JBCE and JP4EE Feedback on Third-country Equivalence for Recycled Content

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 third-country equivalence for recycled content under the Packaging and Packaging Waste Regulation (PPWR).

JBCE and JP4EE support the Commission’s objective of ensuring the credibility, traceability and transparency of recycled content placed on the EU market. At the same time, the framework should remain practical and proportionate, recognising that reliable and recycled materials sourced through international supply chains will play an important role in achieving the recycled content targets established under the PPWR.

We call for:
• Equivalence based on outcomes: Third-country equivalence should be assessed on the basis of outcomes rather than formal alignment with EU systems. The assessment should focus on reliable information, traceability and effective fraud-prevention controls, while recognising different systems that provide a comparable level of assurance.
• A flexible and efficient compliance framework: Economic operators should be able to demonstrate compliance through existing records, recognised documentation and traceability systems. The framework should avoid unnecessary duplication of audits, certification and verification requirements and apply a targeted, gap-based approach where additional information is required.
• Support for international supply chains and fair competition: Requirements should be practical, proportionate and non-discriminatory, supporting participation by a diverse range of suppliers, including SMEs. Compliance obligations should be based on risk and evidence rather than the location of suppliers or the origin of materials.

For more information, please contact info@jbce.org