A new rule that is changing the game
On August 6, 2026, the EU published TBT notification G/TBT/N/EU/1229 through the WTO, releasing the draft Commission Implementing Regulation that unifies end-of-waste status rules for thermoplastic plastic waste across the EU. The core significance of this document is that it sets a unified end-of-waste standard for recycled PP, PE, PET and other thermoplastics. Once certified, recycled plastics are no longer legally regarded as waste and can circulate as commodities like ordinary raw materials.
For Chinese suppliers exporting recycled sheets, modified plastics, and recycled composite materials, this is not merely an environmental regulation update. It is a compliance threshold that directly affects customs clearance efficiency and order competitiveness. EU importers have already begun to include this set of compliance documents in the core checklist for supplier audits.
What the new rules cover and what they do not
The regulation applies to all waste thermoplastic polymers and their blends, regardless of polymer type and waste source, and covers two processing modes: mechanical recycling and solvent-based recycling. The specific plastics involved include PE (polyethylene), PET (polyethylene terephthalate), PP (polypropylene), and PS (polystyrene), among the most common thermoplastics. Thermosetting plastics and non-plastic materials are outside the scope.
Chemical recycling is currently not included in the scope of this regulation, and simple sorting and inspection alone does not constitute valid recycling. Recycled material can obtain end-of-waste status only when used to produce new plastic products. If used for energy recovery, backfilling, or chemical feedstock, it remains regulated as waste.
Key changes facing exporters
Every batch needs an “electronic ID”
This is the most direct impact on exporters. The regulation requires that each batch of recycled plastic be accompanied by an electronic declaration of conformity in the uniform format set out in Annex II, which circulates with the trade chain. The declaration must include key fields such as recycler information, batch number of the recycled plastic product, polymer type, and conformity assessment results.
When receiving goods from third-country suppliers, EU importers must verify the supplier’s quality management system certification documents. This means the old approach of relying on a single test report no longer works, and importers will increasingly require suppliers to provide systematic compliance evidence.
Non-EU suppliers must pass third-party audits
The regulation sets additional requirements for recycling companies outside the EU: non-EU suppliers must establish a complete quality management system covering raw materials, recycling processes, and output quality, and have it verified by a recognized conformity assessment body or environmental verifier. This system must cover all links, including raw material procurement monitoring, process monitoring, finished product sampling, customer feedback records, and employee training. It must undergo a review every three years, and all records must be kept for at least five years.
For Chinese recycled plastics processors, this means engaging qualified third-party certification bodies in advance to complete system development and review. The existing EN 15343 certification system on the market is highly consistent with the new rules in traceability logic and can serve as an important foundation for preparation.
Impurity thresholds and single-polymer restrictions
The new rules set clear impurity control standards: total foreign impurity content in compliant recycled material must be below 1.9%, stricter than the previous 2% limit for B3011 waste. At the same time, recycled plastics shipped outside the EU may only contain a single thermoplastic polymer, except for mixtures of PE, PP, and PET.
This means the precision requirements for sorting and washing are further raised. If exported products exceed impurity limits or are not a single polymer, they will not only fail to obtain end-of-waste status but may also be subject to cross-border controls under waste rules, significantly increasing customs clearance risk.
Special note for exporters of recycled sheets and modified plastics
Recycled sheets and modified plastics need to obtain end-of-waste status at the upstream raw material stage. If the PCR recycled material used has not itself obtained end-of-waste certification, downstream finished products may face the risk that their recycled content is not recognized in the EU market.
When purchasing, EU industrial buyers will audit the completeness of documentation for PCR recycled materials batch by batch. The probability of non-compliant cargo being detained at EU ports increases significantly.
One background worth noting: before November 21, 2027, recycled PET originating from non-EU countries cannot count toward the recycled content targets under the EU Single-Use Plastics Directive. Although this is not directly equivalent to the effect of the end-of-waste regulation, EU buyers will consider the “compliance value” of recycled materials when selecting suppliers. If Chinese suppliers’ recycled materials cannot help buyers meet their legal recycled content obligations, purchasing willingness will decline significantly.
What companies should do now
First, start building a batch traceability system. Establish a complete batch coding system from waste plastic collection, crushing, pelletizing, and modification processing to finished product shipment, ensuring one-to-one correspondence among each batch of raw materials, semi-finished products, and finished products. Procurement documents, sorting records, production process ledgers, quality inspection reports, and inbound/outbound warehouse documents must be kept complete.
Second, advance third-party system review. Contact qualified certification bodies to conduct a pre-audit and rectification according to the new rules’ quality management system requirements. Focus on three major modules: raw material admission control, recycling process specifications, and finished product quality testing.
Third, standardize the issuance process for electronic declarations of conformity. Study the declaration template format in Annex II in advance and establish an internal issuance and archiving mechanism. Electronic declarations must circulate with the goods, and the company’s original records must be kept for at least five years.
Fourth, keep compliance information synchronized with EU buyers. Proactively explain to customers your progress in end-of-waste certification preparation and provide verification paths for quality management system certification documents, avoiding order loss caused by information asymmetry.
The new rules are proposed to enter into force on the 20th day after publication in the Official Journal of the EU, with full implementation six months after entry into force. Given that third-party audits and system development take time, it is not too early to start preparations now.