EU PPWR FAQs Updated August 2026 - Flipbook - Page 28
V.
RECYCLED CONTENT IN PLASTIC PACKAGING
1) How should compliance with the recycled content requirements be demonstrated?
Compliance with the recycled content targets in the PPWR must be demonstrated in the technical
documentation for the packaging, as specified in Annex VII. Compliance with the recycled content
requirements can be exemplified as follows.
An economic operator places a plastic tray made of polyethylene (PET) with a peelable lid made
of polypropylene (PP) on the market. In this case, we could assume that the PET tray and PP lid
are manufactured in different manufacturing plants within the EU and supplied to the economic
operator who assembles the packaging components into a tray with a lid, fills it with product, and
eventually places it on the market.
The two manufacturing plants which manufacture, respectively, the tray and the lid must each
disclose information about the compliance with the minimum recycled content requirements for
their components, as provided for in Article 7(2). Based on the information from these
manufacturing plants, the economic operator who eventually places the tray with the lid on the
market (i.e. the manufacturer), must draw up the technical documentation that demonstrates
compliance with the legal requirements for recycled content.
The same principle applies to intermediate plastic packaging components, empty plastic packaging
or filled plastic packaging imported into the EU. The economic operator must also ensure that the
requirements for the recycled content meet the sustainability and equivalence criteria, which will
be set out in the implementing acts pursuant to Article 7(9) and (10), respectively.
2) What is to be understood by 8average per manufacturing plant and year9 in the context
of recycled content in plastic packaging?
A manufacturing plant must be understood as the industrial facility in which packaging is
manufactured. An average per year refers to the amount of recyclates (recycled content) in each
plastic packaging type and format over the period of a calendar year, produced for each
manufacturer in a specific manufacturing plant. The manufacturing plant will have to provide
documentation demonstrating that the average supply per year to the specific manufacturer fulfils
the targets for recycled content.
Manufacturers usually produce several packaging formats in one manufacturing plant and will
therefore have to calculate the recycled content targets for each packaging type and format.
The implementing act to be adopted under Article 7(8) will outline the rules on how to calculate
and verify the recycled content in plastic packaging.
3) Are adhesives, paints and inks covered by the recycled content requirements for
plastic packaging?
Adhesives, paints and inks are not deemed plastic under the PPWR and therefore do not need to
fulfil the recycled content requirements. This is regardless of whether they represent less than 5%
of the packaging unit.
4) Are environmental claims on recycled content in plastic packaging allowed?
Environmental claims on recycled content in plastic packaging are allowed where the recycled
content exceeds the applicable minimum requirements set out in Article 7(1) and (2) of the PPWR.
Article 14 specifies that the economic operator is allowed to make environmental claims for a
packaging unit, the part of the packaging unit that contains the recycled content, or all packaging
placed on the market over a calendar year by the economic operator. This is exemplified in the table
below.
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