PPWR recycled content: what your packaging must contain

1. The targets, category by category

Article 7 splits plastic packaging into categories because the food-contact rules make high recycled shares much harder for some formats than others. Non-contact-sensitive packaging carries the highest obligation precisely because it is the easiest to satisfy with mechanically recycled polyolefins — and that is exactly the space PolyAl serves.

Treat these percentages as the working planning basis: the instrument is adopted, but the Commission still has to publish the delegated act under Article 7(8) that fixes the calculation and verification methodology, and the application date of the targets is linked to it.

• Contact-sensitive PET packaging: 30% by 2030 → 50% by 2040
• Other contact-sensitive plastic packaging: 10% by 2030 → 25% by 2040
• Single-use plastic beverage bottles: 30% by 2030 (aligned with the SUP Directive)
• Plastic packaging that is not contact-sensitive: 35% by 2030 → 65% by 2040
• Some categories (e.g. compostable packaging and certain medical or dangerous-goods uses) are exempted or postponed

2. Why 35% and 65% is the number that changes your business

Most industrial and transport packaging — crates, trays, drums, dunnage, buckets, pallets, bins — is not contact-sensitive. That puts it in the 35% bracket for 2030 and 65% for 2040. A 65% post-consumer share cannot be improvised in 2039: it needs a qualified supply relationship built years earlier, because the volume of certified post-consumer polyolefin available in Europe is finite.

This is why buyers are moving now. Securing a contracted share of certified post-consumer polyolefin today is cheaper and lower risk than bidding for the same tonnes in a market where every converter is legally obliged to buy them.

• 65% by 2040 means recycled becomes the base resin, not the additive
• Certified post-consumer supply is the constraint, not process capability
• Early framework contracts lock volume and price before the compliance rush

3. How PolyAl gets you there

PolyAl is the polyethylene-and-aluminium fraction recovered from used beverage cartons: roughly 66% LDPE, 18% HDPE, 6% PP and about 10% aluminium. Every gram of it is post-consumer, because it starts life as packaging a consumer used and discarded. It is washed, dried and pelletised following UNE 53925:2026 and shipped in homogeneous 60-tonne batches with Big Bags up to 1000 kg.

Because it is a blended into a percentage of your virgin PE/PP on injection and extrusion lines, the recycled share you declare goes up while your raw-material cost per tonne goes down. Compliance and cost normally pull in opposite directions; here they do not.

• 100% post-consumer origin — counts fully towards Article 7
• Mechanically recycled and traceable, no mass-balance allocation needed
• Produced following UNE 53925:2026; cleaning-chemical resistance tested to UNE 56875:2021
• EUR.1 preferential EU origin — reduced or zero duty for EU buyers
• ≈1.6 t CO₂e avoided per tonne replacing virgin polyolefin

4. What you must be able to show

Meeting the percentage is only half the obligation. PPWR requires conformity assessment, an EU Declaration of Conformity (Annex VIII) and technical documentation (Annex VII) that substantiates the declared recycled share. In practice, that documentation is only as good as the certificates your resin supplier gives you.

• EU Declaration of Conformity per packaging type
• Technical file: composition, recycled-content calculation basis, supplier certificates
• Batch-level traceability from waste origin to pellet
• Third-party certification (EN 15343-based schemes such as EuCertPlast or RecyClass)

5. Penalties and enforcement

PPWR does not set EU-wide fines. Article 68 leaves penalties to each Member State, so the exposure depends on national transposing law — Germany, for example, replaces the VerpackG with the new VerpackDG from 12 August 2026. The practical risk is rarely the fine alone: it is a market-surveillance authority questioning a declaration, a customer audit failing, or packaging being withdrawn from a market.

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.