Recycled Content Requirements for Plastic Packaging: Minimum Quotas, Calculation and Exemptions under PPWR

Which minimum quotas apply from when?

The PPWR establishes staged minimum recycled content requirements for plastic packaging. The relevant factor is the packaging category:

From 2030:

• Contact-sensitive packaging made of PET: 30 % recycled content (based on the plastic weight of the packaging)
• Other contact-sensitive plastic packaging: 10 %
• Single-use plastic bottles: 30 %
• All other plastic packaging: 35 %

From 2040, the quotas increase significantly:

• Contact-sensitive packaging made of PET: 50 %
• Other contact-sensitive plastic packaging: 25 %
• Single-use plastic bottles: 65 %
• All other plastic packaging: 65 %

These quotas apply to packaging first placed on the EU market from the respective cut-off date.

How is the recycled content calculated?

The basis is the mass fraction of post-consumer recyclate (PCR) in the total weight of plastic in the packaging unit. Pre-consumer recyclate (production waste recirculated within the same facility) does not generally count towards the mandatory figure – what matters is secondary raw material that has passed through the consumer cycle.

The calculation is performed at the level of the individual packaging unit, not across the product portfolio. Mixed plastics are broken down by plastic type; the weight of each plastic fraction is assessed separately.

For documentation purposes you will need: 1. Weight data per plastic component of the packaging 2. Certificates or supplier evidence of PCR content (e.g. in accordance with ISO 14021 or a recognised industry scheme) 3. Declaration of conformity from the entity first placing the packaging on the market

How must the recycled content be indicated?

The PPWR requires the recycled content to be indicated on the packaging – or, where technically not feasible, on accompanying documents. The indication must be machine-readable (e.g. QR code, Data Matrix) and must reference a standardised digital product passport format once this has been established by the Commission through delegated acts. Until then: textual or symbolic indication on the packaging, supplemented by internal documentation.

Exemptions and special provisions

The following packaging types are exempt from the minimum quotas or benefit from different transitional periods:

• Packaging in direct contact with food for which no food-law-approved recyclates are available (proof of non-availability required)
• Packaging for hazardous substances under the CLP Regulation where recyclate would compromise product safety
• Very small packaging (empty volume under 50 ml) pending a transitional arrangement yet to be specified

What to do if no suitable recyclate is available?

If a food-grade or technically suitable recyclate is not available on the market, a company may invoke a reasoned exemption. The requirement: the evidence must be actively compiled – market research, supplier enquiries, documentation of findings. A blanket invocation of non-availability without supporting evidence will not be accepted. The European Commission and national authorities may limit the exemption in time and review it annually.

Practical note: Start now with supplier surveys on PCR content and establish a materials database. For a binding legal assessment of your specific packaging situation, consult your competent Chamber of Commerce and Industry (IHK).