Procter & Gamble

We welcome the legal certainty provided by the harmonisation of rules for the calculation and verification of recycled content in plastic packaging. This is essential for the Single Market in packaged goods. Divergent national approaches would create additional administrative burdens that distort competition and result in uncertainty throughout the value chain. Any calculation method should be technology neutral so as not to disadvantage any specific recycling technologies. Mass Balance Accounting (MBA) needs to be recognised as the appropriate tool by which to allocate recycled content. This is necessary where recyclates are processed alongside other raw materials and the physical…

Article 7(3) explicitly permits the use of recycled content from third-countries subject to the specific conditions mandated in Article 7(10). As a consequence, the Implementing Act should strive to be fundamentally permissive in nature, rather than a construct that effectively prohibits international trade in post-consumer recyclate. Article 7(10) also requires equivalence in standards of environmental and human health protection. The possibility that certain (suitable) countries could be subject to some form of a general recognition of equivalence (without the need for additional compliance requirements), should be considered. There is precedence for such a blanket approach. Regulation…

The sustainability assessment and resulting key criteria for plastic recycling technologies should be technology neutral, so as to permit (rather than hinder) innovation in support of a circular plastics economy. This requires a focus on objective and transparent indicators of performance rather than an a priori preference for a specific technology per se. Different types and forms of plastic waste will require different recycling solutions. A degree of complementarity of recycling technologies should be envisaged across different waste streams. This is acknowledged in Recitals 5 and 32 of Implementing Decision EU/2026/1425 which recognise that chemical recycling can complement mechanical…

Here the main EU policy areas where P&G is active:
- EU Chemicals policy (Chemical Industry Package; REACH; Microplastics restriction; CLP; Restriction of Hazardous Substances in Electrical and Electronic Equipment, Detergent Regulation Revision, Cosmetic Regulation Review, Chemical Omnibus)
- EU Circular economy (Packaging and Packaging Waste Regulation Implementation, Circular Economy Act, Clean Industrial Deal, Sustainable Products Initiative, Batteries Regulation, Urban Waste Water Directive, WEEE Revision, Industrial Accelerator Act)
- EU Corporate Governance Policy (Deforestation Free Value Chain Regulation, Corporate Sustainability Due Diligence Directive, Taxonomy Regulation, Corporate Sustainability Reporting Directive)
- EU Consumer Policy (Unfair Commercial Practices Directive Review, Green Claims Directive, Consumer Protection Coordination Directive Revision, Digital Fairness Act, AVSMD Review)
- EU Digital Policy (Digital Fairness Act, Cybersecurity Act 2.0, Digital Omnibus)
- Copyright & Intellectual Property (Anti-counterfeiting)
- Simplification and Omnibus Directives
- EU Competition Policy
- EU Trade Policy
- Single Market Strategy and Single Market Barriers Prevention Act (28th Regime)
- EU Tax & Finance Policy (Council Directive on Ensuring a Global Minimum Level of Taxation for Multinational Groups in the Union, Un-shell Directive, Debt-equity Bias Reduction Allowances Initiative, Business in Europe: Framework for Income Taxation (BEFIT), Transfer Pricing Directive, Late Payments Directive Revision)
Note: Including any implementing and delegated acts deriving from the above