool was already introduced in 2025 to systematically record trade flows of recyclates. The establishment of a task force to specifically analyse plastic imports - along with other product categories - is also being discussed for 2026. The aim is to enable data-based decisions and, if necessary, take measures to protect the European single market and the industrial base. Industry associations and manufacturers are to contribute market information.
Dedicated customs codes for virgin and recycled materials
In addition, the Commission is planning a proposal to introduce separate customs tariff codes for virgin and recycled polymers in the first half of 2026. Such a differentiation would:
- make trade flows more transparent,
- make inconsistencies in import declarations easier to identify,
- reduce the risk of virgin material being falsely declared as recycled material,
- strengthen traceability along global supply chains.
Classification from ALPLA's perspective
From ALPLA's perspective, clear definitions, transparent verification systems and consistent enforcement are key prerequisites for credible recycled content quotas. This is the only way to create a resilient framework for investment in European collection, sorting and recycling infrastructure. At the same time, it is important to take a differentiated view of international trade flows and ensure fair competitive conditions. A sustainable circular economy requires reliable standards, both within the EU and in cooperation with qualified partners in third countries.
ALPLA will closely monitor further regulatory developments and continue to play an active role in the dialogue with politicians, authorities and industry representatives - with the aim of helping to shape a robust and economically viable circular economy for plastic packaging.
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