PPWR Article 7: minimum recycled content in plastic packaging

In short: PPWR Article 7 sets a minimum share of post-consumer recycled plastic for the plastic part of most EU packaging. From 1 January 2030 at the earliest, the share is 10%, 30% or 35%, depending on the packaging. From 1 January 2040 the shares rise to 25%, 50% or 65%. The share is averaged per manufacturing plant and year, for each packaging type and format. Medicinal, medical-device, infant-food and compostable packaging are among the exemptions.

If you only need the numbers, the table below is enough. If you have to defend them to an auditor, read on: the averaging rule, the definition of "post-consumer" and the pending implementing acts decide whether your figure counts.

PPWR Article 7 targets for 2030 and 2040

Article 7(1) and 7(2) of PPWR (EU) 2025/40 set four categories. Each applies to "any plastic part of packaging placed on the market".

Packaging categoryFrom 2030From 2040Source
Contact-sensitive packaging with PET as the major component (except single-use plastic beverage bottles)30%50%Art. 7(1)(a), 7(2)(a)
Contact-sensitive packaging made from plastics other than PET (except single-use plastic beverage bottles)10%25%Art. 7(1)(b), 7(2)(b)
Single-use plastic beverage bottles30%65%Art. 7(1)(c), 7(2)(c)
All other plastic packaging35%65%Art. 7(1)(d), 7(2)(d)

Contact-sensitive packaging is packaging for products such as food, feed, cosmetics, medicines and medical devices (Article 3(1)(49) lists the regulations it covers). A PET tray for cheese is contact-sensitive. A stretch film around a pallet of boxed goods is not.

When the 2030 targets start

The 2030 date is not fixed. Article 7(1) applies "by 1 January 2030 or 3 years from the date of entry into force of the implementing act referred to in paragraph 8, whichever is the latest". That implementing act sets the calculation and verification method. The Commission must adopt it by 31 December 2026. If it arrives on time, 1 January 2030 holds. If it arrives late, the targets start 3 years after its entry into force.

The 2040 targets in Article 7(2) have a fixed date: 1 January 2040.

How the Article 7 average is calculated

This is the rule to get right. Article 7 does not set one target per company, and it does not apply bottle by bottle. The minimum share is:

  • per packaging type and format, as listed in Table 1 of Annex II, and
  • calculated as an average per manufacturing plant and year.

In practice, this means:

  1. You cannot average across your whole EU portfolio. A high recycled share in one plant does not offset a low share in another.
  2. You cannot average across formats. A PET bottle line and a PET tray line are separate calculations if Annex II places them in different types or formats.
  3. Within one plant, one format and one year, individual units can vary. What counts is the average.

The detailed calculation method comes from the implementing act under Article 7(8). Under Article 7(11), its rules apply from 1 January 2029, or 24 months after the act enters into force, whichever is later. Until then, plan with the averaging rule in the regulation and expect the method to add detail.

What counts as recycled content

Article 7(3) sets two conditions. The recycled plastic must come from post-consumer plastic waste that:

  • was collected in the EU under EU waste rules, or in a third country under separate-collection standards equivalent to the EU's; and
  • was recycled, where applicable, in an EU installation covered by the Industrial Emissions Directive (2010/75/EU), or in a third-country installation under equivalent emission rules.

Post-consumer plastic waste is waste "generated from plastic products that have been placed on the market" (Article 3(1)(48)). Scrap and regrind from your own production never reached the market, so they do not meet this definition.

Two further layers are still being written:

  • Recycling technologies. By 31 December 2026, the Commission must adopt delegated acts with sustainability criteria for plastic recycling technologies (Article 7(9)). Recycled content will count only if it comes from installations whose technology meets those criteria or, outside the EU, equivalent standards.
  • Third-country equivalence. By the same date, implementing acts must set how equivalence is assessed, verified and certified, including through third-party audit (Article 7(10)).

Mechanical and chemical recycling

Article 7 does not name mechanical or chemical recycling. It asks the Commission to assess "the available recycling technologies", including output quality, waste availability, energy use and greenhouse-gas emissions, when it adopts the methodology (Article 7(8)). The delegated acts under Article 7(9) then set which technologies meet the sustainability criteria.

For food-contact packaging, a separate rule already applies. Recycled plastic in food-contact materials must meet Commission Regulation (EU) 2022/1616, which includes requirements on recycling technologies (PPWR recital 50). Where suitable technologies are not available, Article 8(2)(c) allows the Commission to propose letting biobased plastic feedstock count towards the Article 7 targets instead. That is a possible future proposal, not a current rule.

What this means for planning: a recycled-content claim based on chemical recycling may count, but the conditions are set in acts due by 31 December 2026. Check those acts before you rely on chemically recycled supply in your 2030 plan.

Chain of custody and certification

PPWR does not yet recognise any certification scheme for recycled content. The verification method in the Article 7(8) implementing act "may include the obligation to carry independent third-party audits" on manufacturers of recycled content and of plastic packaging. Whether mass-balance allocation is accepted, and under which conditions, will also be settled there.

Schemes such as ISCC PLUS, EuCertPlast and REDcert² are used in the market today. They are useful evidence of how your supplier tracks recycled material. As of 4 October 2026, they are not a legal presumption of conformity under PPWR.

A defensible approach now: ask suppliers for the post-consumer share, the certification scheme and certificate number, and the collection and recycling location for each supply batch. If the implementing act relies on certification schemes, that evidence carries over. If it does not, you still hold the data the act is likely to ask for.

Exemptions

Article 7(4) and 7(5) list packaging to which the 2030 and 2040 targets do not apply.

Exempt packagingSource
Immediate packaging of medicinal products and veterinary medicinal productsArt. 7(4)(a)
Contact-sensitive plastic packaging of medical devices, research-use devices and investigational devicesArt. 7(4)(b)
Contact-sensitive plastic packaging of in vitro diagnostic medical devicesArt. 7(4)(c)
Outer packaging of medicinal products, where needed to preserve product qualityArt. 7(4)(d)
Compostable plastic packagingArt. 7(4)(e)
Packaging for the transport of dangerous goodsArt. 7(4)(f)
Contact-sensitive plastic packaging for infant and young-children food and food for special medical purposesArt. 7(4)(g)
Packaging of supplies and components for manufacturing medicinal products, where needed for quality standardsArt. 7(4)(h)
Food-contact plastic packaging where the recycled share would threaten human health and breach Regulation (EC) 1935/2004Art. 7(5)(a)
Any plastic part under 5% of the total weight of the packaging unitArt. 7(5)(b)

The 5% rule matters for mixed-material packaging. A plastic window on a paperboard sleeve may fall under it. A plastic tray inside a cardboard box usually does not. Weigh the components before you assume the exemption.

Both Article 7(5) exemptions apply directly: no authority needs to grant them. According to the Commission guidance (C(2026) 3702, section 7), you must still back them with evidence in the technical documentation. For the food-contact exemption in 7(5)(a), the file names the polymer of each plastic part of 5% or more of the unit's weight. It then confirms two points: Annex I to Regulation (EU) 2022/1616 lists no suitable recycling technology for that polymer, and no technology is available at industrial scale. The guidance reads "plastic parts" in line with the definition of composite packaging (Article 3(1)(24)).

The list can change. By 1 January 2028, the Commission must assess derogations from the 10% and 35% targets (points (b) and (d)) and a revision of the exemption list (Article 7(12)).

How to document compliance

Article 7(6) puts the burden on manufacturers or importers: compliance is shown "in the technical information concerning the packaging referred to in Annex VII". Annex VII is the conformity assessment procedure (internal production control), and its technical documentation feeds the EU declaration of conformity (Article 39).

For each packaging type and format, per plant and year, the file should let an auditor trace:

  • the plastic parts in scope, with weights (and any part claimed under the 5% exemption);
  • the category and target that applies;
  • supplier declarations: post-consumer share, certificate, collection and recycling location;
  • the annual average calculation per plant;
  • once the implementing act is adopted, the format it prescribes for the technical documentation (Article 7(8)).

Labels. Recycled-content labels are voluntary. If you use one, it must follow the EU label specifications and the Article 7(8) methodology. This applies to packaging placed on the market from 12 August 2028, or 24 months after the relevant implementing act, whichever is later (Article 12(4)).

EPR fees. The EPR contributions producers pay under Article 45 may be modulated by the recycled share used in packaging (Article 7(7)). Where fees are modulated, a documented share can lower EPR costs as well as prove compliance.

Timeline

DateWhat happensSource
31 Dec 2026Implementing acts: calculation and verification method; third-country equivalence. Delegated acts: sustainability criteria for recycling technologiesArt. 7(8), 7(10), 7(9)
1 Jan 2028Commission assesses derogations from the 10% and 35% targets and the exemption listArt. 7(12)
12 Feb 2028Commission reviews biobased plastic packaging; may propose letting biobased feedstock countArt. 8
12 Aug 2028*Recycled-content labels must follow EU specificationsArt. 12(4)
1 Jan 2029*Calculation and verification follow the implementing actArt. 7(11)
1 Jan 2030*2030 targets applyArt. 7(1)
12 Feb 2032Commission report on the 2030 targets and the feasibility of 2040; possible proposal to amend 2040 targetsArt. 7(14)
1 Jan 20402040 targets applyArt. 7(2)

* or later, if the related implementing act enters into force late.

The targets can also be lowered in exceptional cases. If specific recycled plastics are unavailable or excessively priced, the Commission may adjust the percentages by delegated act (Article 7(13)). It may do so only in exceptional cases with severe adverse effects for human or animal health, the security of food supply or the environment.

Five common PPWR Article 7 mistakes

  1. Averaging across the company. The average is per manufacturing plant and year, per packaging type and format. A group-wide figure does not demonstrate compliance.
  2. Counting production scrap. Regrind and off-cuts never reached the market, so they are not post-consumer plastic waste.
  3. Treating a scheme certificate as legal proof. No scheme is recognised under PPWR yet. Keep the certificate, and also keep the data behind it.
  4. Confusing recyclability with recycled content. A grade A package under Article 6 can contain 0% recycled plastic. Article 7 is a separate obligation.
  5. Planning only for 2030. The 2040 targets are 1.7 to 2.5 times the 2030 levels. A supply contract signed for 2030 volumes needs a path to 2040, with the 2032 review as a checkpoint.

Frequently asked questions

Does Article 7 apply to paper, glass or metal packaging?

Article 7 covers only plastic. The plastic part of mixed-material packaging is in scope unless it is under 5% of the unit's weight (Article 7(5)(b)). For other materials, the Commission will review the case for recycled-content targets by 12 February 2032 (Article 7(15)).

Does the target apply to each package?

No. It is an average per manufacturing plant and year, for each packaging type and format in Annex II, Table 1.

Who is responsible: the brand, the converter or the importer?

Article 7(6) assigns the demonstration to manufacturers or importers, in the technical documentation under Annex VII. Who counts as the manufacturer of a given package is set in Article 3 and Article 15; see who PPWR applies to.

Is chemically recycled plastic allowed?

Article 7 does not exclude it. Whether and how it counts depends on the sustainability criteria and methodology due by 31 December 2026 (Article 7(8) and 7(9)).

Can the percentages change before 2030?

Yes, in limited ways: derogations for the 10% and 35% categories after the 2028 assessment (Article 7(12)), or an adjustment for lack of supply or excessive prices (Article 7(13)).

Where Carbonorm fits

Article 7 evidence starts with your suppliers. The Carbonorm continuous PPWR compliance platform collects supplier declarations through a secure form, with no account or login needed. Each figure is stored next to the PPWR article it supports and the date it was recorded. When the Article 7(8) implementing act is published, we process it into the rule set and log the change in the public changelog.

A free PPWR audit walks one bill of materials with a regulatory engineer. You leave with the evidence gaps and the article behind each.

Get the PPWR readiness checklist · Book a free PPWR audit

Source: Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025, Articles 3, 7, 8, 12 and Annex VII; Commission Notice C(2026) 3702, section 7. Rule set as of 5 October 2026. Implementing and delegated acts under Article 7(8)–(10) are due by 31 December 2026; check the change-log for their status.