The European debate on the circular economy is increasingly focusing on End-of-Waste (EoW) rules, namely the point at which a material, after processing, ceases to be waste and becomes a secondary raw material for further industrial use. The design of these rules will also be important for the further development of chemical recycling of plastics, new investments, and the functioning of the European market for secondary raw materials.
Chemical recycling is now regarded as an important complement to mechanical recycling, particularly for materials that are difficult to process through conventional recycling methods. These include mixed plastics, multilayer packaging, coloured materials, composites, and residues from mechanical recycling. Such waste is often used for energy recovery or ends up in landfill.
Unlike mechanical recycling, which preserves the polymer structure of the material, chemical recycling intentionally breaks polymers down into chemical feedstocks — such as monomers, oils, gases, or other intermediates that can be further utilised in the chemical industry. It is precisely the different nature of these processes that lies at the centre of the current European debate on EoW.
Different process, different requirements
European industry associations point out that chemical recycling cannot be assessed in the same way as mechanical recycling. While the purity of the input material plays a crucial role in mechanical processes, the chemical industry considers the quality of the resulting output material and its intended use to be more important in the case of chemical recycling.
The discussion therefore focuses on a technologically neutral approach applicable to different types of chemical recycling — from pyrolysis and depolymerisation to gasification. According to this approach, the rules should not favour a particular technology, but should instead be based primarily on the parameters of the resulting secondary raw material.
Another key issue is Article 6(1) of the Waste Framework Directive (WFD), which lays down the basic conditions for End-of-Waste status. The material must be intended for a specific purpose, there must be a market or demand for it, it must meet technical and legislative requirements, and its use must not have an adverse impact on human health or the environment.
According to representatives of the chemical industry, outputs from chemical recycling meet these conditions. The emphasis is therefore placed primarily on the quality of the output material and its further use within the chemical industry, rather than on strictly defined purity limits for input polymers, which are mandatory for mechanical recycling.
Debate over European harmonisation
A major issue remains the differing interpretation of EoW rules among Member States. A material may therefore be regarded as a secondary raw material in one country, while still being classified as waste in another. This complicates cross-border transport of materials, recycling reporting, and certain permitting procedures.
Industry associations therefore support the creation of a harmonised European framework that would provide greater legal certainty and support the functioning of the single European market for secondary raw materials.
The debate has also been intensified by the draft European implementing regulation establishing End-of-Waste criteria for plastic waste. The public consultation took place between 23 December 2025 and 26 January 2026 and received 145 comments. However, the proposal focuses primarily on mechanical recycling and technologies in which the molecular structure of polymers is not altered. Chemical recycling is not yet included in the proposal.
European industry associations, including CEFIC, are therefore proposing several possible approaches. One option is to establish EoW primarily under the Waste Framework Directive (WFD). Another possibility is the adoption of a separate implementing act focused on chemical recycling or the inclusion of general principles for outputs from these processes within the existing proposal for EoW criteria for plastic waste.
The growing role of chemical recycling
The sector still represents a relatively small but rapidly developing segment in Europe. Most current capacities are based on pyrolysis technologies, although projects focused on depolymerisation — including RECIVONE technology — and gasification are also gradually developing.
Further development is also supported by new European legislation, particularly the PPWR with its recycled content requirements for plastic packaging, as well as the recognition of Recycled Carbon Fuels (RCF) under RED III.
According to industry representatives, a clear legislative framework for EoW could increase the volume of plastic waste processed through chemical recycling in Europe from approximately 0.3 million tonnes today to around 3 million tonnes annually by 2030.
At the same time, the European debate continues to stress that chemical recycling is not intended to replace mechanical recycling, but rather to complement it for materials that are technologically or qualitatively problematic for conventional recycling processes.
This is precisely why the issue of End-of-Waste is gaining increasing importance today — not only from a legislative perspective, but also for the future functioning of the European market for secondary raw materials.
By Lenka Linhartova, Co-founder of RECIVONE