The European PET value chain is urging the adoption of the prEN 18120 series on design for recycling and recyclability assessment protocols for plastics packaging, developed by CEN TC261/SC4/WG10 Design for Recycling under a mandate from the European Commission. According to the industry, these standards constitute the technical backbone for the delegated act that the Commission is expected to adopt by 1 January 2028 under the Packaging and Packaging Waste Regulation (PPWR, EU 2025/40). The work is presented as the outcome of a three-year process involving nearly 150 expert meetings focused on plastics, including more than 25 meetings exclusively on PET bottles, and the participation of hundreds of specialists from across the packaging ecosystem, among them material producers, converters, brands, retailers, recyclers, academia, testing laboratories, technology providers and national standardisation bodies.
The initiative is framed as a comprehensive and consensus-based effort, and the European PET industry is calling on the Commission to confirm its support shown over the past three years by adopting these standards as the basis for the recyclability performance assessment foreseen in PPWR article 6. The signatories underline that the standards are intended to align design-for-recycling requirements with operational recycling practices and to provide a harmonised reference point for evaluating packaging recyclability across the EU internal market.
A consensus-based, value-chain-wide standardisation process
The development of prEN 18120 and related standards took place within the formal CEN framework, which the PET sector describes as a neutral, rules-based platform where each technical element was examined repeatedly, supported by data and adopted according to established consensus rules. Recycling industry representatives, including their representative association at both national and European level, were reported to have participated fully in the process, engaging in discussions and contributing technical expertise.
According to the PET value chain, every requirement in EN 18120 and associated standards passed through consensus, which implies that no element could be included without agreement from all participating sectors, recyclers included. The standards are said to integrate real-world operational experience and many years of best practice and guidance, including almost two decades of technical work from the European PET Bottle Platform (EPBP) and the Tray Circularity Evaluation Platform (TCEP). The PET chain was represented by Petcore Europe and many of its members, such as retailers, brand owners, raw material producers, converters and recyclers, participating via national standardisation bodies.
On this basis, the industry argues that the resulting documents reflect both the realities of packaging production and the operational needs of European recyclers, and that the process has provided a structured channel for input from all relevant segments of the PET value chain.
Foundation for PPWR implementation and circularity targets
The prEN 18120 series is presented not as an endpoint, but as the first harmonised technical foundation in Europe for improving recyclability at scale, enhancing material quality, providing investment certainty and enabling the PPWR recyclability and recycled-content targets for 2030. For packaging manufacturers and brands, the standards are expected to deliver clear, unified design criteria that reduce fragmentation and help bridge long-standing gaps in the internal market.
For recyclers, the documents aim to offer greater predictability regarding incoming material streams, support for high-quality secondary output and a mechanism to guide future investment decisions. In the assessment of the PET industry, this constitutes the strongest shared technical basis so far developed jointly across the plastics value chain for design for recycling and recyclability assessment.
Permanent platform to support deployment and revision
Although described as robust and technically grounded, the current standards are regarded by the PET sector as a first version that will need to evolve in parallel with innovation in materials, sorting technologies and recycling processes. To structure this evolution, the creation of a permanent PET value chain platform, led by Petcore Europe, is being proposed.
The tasks envisioned for this platform include supporting and monitoring the deployment of the standards, observing their impact on quality, yield and economics along the recycling chain, and tracking technological developments that should be reflected in future revisions for both design-for-recycling criteria and recyclability assessment protocols. The platform is also intended to collect feedback from brand owners, collectors, converters, pre-processors, recyclers and other stakeholders and to aggregate operational experience that can feed into future updates of the standards within the CEN framework.
The first formal revision of the standards is expected before the end of 2027. Petcore Europe has declared its commitment to contribute operational insights, scientific data and field results in order to further strengthen future versions. The PET value chain also signals that it will continue to work closely with the European Commission, the relevant Directorates-General and other stakeholders so that the standards evolve in line with Europe’s circularity objectives and technological progress.
Clarifying the development process and addressing misconceptions
The PET industry notes that several misconceptions about the standards development process have circulated recently and states that it is important for policymakers to have a clear view of the underlying facts. A series of quotations is contrasted with factual statements provided by the value chain.
Recycler involvement
In response to the assertion that the standards were developed without adequate recycler input, the PET industry states that recyclers, including various extended producer responsibility (EPR) systems such as Citeo and Corepla and recycler organisations, participated in every phase of drafting, discussion and approval. Given that the CEN process is based on consensus, the argument is that no provision could have been adopted without the agreement of recycler representatives.
Data basis and use of existing guidelines
On the claim that the standards rely on limited or biased data, it is stated that the documents were built using multiple scientific data sources, inter-laboratory inputs, industrial testing and shared datasets from across the value chain. Where there were variations in the data, CEN is said to have applied conservative and technically robust criteria, documented in the standardisation files.
To the criticism that existing guidelines were ignored, the PET industry stresses that guidance documents and the data used to create them, including those developed by Ceflex, EPBP, TCEP, RecyClass and others, were actively considered and discussed. At the same time, CEN standards are required to reflect the harmonised needs of the entire European PET value chain, encompassing multiple recycling technologies, brands, materials producers, national practices and existing sorting infrastructure, rather than any single operational model.
Compatibility, recyclability and future improvements
Facing the statement that the standards endorse materials or components that recyclers cannot handle, the PET sector replies that all compatibility assessments were evidence-based, validated in working groups and aligned with the PPWR definition of recyclability at scale. When differences emerged between industry guidelines and real-life variability across Europe, the approach described is one of consensus-driven and technically neutral criteria.
Regarding the view that the standards weaken recyclability requirements, the PET value chain argues that they instead strengthen such requirements by introducing harmonised design rules across the EU, defining performance grades and creating the basis for the Commission’s delegated acts. It is emphasised that this marks the first time in EU policymaking that recyclability requirements are anchored in harmonised European standards.
Addressing the suggestion that the standards cannot be improved, it is underlined that, like all CEN standards, they will undergo systematic revision informed by industrial data, observed sorting and recycling performance and technological advances. Preparations are said to be under way within the value chain to support this process in an efficient and transparent manner.
Call for coordinated implementation of recyclability standards
The European PET industry positions the CEN standards as a shared achievement and a shared responsibility within the broader context of Europe’s transition to a circular economy. The documents are said to give manufacturers greater clarity on design expectations, recyclers a more structured input mechanism and the European Commission a harmonised technical basis for implementing the PPWR.
In this view, coordinated deployment and continuous improvement of the standards can provide a credible path for the EU to meet its 2030 targets related to packaging recyclability and recycled content. The PET value chain confirms its commitment to continued cooperation within the CEN process and with EU institutions and stakeholders in order to support the strengthening of recyclability performance across European plastics packaging systems.
