JBCE and JP4EE Feedback on the Rules for the Calculation and Verification of Recycled Content in Plastic Packaging
On 15 September 2026, JBCE and the Japanese 4EE industrial associations (JP4EE) published their position paper in response to the European Commission’s consultation on rules for the calculation and verification of recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR).
JBCE and JP4EE support the Commission’s efforts to establish harmonised rules for the calculation and verification of recycled content in plastic packaging. A credible and practical framework is essential to support the implementation of recycled content targets and strengthen confidence in recycled content claims. At the same time, the framework should reflect the realities of global supply chains, where different economic operators perform different functions and have varying responsibilities and access to information.
We call for:
• Clarified responsibilities: Responsibilities should be limited to information that each economic operator can reasonably control and verify. Verified information should be transmitted through the supply chain and relied upon by downstream operators without unnecessary duplication of certification or verification activities.
• Harmonised and practical calculation and verification methodologies: Calculation and verification methodologies should reflect practical production and procurement realities, permit appropriate allocation and mass-balance approaches, and remain aligned, where appropriate, with relevant international and European standards.
• Proportionate verification requirements: Existing certification and chain-of-custody systems should be utilised wherever possible, and verification requirements should remain proportionate, risk-based and practical, avoiding unnecessary administrative burdens and duplicate verification efforts.
For more information, please contact info@jbce.org