European Commission prepares key rules for recycled content in plastic packaging

The European Commission is entering an important stage in the implementation of the Packaging and Packaging Waste Regulation (PPWR): establishing the practical rules through which companies will calculate, demonstrate and verify the use of recycled material in plastic packaging.

Against this background, the Bulgarian Industrial Association (BIA) is urging companies to participate in the consultation process and provide data based on real industrial conditions before the future rules are finalised.
The consultation is open until 16 September 2026.
The implications extend well beyond Bulgarian industry. The acts being prepared at European level will affect packaging manufacturers, plastics converters, recyclers, importers and users of recycled materials throughout the European Union.

How recycled content will be calculated and verified

The first area concerns the methodology for calculating and verifying the percentage of recycled material used in plastic packaging.
The rules will need to clarify how companies demonstrate the amount of recyclate used and what information will be required to verify compliance.
For industry, this is not simply a mathematical question.
The methodology could determine what information must be transferred along the supply chain, what documentation companies need to retain and what verification mechanisms will be required.

The design of the system could therefore directly affect administrative and compliance costs for recyclers, compounders, converters and packaging manufacturers.

What happens to recyclates originating outside the EU

A second important area concerns recycled materials originating in third countries.
The Commission must establish how companies can demonstrate that imported materials originate from recycling operations carried out under conditions equivalent to those applicable within the European Union.
In practice, this could involve requirements concerning traceability, certification and independent verification of international supply chains.

The issue has significant commercial implications.
Imported recycled materials already compete with European production. The conditions under which these materials will be eligible to count towards PPWR recycled-content targets could therefore influence both the competitiveness of EU recyclers and the sourcing strategies of European converters.

Which recycling technologies will meet the criteria

The third area concerns sustainability criteria applicable to recycling technologies.
The preparatory process considers factors such as process efficiency, energy consumption, emissions and the quality of the resulting recycled material.
How these criteria are defined could have direct implications for investment in recycling capacity.
Requirements that are too restrictive could limit the use of existing technologies, while insufficiently clear criteria could create uncertainty for companies making investment decisions today for equipment expected to operate for many years.

Bulgarian industry calls for real-world data

BIA is asking companies to contribute concrete information on costs, availability of recycled raw materials, technological capabilities and the administrative burden associated with the future requirements.
The organisation argues that the rules need to be not only effective in achieving environmental objectives but also workable under real industrial conditions, including for small and medium-sized enterprises.
BIA also highlights the relationship between recyclate costs and packaging competitiveness.
When collection, sorting and recycling costs result in recycled material being more expensive than virgin polymers, achieving circularity targets becomes an economic challenge as well as a technical one.

From PPWR to rules applied on the factory floor

PPWR establishes the overall direction and recycled-content targets. Secondary legislation, however, will determine much of how those obligations work in industrial practice.

For companies, the questions are becoming increasingly concrete:
• How will recycled content be calculated?
• How will the origin of recycled material be demonstrated?
• What documentation will need to be retained?
• How will the information be verified?
• Under what conditions can recyclates originating outside the EU be used?
• Which recycling technologies will meet European criteria?

The answers will influence not only PPWR compliance but also investment decisions, supplier-customer relationships and the future structure of Europe's recycled materials market. For the packaging and recycling industries, the current period is therefore particularly important: some of the rules that will determine how PPWR operates in practice are still being defined.

Sources:

Bulgarian Industrial Association (BIA), 20 August 2026 – information and industry position regarding the PPWR consultation