Plastics Europe shares the European Commission’s climate ambition and commitment to prevent carbon leakage. We believe that, in its current form and timing, extending CBAM to plastics and organic chemicals would not achieve these aims and could instead undermine the EU’s industrial transformation by imposing high emission and administrative costs, leaving critical scope gaps, and eroding competitiveness and support at a critical time for the plastics industry.

Brussels: 06 November 2025

Plastics Europe welcomes the publication of a draft Implementing Decision on EU harmonised rules for calculating, verifying and reporting recycled content in single-use plastic beverage bottles. We support in particular the Commission’s explicit recognition of chemical recycling as a complement to mechanical recycling, its support for a credit-based fuel-use exempt mass-balance methodology in existing and new assets, and the intent to bring forward clear and implementable rules.

The plastics industry as vital contributor to Europe’s economy and central facilitator of a low-carbon future faces significant increases in energy costs, further exacerbated by the CO₂ costs embedded in electricity prices. Since 2020, the sector was not eligible any more for a compensation of these indirect costs under State Aid Guidelines. Considering the significant changes in market conditions, CO₂ prices etc., Plastics Europe calls for a reassessment of the eligibility for the plastics sector (NACE 20.16) and precursors (NACE 20.14) in the framework of the State Aid Guidelines.

Any future European Industrial Deal to complement the Green Deal should include measures to develop sustainable carbon markets and boost sustainable carbon availability while deploying instruments for imports to ensure a fair global level playing field. Creating market incentives in product regulation is key for the transition to sustainable carbon sources. These actions can work together with the update to the EU's Bioeconomy Strategy as well as the ongoing implementation of the Circular Economy Action Plan and the EU Industrial Carbon Management Strategy. Read the full position paper below.

Plastics Europe supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular plastics target will all be needed.