The new regulations fundamentally open the road to industrial-scale implementation of chemical recycling.

By : Dr. Magdalena Laabs 
CEO of Rolbatch Group | Expert in Plastics Processing, 

Recycling & LinkedIn B2B Strategies for Industry | Technical Online

July 2025 has become one of the most significant milestones in the history of European plastics policy. The European Commission has published the first fully structured implementing act regulating chemical recycling – a document the industry has awaited for years.

This decision is highly consequential because, for the first time, the EU clearly defines:

how to calculate the share of chemically recycled content,
how technologies must be verified,
what qualifies as material recovery,
what obligations fall on producers and plant operators.

Until now, many companies operated in an environment of interpretational uncertainty, and chemical processes were treated as an area without a coherent regulatory framework. The new regulations fundamentally change this landscape and, in practice, open the road to industrial-scale implementation of chemical recycling.

1. Mass balance as the mandatory standard

The central element of the act is the formal adoption of mass balance as the accounting method for allocating chemically recycled content to products.

The regulation specifies:

how recycled content must be allocated to a given product batch,
rules for accounting waste-based and virgin feedstocks,
the requirement to track material flows at every stage.

In practice, this means that companies must introduce transparent and auditable accounting systems, because demonstrating the recycled content share will depend on these systems.

This is a fundamental shift – particularly for petrochemical and chemical producers planning to co-process oils derived from chemical recycling.

2. The “fuel-use excluded” rule – the boundary between recycling and energy recovery

The new rules precisely distinguish material recycling from energy recovery.

No product that is burned as fuel can be counted as recycling.

This applies especially to:

process gases,
light fractions combusted inside the unit,
by-products that do not return to the material cycle.

Companies must now document in detail which outputs return to the material loop and which are simply used as an energy source.

3. Mandatory external audits for chemical-recycling plants

The implementing act introduces the requirement for regular, independent verification of chemical-recycling processes.

Audits will cover:

compliance of the mass-balance system with regulatory rules,
control of material flows,
feedstock classification procedures,
recycled-content allocation methodology,
completeness of documentation.

This marks a major shift for operators of pyrolysis, depolymerisation and hydrothermal processes – audits will become a permanent part of operations.

4. Rules for allocating chemically recycled content to products

The document establishes consistent rules defining when a product can be officially recognised as containing chemically recycled content.

The regulation requires:

precise accounting of waste-based and virgin feedstock proportions,
allocation of recycled content according to approved formulas,
consideration of differences between feedstock types,
detailed evidence proving compliance with process requirements.

For many companies, this will require updating internal procedures and ensuring full alignment between production, laboratory teams and compliance departments.

5. Expansion of regulatory scope – additional sectors by 2030

The July 2025 act focuses primarily on packaging streams, but the EU clearly states that similar obligations will gradually extend to:

textiles,
electronics,
automotive,
industrial packaging,
sectors requiring high-purity materials.

This means that in the coming years chemical recycling will become embedded in regulatory obligations across multiple industries.

Related : Adam Laabs writes : The Age of New Threats, The Age of Old Regulations

What does this mean for chemical and waste-management companies?

The new regulations require:

precise feedstock-quality management,
standardisation of product parameters,
implementation of mass-balance accounting systems,
training of compliance teams,
preparedness for material audits and inspections.

At the same time, this is an opportunity: companies that adapt early will gain competitive advantage.

How Rolbatch supports companies in meeting the new requirements ?

Rolbatch develops online training in fourteen languages, along with strategic and technical reports tailored to individual clients.

The scope of cooperation may include:

understanding regulatory consequences,
analysing the impact of legislation on plant operations,
assessing feedstock streams for compliance,
preparing teams for audits,
designing mass-balance models for a specific organisation.

The goal is to provide practical, actionable knowledge aligned with the company’s development strategy.

Dr. Magdalena Laabs ,European plastics policy ,July 2025 ,European Commission , New EU Regulations ,  Chemical Recycling , Rolbatch