PPWR Question

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

The obligation to declare the recycled content in plastic packaging is not yet in force under current law. It depends on delegated acts of the European Commission (Art. 7(8) of Regulation (EU) 2025/40) that have not yet been adopted. Mandatory minimum quotas for recycled content will only apply from 2030.

Nevertheless, voluntary documentation is worthwhile today:

Calculation basis (for voluntary declaration or preparation)

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 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 deadline. Without reliable supplier data you may not declare a positive recycled content.

Certification

For robust documentation, certification under recognised standards such as ISCC PLUS, RecyClass or DIN SPEC 91446 is recommended. These certificates demonstrate recyclate traceability and protect you during future regulatory inspections.

For a binding assessment of your specific situation, please contact your local Chamber of Commerce and Industry.

Stand: 07.08.2026 · geprüft von Erik Eggerth

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