SUMMARY

• On 7 September, FESI participated in a high-level meeting with Director-General Eric Mamer of DG ENV and Deputy Director-General Valère Moutarlier of DG GROW, alongside many high-level Commission officials.
• The meeting focused on recycled content requirements under ESPR, and in particular on our proposed aggregated average approach (also previously mentioned as portfolio-level) to recycled content compliance calculation.‍
• Overall, the outcome of the meeting can be considered positive. While the Commission has not fully accepted the approach at this stage, DG ENV and DG GROW appeared more open than in previous technical-level discussions and expressed willingness to consider further data and evidence, particularly regarding the potential benefits for SMEs.

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MORE INFORMATION

The meeting brought together the coalition of associations supporting the aggregated average approach (FESI, EBCA, EuroCommerce and EURATEX) with very senior officials from both DG ENV and DG GROW. From DG ENV, participants included Director-General Eric Mamer, Aurel Ciobanu-Dordea (Director for Circular Economy), Matjaž Malgaj (Head of Unit), and policy officers Carsten Wentink and Jana Hrčková. From DG GROW, Deputy Director-General Valère Moutarlier, Stefano Soro(Head of Unit), and António de Sousa Maia (Legal Counsel) were present.

During the meeting, the associations reiterated that an aggregated average approach (what we previously rereferred to as portfolio-level compliance calculation) would assess recycled content compliance across an operator’s in-scope products, rather than requiring each individual product to meet the same recycled content threshold.

FESI and the other associations underlined that this approach could:

• allow companies to allocate recycled fibres where technically feasible, while preserving product quality, durability and performance;
• support higher overall recycled content ambition over time;
• reduce disproportionate tracking, certification and verification burdens linked to strict product-level compliance;
• remain compatible with the flexibility provided under the ESPR framework.

A key point from the discussion was the Commission’s request for further concrete evidence. In particular, the Commission expressed interest in being “convinced” through data and practical arguments that an aggregated average approach would be beneficial, especially for SMEs.

The Commission presented three main arguments against the introduction of an aggregated average approach, which will need to be addressed in FESI's subsequent advocacy material and initiatives. Specifically, the Commission argued:

1. First, that the aggregated average approach was that SMEs across Europe may prefer the original product-level approach. As this point has yet to be proven, FESI will carry out some internal research on SME positioning on the matter.
2. Second, that  the approach would ultimately affect consumer choice, leading them to favour buying non-recycled products;
3. Finally, that such an approach would incentivize the use of synthetic fibers over natural fibers, going against the principles of the circular economy.

Nevertheless, the overall outcome of the meeting can be considered an important positive development. While it does not amount to acceptance of the aggregated average approach, it marks the first clear opening from the Commission to consider further evidence and arguments on this option, following previous technical-level discussions where the approach had simply not been considered feasible. This opening reflects the sustained advocacy efforts carried out by FESI and the wider industry coalition; at the same time, it also confirms that the coming period will be particularly important for advocacy action, as further evidence and practical arguments will be needed to support the case for this approach.

Following the meeting, FESI also participated in a coalition follow-up call on 11 September to discuss next steps in the advocacy strategy.

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NEXT STEPS

In the coming weeks, the coalition plans to organise another meeting with DG ENV and GROW's experts to discuss the more technical aspects of the aggregated average approach, including a clearer definition of how it would work in practice.

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