Recycling targets under the PPWR: what percentage of recycled material must plastic packaging contain?\

The post-consumer recycled (PCR) content of PPWR is one of the most important obligations for companies using plastic packaging. From 2030, plastic packaging placed on the EU market will have to contain a minimum proportion of post-consumer recycled (PCR) material. The thresholds will range from 10% to 35% in 2030, depending on the type of packaging, and will rise to 25–65% in 2040. The PPWR Regulation specifies specific values for PET food-contact packaging, food-contact packaging made from other plastics, single-use plastic beverage bottles and other plastic packaging.

For businesses, this means more than just a change in the material used. Companies will need to know what the packaging is made of, what proportion of post-consumer recycled (PCR) material it contains, who supplies the raw material, how the proportion of recycled content was calculated, and what documents confirm compliance.

What is PCR in plastic packaging?

PCR, or post-consumer recycled content, refers to material derived from the recycling of post-consumer waste. In the context of PPWR, this refers to raw material recovered from plastic waste that has already been used by consumers or end-users, and which has been collected, sorted and recycled.

PCR does not refer to just any production waste. It is a recycled material derived from post-consumer waste, intended to replace virgin plastics in new packaging.

This distinction is of great importance. Post-production waste, such as offcuts from a production line that are fed directly back into the process, may be technologically useful, but will not always qualify as PCR within the meaning of the PPWR requirements. For the purposes of compliance with the Regulation, only material that meets the criteria set out in the legislation and implementing methodologies will be taken into account.

The PPWR specifies that the recycled material must come from post-consumer plastic waste collected in the EU in accordance with the relevant legislation, or collected in a third country in accordance with equivalent standards for separate collection and high-quality recycling.

Why is the PPWR introducing a mandatory recycled content requirement?

The European Union wants to reduce the consumption of virgin raw materials, increase demand for high-quality recycled materials and strengthen the circular economy. The European Commission points out that the PPWR is intended to safely increase the use of recycled plastics in packaging and reduce the use of virgin materials.

Until now, the recycled materials market has often been uneven. Some companies used PCR for environmental or marketing reasons, but much packaging was still made from virgin plastic because it was more readily available, of more consistent quality or cheaper at the time.

The PPWR changes this approach. The minimum PCR content will become a regulatory requirement, rather than merely part of a voluntary ESG strategy.

Since when have the recycled content requirements in the PPWR been in force?

The PPWR came into force on 11 February 2025 and will, in principle, apply from 12 August 2026. The European Commission confirms these dates and states that the Regulation covers all packaging and packaging waste, regardless of material or origin.

The minimum levels of recycled content in plastic packaging are linked to the years 2030 and 2040. Article 7 of the PPWR stipulates that, from 1 January 2030 or three years after the entry into force of the relevant implementing act — whichever is later — plastic packaging components must contain a minimum proportion of recycled material.

In practice, companies should not wait until 2030. Changing the material, supplier, formulation, certification and documentation takes time, testing and approvals.

PPWR recycled content thresholds from 2030.

The key provisions for businesses are set out in Article 7 of the PPWR. From 2030, the minimum recycled content will depend on the type of plastic packaging.

Type of plastic packaging	Minimum PCR content from 2030.
Contact packaging made primarily from PET, with the exception of single-use plastic beverage bottles	30%
Contact packaging made from plastics other than PET, with the exception of single-use plastic beverage bottles	10%
Disposable plastic drinks bottles	30%
Other plastic packaging	35%

The PPWR states that the minimum proportion of recycled material is to be calculated as an average for each production site and year, by type and format of packaging. This is important because the requirement is not described simply as a percentage „in each individual item” in isolation from the production process.

The highest threshold in 2030 applies to other plastic packaging that does not fall within the categories of food contact packaging or single-use beverage bottles — for these, the required PCR content is 35%.

PPWR recycled content thresholds from 2040 onwards.

In 2040, the thresholds will be raised significantly. For some types of packaging, the increase will be more than double the 2030 level.

Type of plastic packaging	Minimum PCR content from 2040 onwards.
Contact packaging made primarily from PET, with the exception of single-use plastic beverage bottles	50%
Contact packaging made from plastics other than PET, with the exception of single-use plastic beverage bottles	25%
Disposable plastic drinks bottles	65%
Other plastic packaging	65%

The biggest change concerns single-use plastic drinks bottles and other plastic packaging, for which the threshold is set to rise to 65%.

A packaging strategy designed solely with 2030 in mind may prove to be short-sighted. Companies should check whether their suppliers and technologies will also be able to meet the requirements for 2040.

What does „contact packaging” mean in practice?

Contact packaging refers to packaging that comes into contact with the product in a way that is relevant to safety, hygiene or quality. In practice, this includes, amongst other things, packaging for food, drinks, cosmetics, pharmaceutical products, medical devices and pet food.

Under the PPWR, contact packaging has lower thresholds for materials other than PET, as the use of recycled material in such packaging may require additional safety assessments, material compliance assessments and authorisations for contact with the product.

Examples:

– PET bottle for juice or water: a type of single-use plastic drinks bottle,
– PET food tray: PET food-contact packaging,
– PP packaging for cosmetics: contact packaging made from a material other than PET,
– transport or bulk wrap: usually other plastic packaging,
– technical packaging made of HDPE that does not come into contact with food: usually other plastic packaging.

The boundaries between categories may require careful analysis. It is not enough simply to know that the packaging is „plastic”. Its function, predominant material, use and relationship with the product must be determined.

Do the requirements apply to the entire packaging or just the plastic part?

The PPWR refers to the plastic part of packaging placed on the market. This is particularly important in the case of multi-material packaging, where plastic is one of the components – for example, a layer, a window, a cap, a label, a laminate or a security feature.

In the case of such arrangements, the company should determine:

– what proportion of the packaging’s mass is made up of plastic,
– whether the plastic component exceeds the materiality thresholds,
– whether the item is part of the contact packaging,
– does the packaging consist of several components made from different plastics,
– Can the supplier specify the PCR content for each relevant plastic component?.

The PPWR stipulates that the requirements regarding the minimum proportion of recycled material do not apply to the plastic component constituting less than 5% of the total mass of the entire packaging unit.

If a company uses multi-material packaging, it should assess not only recyclability, but also the proportion of plastics and the ability to document the PCR in individual components.

What types of packaging may be exempt from the PCR requirements?

The PPWR provides for exemptions for selected categories of packaging. These include, amongst others, specific medical, diagnostic and veterinary packaging, packaging for the transport of dangerous goods, compostable packaging, and selected food contact packaging for infant and young child food and food for special medical purposes.

Furthermore, the requirements do not apply to plastic packaging intended to come into contact with food if the proportion of recycled material would pose a risk to human health and result in non-compliance with the regulations on materials intended to come into contact with food.

However, this does not mean that every company can simply invoke the exemption. Exemptions must be analysed carefully, taking into account the function of the packaging, the type of product, the technical documentation and sector-specific regulations.

An exemption from the PCR requirement should not be treated as a default exemption. This is an area requiring a documented legal and technical assessment.

How should the PPWR recycled content be documented?

The PCR requirements will necessitate documentation. The PPWR stipulates that compliance with the minimum recycled content requirements must be demonstrated by manufacturers or importers in the technical documentation relating to the packaging. The Regulation also provides for implementing acts concerning the methodology for calculating and verifying the recycled content, as well as the format of the technical documentation.

For the company, this means it will need to set up a packaging data system. In practice, it is worth preparing a packaging data sheet now, covering:

– the name and code of the package,
– packaging type: individual, bulk, transport, e-commerce,
– main material,
– all plastic parts,
– the mass of each component,
– plastic type: PET, PP, PE, HDPE, LDPE, PS, others,
– contact or non-contact mode,
– PCR concentration,
– PCR source,
– the supplier of the material,
– a document confirming the recycled content,
– compliance with food contact requirements, where applicable,
– risks relating to recyclability.

Such a card is not merely a compliance document. It is a tool for procurement, design and negotiations with suppliers.

Recycled material in PPWR and packaging suppliers

The greatest risk for businesses is not that they are unaware of the percentage thresholds. The risk is that their suppliers will be unable to verify PCR in the manner required by regulations, an audit, a customer or the market.

The company should ask the supplier:

– does the pack contain a PCR test,
– what is the proportion of PCR in each plastic component,
– whether the PCR comes from post-consumer waste,
– is there any documentation available confirming the origin of the raw material,
– whether the material meets the quality requirements,
– whether the packaging comes into contact with food or a sensitive product,
– does the supplier plan to increase the share of PCR by 2030 and 2040,
– Will a change in the PCR content affect strength, colour, migration, odour or weldability?.

It is worth avoiding general claims such as „eco-friendly packaging” or „made from recycled materials” if they are not backed up by specific values, standards, reports or declarations.

PCR and packaging quality: what do you need to bear in mind?

The use of recycled material must not compromise product safety. Recycled material may affect the mechanical properties, colour, transparency, odour, migration of substances, consistency of specifications and the behaviour of the packaging during transport.

The most common areas of inspection are:

– crush strength,
– puncture resistance,
– dimensional stability,
– airtightness,
– compatibility with labels and printing,
– temperature resistance,
– the ability to heat-seal,
– suitability for contact with food,
– impact on the recyclability of the entire packaging.

Companies should test not only one packaging variant, but also the stability of PCR supply. Recycled material may be subject to greater variations in quality than virgin material, so monitoring suppliers and specifications will be crucial.

Recycled content versus recyclability – they are not the same thing

In PPWR, a distinction must be made between two concepts: recycled content and recyclability.

The recycled content indicates how much recycled material is in the packaging. Recyclability indicates whether the packaging can be effectively collected, sorted and processed after use.

Packaging may contain PCR, but may still be difficult to recycle if it contains problematic dyes, laminates, a multi-layered structure or elements that interfere with sorting. It may also be recyclable, but fail to meet the required PCR content.

The PPWR sets out both objectives in parallel. The European Commission states that one of the aims of the regulation is to ensure that all packaging on the EU market is recyclable in an economically viable manner by 2030, and to safely increase the use of recycled plastics in packaging.

That is why simply switching to „partly recycled” material is not enough. A comprehensive assessment of the packaging is needed.

How can a company prepare for the requirements of Plastics 2030?

The Plastics 2030 requirements call for a plan. Companies should start with the data, rather than simply switching suppliers at random.

1. Carry out an inventory of plastic packaging

The first step is to draw up a list of all plastic packaging and plastic components. This should include unit packaging, bulk packaging, transport packaging, dispatch packaging, films, labels, caps, trays, sachets, bags and protective elements.

2. Sort the packaging into PPWR categories

Each package must be assigned to the correct category:

– PET contact packaging,
– contact packaging other than PET,
– a single-use plastic drinks bottle,
– other plastic packaging.

This allocation determines whether the threshold will be 10%, 30% or 35% in 2030.

3. Check the current PCR result

The company should determine which packaging already contains recycled material and which is made entirely from virgin plastic. The lack of data from the supplier should be treated as a risk.

4. Assess the gaps in relation to 2030 and 2040.

It is worth assigning the current PCR content and the target threshold to each packaging item. This will enable the company to see which packaging items require immediate action and which are closer to compliance.

5. Check the impact of PCR on product quality

A change in the proportion of recycled material may require testing for migration, durability, leak-tightness, transport, aesthetics and compliance with customer requirements.

6. Update your procurement requirements

Procurement specifications should include requirements regarding PCR, the type of raw material, documentation, origin, quality and compliance with the PPWR.

7. Combine PCR with the PPWR and GOZ audit

The best way to prepare for PPWR is to combine regulatory obligations with the circular economy. In practice, this involves analysing materials, recyclability, documentation, suppliers and future environmental costs. A good starting point is PPWR audit and the implementation of a broader approach to circular economy.

Example: how should PCR cut-off values be interpreted in practice?

The company uses three types of packaging:

1. A PET bottle for a drink.
2. A PET food tray.
3. Plastic transport film.

For PET beverage bottles, the threshold will be 30% PCR from 2030 and 65% from 2040. For PET food trays, provided they are not single-use plastic beverage bottles, the threshold will be 30% from 2030 and 50% from 2040. For transport film, classified as other plastic packaging, the threshold will be 35% from 2030 and 65% from 2040.

This example shows that the term „PET” alone is not sufficient. The function of the packaging and its category within the PPWR must be specified.

Which departments within the company should be involved in the preparations?

Recycled content requirements are not solely the responsibility of the environmental department. At least the following departments within the company should be involved:

– procurement, as they select suppliers and materials,
– R&D or the technology department, as it is responsible for the packaging design,
– quality, as it verifies safety and performance,
– marketing, because it uses environmental claims,
– logistics, as it assesses durability during transport,
– compliance, as it is responsible for ensuring compliance,
– finance, as changes may affect the cost of materials and fees,
– the management board, because PPWR influences product strategy and the market.

If a company does not have an in-house environmental team, it is worth considering comprehensive environmental consulting for companies, which enables the integration of PPWR and BDO requirements, documentation and the circular economy implementation plan.

Recycled content, BDO, EPR and sales in the EU

The PPWR does not replace national obligations relating to packaging. The company must still analyse the BDO in Poland, extended producer responsibility schemes in EU Member States, and obligations to report packaging weights.

If a company sells products in several markets, it should check whether changes to the packaging affect:

– figures reported in BDO,
– product fees,
– material classification,
– the responsibilities of the EPR/ROP in other countries,
– registrations in systems such as LUCID in Germany,
– data provided to B2B customers and marketplaces.

Companies operating internationally can benefit from compliance with packaging obligations in EU markets, and for sales to Germany, also from LUCID audit.

The most common mistakes when preparing for PCR requirements

The first mistake is to equate recycled material with any kind of production waste. PPWR focuses on recycled material from post-consumer waste, so the presence of regranulate alone is not always sufficient.

The second mistake is the failure to distinguish between different categories of packaging. Different thresholds apply to PET contact packaging, PP contact packaging and transport film.

The third mistake is relying on a supplier’s declaration without supporting documentation. A brief statement such as „contains recycled material” is not sufficient to ensure compliance.

The fourth mistake is designing packaging with only 2030 in mind. The targets for 2040 are significantly higher, so the company should be assessing right now whether its technology and suppliers have a clear path to achieving those targets.

The fifth mistake is failing to take product safety into account. In contact packaging – particularly for food, cosmetics and medical products – recycled material must be assessed in conjunction with sector-specific regulations.

FAQ – frequently asked questions about the PPWR recycled content

What percentage of recycled material must plastic packaging contain from 2030?

From 2030, the minimum PCR content will be 30% for PET food-contact packaging, 10% for food-contact packaging made from materials other than PET, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging.

What are the PPWR recycled content targets that will apply from 2040?

From 2040, the thresholds will rise to 50% for PET food-contact packaging, 25% for food-contact packaging made from plastics other than PET, 65% for single-use plastic beverage bottles and 65% for other plastic packaging.

Is PCR the same as production waste?

No. PCR stands for post-consumer recycled material. Post-production waste may be returned to the process, but it does not have to meet the definition of PCR required under the PPWR.

Do the PCR requirements apply to food packaging?

Yes, but with some important caveats. Packaging intended to come into contact with food is subject to separate thresholds, and the PPWR provides for an exception where the amount of recycled material in such packaging would pose a risk to human health and result in non-compliance with the regulations on materials intended to come into contact with food.

Does a small plastic component also have to contain recycled material?

Not always. The PPWR states that the minimum recycled content requirements do not apply to a plastic component accounting for less than 5% of the total mass of the entire packaging unit.

How should a company begin preparing for the PCR requirements?

It is best to start by carrying out an inventory of plastic packaging, classifying it into PPWR categories, collecting data from suppliers and checking the current PCR content. It is then advisable to carry out a PPWR audit and integrate it with the circular economy strategy.

Find out how to implement the Circular Economy in your business

The requirements regarding the PPWR recycled content show that plastic packaging is becoming part of a materials strategy, rather than merely a purchase cost. Companies that take action early will have more time for testing, negotiating with suppliers, updating documentation and preparing packaging to meet the 2030 and 2040 targets.

If you would like to find out how to implement the Circular Economy in your business and ensure that your plastic packaging complies with the PPWR requirements, please use the GOZ package or PPWR audit. You can also go directly to the tab Contact Eko-Pro and describe your packaging, materials and target markets.