How do I measure and declare the recycled content in my plastic packaging?

Under Regulation (EU) 2025/40, you are required to indicate the recycled content in plastic packaging from 12 August 2026 onwards — either on the packaging itself or on the QR code carrier — even if that content is 0 %. Deliberate non-disclosure is not an option.

Calculation basis

The recycled content is calculated as the proportion by mass of post-consumer or post-industrial recyclate used, relative to the total weight of the plastic component of the packaging. The decisive figure is the share actually processed, not purchased certificates or allocation values without physical incorporation.

Simplified formula: Recycled content (%) = Mass of recyclate ÷ Total mass of plastic × 100

Missing supplier data

If your packaging supplier does not document the material composition, you must actively request this information — in writing and with a set deadline. Without reliable supplier data you may not declare a positive recycled content; you must state 0 %. Unsubstantiated manufacturer statements are not sufficient.

Certification

For robust documentation, certification under recognised standards such as ISCC PLUS, RecyClass or DIN SPEC 91446 is strongly recommended. These certificates demonstrate recyclate traceability and protect you during regulatory inspections. Mass-balance approaches (e.g. for chemical recycling) are subject to separate allocation rules.

Declaring 0 % correctly

A recycled content of 0 % is not a disadvantage as long as it is declared correctly. Incorrect information or missing labelling can trigger fines.

For a binding assessment of your specific situation, please contact your responsible Chamber of Commerce and Industry (IHK).