PPWR Recycled Content Targets (Article 7): the 2030 and 2040 Minimums per Packaging Category, What Counts as Post-Consumer — and How to Document It

Not every recycled material qualifies. The targets count only recycled content recovered from post-consumer plastic waste — defined as plastic waste generated from plastic products that have been placed on the market, or supplied for distribution, consumption or use in a third country in the course of a commercial activity (Article 3(1)(48)).

Production scrap from your own manufacturing that never reached the market — often called post-industrial material — does not meet that definition and cannot be counted towards the targets. Companies planning with industrial regrind should redirect their sourcing towards post-consumer streams in good time.

Article 7(1) staggers the targets across four categories: 30 % for contact-sensitive packaging made from PET as the major component and 10 % for contact-sensitive packaging made from other plastic materials (each excluding single-use plastic beverage bottles), 30 % for single-use plastic beverage bottles, and 35 % for all other plastic packaging.

Contact-sensitive packaging is packaging for products covered by specific EU regimes — including food contact, cosmetics, medical devices and medicinal products (Article 3(1)(49)).

Watch the date mechanics: the targets apply by 1 January 2030 or 3 years from the entry into force of the implementing act on the calculation and verification methodology, whichever is the latest. The Commission must adopt that act by 31 December 2026 — if it enters into force only in 2027 or later, the start of the obligation shifts accordingly.

By 1 January 2040 the minimums rise substantially: 50 % for contact-sensitive PET packaging and 25 % for contact-sensitive packaging from other plastics (again excluding single-use plastic beverage bottles), 65 % for single-use plastic beverage bottles and 65 % for other plastic packaging (Article 7(2)).

Unlike the 2030 step, the 2040 date carries no deferral mechanism in the text. The Commission will, however, review the feasibility of the 2040 targets by 12 February 2032 and may propose legislative changes.

Two reference points decide the practice. First: the targets apply to any plastic part of packaging — broken down per packaging type and format as referred to in Table 1 of Annex II. A carton pack with a plastic window is measured on its plastic part only — provided that part reaches at least 5 % of the unit's total weight (see the exemptions below).

Second: compliance is calculated as an average per manufacturing plant and year. No single packaging unit has to hit the exact percentage — what counts is the annual average of the plant producing the packaging. That gives manufacturers flexibility across batches, but demands robust, continuous material-flow records.

Article 7(4) takes several groups out of the targets entirely — among them compostable plastic packaging and packaging used for the transport of dangerous goods under Directive 2008/68/EC.

Two practical thresholds come from Article 7(5): packaging intended for contact with food is exempt where the recycled content would create a risk to human health and lead to non-compliance with Regulation (EC) No 1935/2004 — and plastic parts representing less than 5 % of the total weight of the packaging unit are out of scope altogether.

The framework stays in motion: by 1 January 2028 the Commission assesses the need for further exemptions for the categories under points (b) and (d), and it may adjust the targets by delegated act in exceptional cases where the availability or price of specific recycled plastics makes compliance excessively difficult and seriously adverse effects loom (Article 7(12) and (13)).

Compliance with the targets must be demonstrated by manufacturers or importers in the technical information concerning the packaging referred to in Annex VII (Article 7(6)). The calculation and verification methodology comes by implementing act; its rules become binding from 1 January 2029 or 24 months after the act enters into force, whichever is the latest (Article 7(11)). Until the PPWR targets take over, the recycled-content rules of the Single-Use Plastics Directive (EU) 2019/904 continue to apply to plastic beverage bottles.

That closes the loop to the declaration: the EU declaration of conformity states conformity with the requirements of Articles 5 to 12 — from 2030, recycled content is part of that statement, and the declaration must be kept continuously updated. One more lever is worth knowing: extended-producer-responsibility fees may be modulated based on the percentage of recycled content used (Article 7(7)). If you label recycled content on the packaging itself, note that the claim is voluntary but regulated — see our guide to the PPWR labelling requirements.