PPWR 05 - How Much Recycled Material Will I Need to Use?

“We already use 30% recycled content. We’re ready.”

A plastics packaging plant has been buying regrind from a trusted supplier for years.
The technical data sheet says: “Contains 30% recycled content.”
Purchasing is happy. Management is happy. And the conclusion seems obvious:
“We’re already ready for PPWR.”
Maybe. Maybe not.
Because Regulation (EU) 2025/40 - PPWR - doesn’t simply ask “Do you use recycled plastic?” The question is far more precise: what kind of recycled material, where does it come from, how is it documented, which packaging category does it fall under, and what percentage applies to that category?
The answers can change the whole calculation.
This is the central question of PPWR 05: how much recycled material will I actually need to use, from when, and how will I prove it?


Four categories, four different targets

Article 7 of PPWR does not treat all plastic packaging the same way. The Regulation sets out four main categories, each with different thresholds for 2030 and 2040.

Single-use plastic beverage bottles
2030 – 30%  ·  2040 – 65%

Contact-sensitive PET packaging, other than the beverage-bottle category above
2030 – 30%  ·  2040 – 50%

Contact-sensitive packaging made predominantly from plastics other than PET
2030 – 10%  ·  2040 – 25%

Other plastic packaging, not covered by the categories above
2030 – 35%  ·  2040 – 65%

One difference jumps out immediately. Why 30% for contact-sensitive PET, and only 10% for other contact-sensitive plastics? We’ll come back to that question, because the explanation matters a great deal for the processing industry. First, though, there’s something even more important to clarify.


PCR versus PIR: the distinction that changes the whole calculation

This is probably the single most important point in Article 7 - and one of the easiest to get wrong.
In industry language we routinely use two terms: PCR - Post-Consumer Recycled - and PIR - Post-Industrial Recycled.
PPWR does not build the obligation around the general notion of “recycled material.” Article 7 refers specifically to recycled content recovered from post-consumer plastic waste. That distinction is essential.

Consider a few examples familiar to any processor:
• sprues and runners from injection moulding;
• edge trim and offcuts from extrusion or cutting;
• product rejected at quality control;
• regrind fed back into the process;
• production scrap sent to a recycler and later reintroduced into the loop.

In everyday industrial language, all of this counts as “recycled material” or regrind. But PIR from these ordinary production-waste streams does not contribute to the mandatory minimum under Article 7, because that minimum is built on content recovered from post-consumer plastic waste.
So a processor can say, quite correctly: “We use 30% recycled content.” And that 30% may still not be equivalent to 30% under the Article 7 calculation.
Which is why the first question worth asking isn’t “how much recycled material do I use?” but: “how much of the recycled material I use actually comes from post-consumer waste, and can I prove it?”
That is a major difference.


How will the percentage actually be calculated?

Here’s some genuinely good news for processors. PPWR does not build the obligation as a simplistic rule requiring every individual packaging unit to contain exactly the same recycled-content percentage.
Article 7 sets the calculation as an average per production unit, per year, per packaging type and format. In practice, batches or production runs can carry different percentages, as long as the applicable requirement is met within the calculation system set out in the Regulation.

That can offer real flexibility for:
●	production planning;
●	procurement;
●	blend formulation;
●	material qualification;
●	managing quality variation.
There’s an important caveat, though. The detailed calculation and verification methodology should not be assumed before the implementing framework is finalised. Article 7 requires the European Commission to adopt the acts governing the calculation and verification methodology and the format of the supporting technical documentation.
In other words: we know the target, and we know the calculation principle - but not yet all the operational detail.


Why PET and PP are not the same problem

Back to the gap between the two contact-sensitive categories: PET at 30% in 2030, other plastics at 10%. Why?
Part of the answer lies in the technical and regulatory reality of recycled plastics intended for food contact. Regulation (EU) 2022/1616 sets the framework for recycled plastic materials and articles intended to come into contact with food.

PET currently has the most mature infrastructure and industrial track record for producing recycled material for such applications. For other plastics - including many PP, PE or HDPE applications - the picture is far more complicated, and the availability of suitable, compliant recycled material for food contact is much more limited.

From a plant’s point of view, the problem becomes very concrete. It isn’t enough to ask “can I source rPP or rHDPE?” The real question is: “can I source the right material for this application, legally authorised, with the required technical properties, in the volume I need?”
For some applications, that may turn out to be one of the hardest problems in PPWR implementation.


Chemical recycling and mass balance: no premature conclusions

Another question keeps coming up: does chemically recycled material count?
The post-consumer origin of the waste is what makes it eligible under Article 7. But where recycled and virgin feedstock are processed together in the same stream, a further problem arises: how do we attribute the recycled content to the final product?
This is where mass balance, chain of custody and allocation methods enter the discussion. As of August 2026, none of this should be treated as if a definitive PPWR methodology already existed for every situation.

The practical takeaway for a company: don’t build your entire compliance strategy around one specific mass-balance method before the applicable rules are officially clarified.


The challenge won’t just be buying the material. It will be proving what I bought.

Say that, in 2030, we buy a regrind declared at 50% recycled content. Is the data sheet enough? That question probably won’t even be framed so simply any more. We’ll need to know what actually sits behind that percentage.
The chain can run: collection → recycler → compounder → processor → packaging manufacturer → brand owner / importer. The information needs to be able to travel through that whole chain.

Depending on the application and the final methodology, companies will need to be able to substantiate information such as:
●	the origin of the material;
●	its post-consumer status;
●	traceability;
●	the country of collection;
●	the country of recycling;
●	the recycling technology used;
●	the documentation supporting the recycled-content declaration;
●	food-contact authorisation status, where relevant.

The final documentation format will be filled in through the acts provided for under the Regulation. But one conclusion can already be drawn: “30% recycled” written on a data sheet should not be mistaken for demonstrating PPWR compliance.


Can I buy recycled material from Turkey?

For traders and processors, this is not a theoretical question. Turkey is already a significant material source for many European companies. But what happens if the rPET, rPP or rPE we buy is produced outside the European Union?
PPWR does, in principle, provide for recycled material from third countries to be taken into account, provided the applicable requirements and the equivalence conditions set out in the Regulation are met. The methodology for assessing, verifying and certifying that equivalence, however, still needs to be established through the implementing acts provided for under Article 7.
So the correct answer today is neither “yes, any imported PCR will count,” nor “no, only European material will be usable.”
The answer is: material from third countries can be a source, but we shouldn’t yet build a compliance strategy on the assumption that any imported material will be automatically eligible.
For traders, the origin and documentation of the material are about to matter far more than they do today.


The 2026 market paradox

There’s an interesting situation here. In 2026, several segments of the European recycled-plastics market are under pressure. Cheap virgin material is squeezing recyclate. Demand is weak in some segments. Some European recyclers are operating in difficult conditions.
Looking only at today’s market, one could conclude: “We have enough recycled material.” But PPWR introduces a structural shift. As 2030 approaches, the issue will no longer be voluntary demand for recycled material alone. For certain applications, demand will be driven by mandatory recycled-content requirements.
And there’s a further distinction. PPWR doesn’t simply create demand for recyclate. It creates demand for documented recyclate: post-consumer material, traceable, of known origin, with the right technical properties and, where relevant, suitable for food contact.

The gap between “recycled” and “eligible, documented recycled” may well become far more commercially significant in the coming years.


Who gains, and who feels the pressure?

For recyclers, PPWR creates the prospect of mandatory demand, but simultaneously raises the bar on quality, traceability and documentation.
For compounders, real opportunities open up in formulation and quality stabilisation, alongside the responsibility of maintaining origin information.
For processors, the issue lands directly on the shop floor: colour, odour, MFI/MFR, mechanical properties, processing stability, batch-to-batch variation.

For packaging manufacturers, two projects start to overlap: Design for Recycling and recycled content.
For brand owners, the issue becomes, at once, one of compliance, procurement and supply security.
And for traders, the ability to supply not just material, but material with verifiable origin and documentation, could become a real commercial advantage.


More recycled content doesn’t automatically mean a better package

In PPWR 04 we discussed Design for Recycling. An important connection emerges here.
Say we add more recycled content to a package. We may see colour variation, odour, different mechanical properties, different processing behaviour, different barrier properties. To compensate, we might be tempted to change the structure, increase gauge, or add other components.
And that’s where the paradox appears: we solve the recycled-content problem and risk creating a Design for Recycling or minimisation problem.

That’s why Article 6 and Article 7 should not be treated as two independent technical projects. Packaging design and recycled-content strategy need to be developed together.


What should I ask my recycled-material supplier tomorrow?

We don’t need to wait for every implementing act before we start asking the right questions.
●	Is the material post-consumer or post-industrial?
●	What is the actual recycled-content percentage?
●	What waste stream does it come from?
●	In which country was it collected?
●	In which country was it recycled?
●	What recycling technology was used?
●	Is there batch-level traceability?
●	What documents support the recycled-content declaration?
●	Is it authorised and suitable for food contact, if the application requires it?
●	What technical specifications are guaranteed: MFI/MFR, colour, odour, mechanical properties?
These questions aren’t yet an official PPWR list of mandatory documents. But they are questions any purchasing department can start asking today.


What can I do now?

What I can do now:
●	Inventory the packaging portfolio and identify the relevant Article 7 category for each item.
●	Check how much of the recycled material actually used is post-consumer versus post-industrial.
●	Clearly separate PCR from PIR in internal data.
●	Review current suppliers and the documentation they can actually provide.
●	Identify high-risk contact-sensitive applications.
●	Review supply contracts from a traceability and origin perspective.

What I’m preparing now, to implement later
●	Alternative suppliers.
●	Industrial trials at meaningful recycled-content percentages.
●	Material qualification.
●	Product validation.
●	Customer approvals.
●	A procurement strategy that can adapt once the methodologies are finalised.

What I’m tracking
●	The official calculation and verification methodology.
●	The rules for recycled material from third countries.
●	How the framework for mass balance and chemical recycling develops.
●	Developments on recycled materials for food contact.
●	Any adjustments or derogations under the PPWR framework.

What I wouldn’t do yet
●	I wouldn’t assume that any material sold as “recycled” is automatically eligible under Article 7.
●	I wouldn’t build an entire strategy around a single mass-balance method before the official framework is clarified.
●	I wouldn’t assume that any imported PCR will be automatically accepted.
●	I wouldn’t invest in a technology just because a supplier markets it as “PPWR compliant.”
But the reverse is also true: I wouldn’t wait until 2029 to start qualifying materials. Industrial trials, customer approvals, specification changes and supplier qualification can all take far longer than expected.


Five misconceptions worth clearing up now

“We already use 30% recycled content, so we’re compliant.”
Not necessarily. What matters is what that material actually is, where it comes from, and which packaging category applies.

“PIR is recycled material too, so it counts the same way.”
Industrially, yes. But for the Article 7 minimum, the requirement is built on material recovered from post-consumer plastic waste.

“The supplier’s certificate settles the matter.”
Don’t assume that. Traceability and the verification methodology will matter.

“If I import PCR, I can obviously use it for PPWR.”
Not automatically. Eligibility of material from third countries has to be assessed under the equivalence and verification rules.

“We still have time until 2030.”
True. But qualifying suppliers, testing materials and getting product approvals don’t start in 2030.


The real question

We started by asking: “how much recycled material will I need to use?” We can now put the question better.
The real challenge of Article 7 isn’t just “where do I buy recycled material?” It’s: where do I buy the right recycled material, in the right quantity, with the technical properties I need, and with the documentation that lets me prove what I bought and what went into the product?
That’s the shift.

2030 can still feel a long way off. But if we need to qualify new suppliers, test materials, adjust formulations, adapt processes, secure customer approvals and lock in supply sources, it isn’t far off at all.

That’s why preparation starts now - not through blind investment, but through information, testing, traceability and conversations with suppliers.

And this is where we want to keep the dialogue with the industry going.
●	Do you use PIR and aren’t sure how Article 7 affects you?
●	Are you buying recycled material from Turkey or other non-EU countries?
●	Does your supplier quote a recycled-content percentage but can’t clearly demonstrate its origin?
●	Not sure which of the four categories your packaging falls into?
Write to us. The questions that keep coming up across the industry often become the next explainer in this PPWR series.


Official Sources

●	Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (PPWR) - in particular Article 7 and the relevant annexes.
●	Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with foods.
●	European Commission - Packaging and Packaging Waste Regulation (PPWR).
●	European Food Safety Authority (EFSA) - information and assessments on recycling processes for plastics intended for food contact.


Other Sources

●	European Commission - information and technical documents on PPWR implementation.
●	EFSA - scientific guidance and opinions on recycling processes for food-contact plastics.
●	Specialised European sources from the recycling and plastics industry, used for context on the availability, quality and evolution of the recycled-materials market.