1. Why the law draws this line
Recycled-content mandates exist to pull material out of the waste stream that would otherwise be landfilled or incinerated, and to create demand for collection and sorting infrastructure. Reusing your own sprues does neither: that material never entered the waste stream, and reusing it is simply good manufacturing practice.
So a converter can honestly say '30% recycled' internally and still declare 0% under PPWR. The gap between the two numbers is where compliance projects get expensive.
- Statutory targets exist to create demand for collected waste
- In-house scrap reuse is efficiency, not recycled content
- Check every supplier claim for the word 'post-consumer'
2. The trap in supplier claims
'Recycled', 'regranulate', 'reprocessed' and 'circular' are not legal terms. A regranulate can be entirely post-industrial and still be sold as recycled. Under Directive (EU) 2024/825, which applies from 27 September 2026, an unsubstantiated or misleading recycled claim is also a consumer-protection problem, not just a compliance one.
The only safe purchasing specification is explicit: post-consumer origin, stated share, third-party certified, traceable to batch.
- Require the words 'post-consumer' in writing on the certificate
- Ask which waste stream and which collection system it came from
- Ask for the certification scheme and certificate number
- Ask whether the figure is physical or mass-balance allocated
3. Why carton PolyAl is unambiguous
A beverage carton is drunk by a consumer, put in a household collection stream, taken to a paper mill and pulped. The fibre becomes new paper. What remains is the polyethylene-and-aluminium fraction: PolyAl. There is no version of that story where the material is pre-consumer — its entire origin is post-consumer packaging, and the route is documented at each step.
That makes PolyAl one of the cleanest post-consumer declarations available in polyolefins, with the added advantage that it is a stream most competitors for post-consumer PE are not bidding on.
- Origin: used beverage cartons collected from households
- ≈66% LDPE, 18% HDPE, 6% PP, ≈10% aluminium
- Homogeneous 60 t batches, Big Bag up to 1000 kg
- Produced following UNE 53925:2026, EUR.1 preferential EU origin
- Supply from a stream that is under-contested compared with PCR HDPE
4. What to do if your recycled content is the wrong kind
The remedy is simple in principle: substitute part of your virgin resin with ISCC PLUS certified post-consumer material, keeping your in-house scrap loop exactly as it is. The scrap keeps saving you money; the post-consumer share creates the declarable percentage.
This page is general information about EU legislation, not legal advice. Check the consolidated text of each instrument and your national transposition before you rely on a figure.
- Keep the internal scrap loop — it is still a cost saving
- Add post-consumer pellets to create declarable content
- Start on a reference part at the share you choose, then scale
- Free sample to validate before committing volume
Side by side
| Post-consumer | Used by an end user, collected as waste — counts in full |
|---|---|
| Post-industrial / pre-consumer | Factory scrap, runners, purgings — does not count |
| PPWR (EU) 2025/40 | Post-consumer only |
| SUP Directive 2019/904 | Post-consumer only |
| PolyAl | 100% post-consumer (beverage cartons) |
| Evidence supplied | Batch certificate, UNE 53925:2026, technical datasheet |