IN Brief:
- The European Commission opened evidence gathering on three PPWR recycled content measures on 14 August.
- The work covers calculation and verification, sustainability criteria for recycling technologies, and treatment of third-country recyclate.
- PPWR sets increasing recycled content requirements for plastic packaging from 2030 and 2040.
The European Commission has opened evidence gathering on three measures that will determine how recycled plastic content requirements under the Packaging and Packaging Waste Regulation are calculated, verified, and applied across the packaging supply chain.
The calls for evidence opened on 14 August, two days after PPWR became generally applicable across the EU, and feedback is due to close on 16 September. The measures concern the calculation and verification of recycled plastic content, sustainability criteria for recycling technologies, and the treatment of material collected or recycled outside the EU.
The consultation does not itself establish the final calculation method. PPWR already contains minimum recycled content requirements, but secondary legislation is still needed to define how companies demonstrate compliance consistently and how qualifying recycled material is accounted for.
That distinction is important for food and beverage packaging because Article 7 establishes different targets according to packaging type and application. From 2030, contact-sensitive packaging whose major component is PET is subject to a 30% minimum recycled content requirement, excluding single-use plastic beverage bottles.
Other contact-sensitive plastic packaging is subject to a 10% minimum, single-use plastic beverage bottles to 30%, and other plastic packaging to 35%. The regulation raises those levels further in 2040, while providing exemptions for specified applications, including certain packaging intended for foods for infants, young children, and special medical purposes.
For manufacturers, the percentage on a material specification is only one part of the compliance problem. A harmonised method has to define where the calculation boundary sits, what evidence is acceptable, how plant-level information is treated, and how claims made by resin suppliers, recyclers, converters, and packaging manufacturers are carried through the chain.
Food packaging makes that work more complicated because recycled material intended for contact-sensitive applications must also satisfy the relevant food-contact requirements. A technically recyclable polymer is not automatically suitable for every food application, and availability of compliant recyclate can differ sharply between PET and other plastics.
The Commission’s work on recycling technologies is intended to set sustainability criteria for the processes supplying recycled plastic into packaging. That moves part of the compliance burden upstream, because the legitimacy of a recycled content claim depends on the material’s origin and processing route as well as the quantity incorporated into the finished pack.
Imports create a separate verification challenge. Recycled plastic, converted packaging, and packaged goods routinely move across borders, while the regulation requires rules for determining whether material originating outside the EU meets equivalent requirements. The forthcoming measure will therefore influence importers as well as European recyclers and converters.
Traceability becomes increasingly important under that model. A food company buying a finished tray, bottle, film, closure, or pouch may be several commercial steps removed from the business that recovered and processed the recycled polymer. Documentation has to survive those handovers if the final packaging specification is to carry an auditable recycled content figure.
PPWR’s wider requirements add to that documentation burden. The regulation generally began applying on 12 August 2026 and introduces measures covering recyclability, material reduction, reuse, labelling, chemicals in food-contact packaging, and producer responsibility, with different provisions taking effect at different points through the implementation timetable.
The Commission’s own PPWR material describes increasing recycled content targets for 2030 and 2040 as a central part of the new packaging framework. The legislation therefore sets the direction clearly even while some of the accounting machinery remains under development.
Packaging buyers will need the detail before the 2030 thresholds arrive. Converters making decisions about recycled resin supply, food manufacturers agreeing future packaging specifications, and importers sourcing packaging from outside the EU all need to know what evidence will count and how it will be checked.
The method will also affect internal audit routines, supplier declarations, and the evidence retained against individual packaging specifications.
The consultation period provides the Commission with technical and commercial evidence before those measures are finalised. Once adopted, the calculation rules will turn recycled content from a headline percentage into a production and audit requirement — with the record keeping behind the figure becoming almost as important as the polymer itself.
