EU PPWR FAQs Updated August 2026 - Flipbook - Page 30
By way of example, in the case of a glass bottle with a metallic cap and a plastic label, the metallic
cap is not a plastic part and therefore falls outside the scope of the recycled content requirements.
A plastic label, however, is exempted if its weight accounts for less than 5% of the total weight of
the packaging unit, i.e. the bottle with cap and label.
8) Recycled plastic in plastic caps is mandatory for milk but not for infant formula
packaging. Must an economic operator that uses the same caps for these products
meet the targets for recycled plastic content to comply with the requirements for milk
packaging?
As of 2030, manufacturers must ensure that the plastic part of the packaging placed on the market
is compliant with the recycled content targets of Article 7(1).
Milk is not exempted from the recycled content requirements. Therefore, a manufacturer must
ensure that plastic caps that are used for the milk packaging fulfil the recycled content requirements.
On the other hand, plastic caps for instant baby formula are not required to include recycled content
due to the exemption set out in Article 7(4), point (g).
9) Is there a difference between 8contact-sensitive plastic packaging9 and 8immediate
packaging9 as used in the exemptions of Article 7?
The term 8immediate packaging9 refers to the 8(…) packaging immediately in contact with the
medicinal product919, whereas according to Article 3(1), point (49), of the PPWR contact-sensitive
packaging means packaging that is intended to be used for food and medicinal products.
In the context of medical devices and other medicinal products 8immediate packaging9 will
generally qualify as 8contact-sensitive plastic packaging9 according to Article 3(1), point (49), of
the PPWR, and while the concepts are not identical, they should be understood in the same way for
the purpose of implementation of Article 7 of the PPWR.
10) What is the interplay between the reporting obligations related to recycled content
under the PPWR and under the SUPD?
Article 6(5), points (a) and (b) of SUPD (i.e. recycled content targets for beverage bottles listed in
Part F of Annex to SUPD), and Article 13(1)(e) SUPD on related Member States9 reporting remain
in force until 1 January 2030 or 3 years after the entry into force of the implementing act on the
calculation of recycled content referred to in Article 7(8).
There are some differences in scope between the PPWR and the SUPD, which should be taken into
account:
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In the SUPD, the target is at Member State level, whereas the PPWR sets the. requirements
per packaging type/format, calculated as an average per manufacturing plant and year.
There is no minimum threshold in the SUPD for composite materials, whereas the PPWR
contains an exemption for the plastic part if it represents less than 5% of packaging unit
weight.
There is no exemption regarding compostable plastic packaging in the SUPD.
11) Recycled content requirements for imported plastic packaging
Regulation (EU) 2022/1616 and its provisions (especially Article 6) apply to all recycled plastics
for food contact materials placed on the EU market, including imported packaging.
19
Article 1(23) of Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the
Community code relating to medicinal products for human use (OJ L 311 28.11.2001, p. 67)
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