EU seeks industry input on recycled content requirements

The European Commission has launched a call for evidence to help develop new rules governing recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR). The initiative focuses on how recycled content should be calculated and verified, the environmental criteria applicable to plastic recycling technologies and the conditions for importing recycled plastics from outside the European Union.

The consultation comes as the packaging industry prepares for the PPWR's increasingly demanding recycled content requirements. By gathering technical, economic and supply chain information from stakeholders, the Commission aims to establish rules that can be applied consistently across the European market.

Three areas will shape the new rules

The call for evidence is divided into three main areas. The first concerns methods for calculating and verifying the amount of recycled plastic contained in packaging. Establishing a harmonised methodology is considered essential to ensure that recycled content claims are comparable and supported by reliable evidence.

The second focuses on sustainability criteria for plastic recycling technologies, while the third examines the import of recycled plastic and packaging containing recycled content from non-EU countries. Together, these measures are intended to create a consistent framework covering both domestic and international sources of recyclate.

Traceability becomes increasingly important

The Commission is seeking information on the volume of recycled plastic imported into the EU, the polymer types involved and the countries supplying these materials. It is also asking stakeholders about existing certification, verification and chain-of-custody systems used to establish the origin and recycled content of recovered post-consumer plastics.

Reliable traceability will become increasingly important as recycled content targets increase. Packaging manufacturers and brand owners will need to demonstrate that the recycled material used in their products meets the requirements established under European legislation.

Industry faces data and supply chain challenges

The Commission has identified several potential obstacles, including differences in calculation methods, verification requirements and available data. Without harmonised rules, businesses and authorities could rely on different approaches, increasing administrative burdens and creating uncertainty across the Single Market.

The availability and quality of recycled plastics also remain important concerns. Meeting future quotas will require sufficient volumes of suitable recyclate, stronger cooperation between suppliers and packaging manufacturers and efficient systems for collecting, sorting and processing post-consumer plastics.

Imported recyclate under scrutiny

International supply chains are another important part of the initiative. As European demand for recycled plastics increases, imports may become an important source of material for packaging producers. The Commission is therefore examining how imported recyclate can be verified and whether it has been produced under credible environmental and health-protection conditions.

These requirements could have significant implications for international suppliers seeking access to the European packaging market, particularly where documentation, certification and traceability systems differ from those used within the EU.

New rules expected to shape the recycled plastics market

The evidence collected through the consultation will contribute to the preparation of future implementing and delegated acts under the PPWR. The Commission intends these measures to improve legal certainty, support consistent enforcement and increase confidence in recycled content claims.

Stakeholders can submit scientific research, market data, technical analysis and other relevant evidence through the EU's Have Your Say portal until 16 September 2026. The process represents an important step towards defining how Europe's recycled content targets will operate in practice and could significantly influence investment, sourcing and compliance strategies across the packaging industry.