Recycled Content (PCR) in Plastic Packaging under the PPWR
Recycled content is the share of a plastic packaging component that comes from recycled material rather than primary raw materials. Under Article 7 of Regulation (EU) 2025/40 (PPWR), minimum recycled content becomes a binding legal requirement for plastic packaging placed on the EU market. Any plastic part of packaging must contain a minimum percentage of recycled content recovered from post-consumer plastic waste. The figure is calculated as an average per manufacturing plant and year. The first thresholds apply from 1 January 2030, or three years from the entry into force of the implementing act on the methodology, whichever is the latest. They rise substantially by 1 January 2040.
The industry shorthand for this material is PCR, post-consumer recycled. A precision worth stating up front, because most commercial material gets it wrong: the PPWR never uses the terms PCR or PIR. The Regulation works with the notion of recycled content recovered from post-consumer plastic waste, defined in Article 3. The reference definitions for post-consumer and pre-consumer material come from the international standard ISO 14021, not from EU law. This page uses PCR as the industry term while anchoring every normative statement in the exact wording of the Regulation.
What this guide covers
This guide covers what qualifies as recycled content and what does not, how to read a PCR percentage correctly, and the thresholds per packaging category with their exact dates and exemptions. It also covers the food contact framework for recycled plastic and what the requirements mean commercially for buyers of flexible packaging. Every legal citation is taken from the official English text of Regulation (EU) 2025/40 published in the Official Journal of the European Union.
Everything below also exists as a 31-page technical guide, with Article 7 quoted paragraph by paragraph. Free download, no registration, at the end of this page.
Recycled content targets at a glance
| Mandatory from | 1 January 2030, or 3 years from the entry into force of the implementing act on the methodology, whichever is the latest (Article 7(1)) |
| Legal basis | Article 7 PPWR, with packaging types and formats in Table 1 of Annex II |
| What counts | Only recycled content recovered from post-consumer plastic waste. That means material from products placed on the market and used by an end user (Article 3(1), point (48)) |
| What does not count | Pre-consumer and post-industrial material (PIR), including a converter’s own reprocessed production scrap, regrind and edge trim; bio-based origin; compostable plastics |
| 2030 thresholds | 10% for contact-sensitive packaging made from plastics other than PET, flexible PE and PP food packaging included. 30% for contact-sensitive PET. 30% for single-use beverage bottles. 35% for all other plastic packaging |
| 2040 thresholds | 25% for contact-sensitive non-PET. 50% for contact-sensitive PET. 65% for single-use beverage bottles. 65% for other plastic packaging (Article 7(2)) |
| How it is calculated | Per plastic part of the packaging, as an average per manufacturing plant and year. Not per individual pack, and not on the total pack weight |
| Key exemptions | Medicinal products and medical devices, compostable plastic packaging, food for infants. Plus any plastic part below 5% of the total packaging weight (Article 7(4) and (5)) |
| Methodology status | The Commission must adopt the calculation and verification methodology by 31 December 2026 (Article 7(8)). Not yet published as of August 2026 |
| EPR link | Extended producer responsibility fees may be modulated by recycled content percentage (Article 7(7)) |
Navigate this guide
Source: Regulation (EU) 2025/40, Articles 3 and 7, official English text, Official Journal of the EU.
What recycled content means legally
Under the PPWR, recycled content that counts towards the Article 7 thresholds means exclusively material recovered from post-consumer plastic waste, as defined in Article 3(1), point (48). Pre-consumer and post-industrial material never qualifies, however clean or well reprocessed it is. The definition the entire obligation rests on reads:
The two recycled content definitions in Article 3
“‘post-consumer plastic waste’ means waste that is plastic and that has been generated from plastic products that have been placed on the market or supplied for distribution, consumption or use in a third country in the course of a commercial activity, whether in return for payment or free of charge;”
The key element is placing on the market. Note also what the definition does not say: it does not require a household. Waste generated by commercial, industrial or institutional end users qualifies, provided the product was previously placed on the market. Pallet wrap removed and discarded by a logistics centre is post-consumer waste; a converter’s own production scrap is not.
The categories that carry different thresholds are defined just as precisely:
“‘contact-sensitive packaging’ means packaging that is intended to be used for products falling within the scope of Regulations (EC) No 1831/2003 […], (EC) No 1935/2004, (EC) No 767/2009 […], (EC) No 1223/2009 […], (EU) 2017/745, (EU) 2017/746, (EU) 2019/4 […] or (EU) 2019/6, or of Directives 2001/83/EC, 2002/46/EC […];” (quoted with omissions marked)
Contact-sensitive therefore covers far more than food: cosmetics, medicinal products, medical devices, feed and food supplements are all in scope. Guides that split the thresholds into food and non-food simplify incorrectly; a cosmetic cream pouch is as contact-sensitive as a coffee pouch.
Can manufacturers use their own production waste to meet the targets?
No. Internal scrap, edge trim, start-up waste and rejected rolls never left the factory. They do not come from products placed on the market, so they cannot generate post-consumer plastic waste under Article 3(1), point (48). They do not count towards any Article 7 threshold. The confusion is common because reprocessing internal scrap is legitimate, widespread and economically sensible industrial practice. It simply belongs to manufacturing efficiency, not to recycled content compliance. The reference definitions go one step further. Under ISO 14021, rework and regrind reclaimed within the same process that generated them are not even pre-consumer recycled material. They are simply part of the manufacturing process. A supplier certificate claiming recycled content based on reprocessed production waste therefore proves nothing for Article 7.
How to read a PCR percentage
A claim such as “30% PCR” means that 30% of the material, by weight, comes from post-consumer recycled sources rather than virgin polymer. It says nothing about whether the packaging is recyclable, and it does not mean every individual pack contains exactly 30%.
Under the PPWR, the percentage has a precise legal meaning. It applies to each plastic part of the packaging separately, not to the pack as a whole. On a pouch with a body, a valve and a zipper, each plastic component must individually meet the threshold. Parts below 5% of the total packaging weight are the exception. And it is calculated as an average per manufacturing plant and year, per packaging type and format, not measured pack by pack. A single pouch off the line may contain more or less than the threshold. What the Regulation checks is the annual average at plant level.
Two common misreadings of a recycled content percentage
First, a PCR percentage is not calculated on the total weight of the structure as a single figure. The per-plastic-part logic of Article 7 is stricter than that. Second, a percentage seen on paper packaging, such as 60% recycled content on a paper bag, refers to recycled fibre. It belongs to a different material framework entirely; the PPWR plastic thresholds in this guide apply to plastic parts only.
The official calculation and verification methodology is due by 31 December 2026, under Article 7(8). Until then, percentages declared today rest on voluntary certification schemes and supplier documentation. Useful and recommended, but they will need to be aligned with the official methodology once it is adopted.
What is the difference between PCR, PIR and rPET?
PCR and PIR describe the origin of the waste, while rPET, rPE and rPP name the recycled polymer. PCR comes from products used by end users, PIR from manufacturing waste, and only PCR counts towards the PPWR thresholds. Supplier correspondence routinely blurs these concepts, and the differences are not stylistic. The table separates them.
Term by term
| Term | What it actually means | Counts towards Article 7? |
| PCR (post-consumer recycled) | Material recycled from products that were placed on the market and used by an end user, household or commercial. Industry term defined by ISO 14021; functional equivalent of the PPWR notion of recycled content recovered from post-consumer plastic waste. | Yes, subject to the origin conditions of Article 7(3) |
| PIR (post-industrial recycled) | Material recycled from manufacturing waste, such as another converter’s edge trim, before any product reached an end user. Technically and commercially valuable, legally not post-consumer. | No, never |
| rPE, rPP, rPET | Recycled polyethylene, polypropylene or PET. The r prefix describes the polymer, not the origin: an rPE granule can be post-consumer or post-industrial. Origin must be verified in batch documentation, not assumed from the name. | Only if documented post-consumer |
| rPET vs PCR | Not alternatives but different axes: rPET names the polymer (recycled PET), PCR names the waste origin. Post-consumer rPET is both at once. The frequent question “rPET or PCR?” compares a material with an origin category. | rPET counts when its origin is post-consumer |
| Recyclable | A design property: whether the pack can be sorted and reprocessed after use (Article 6 PPWR). Independent of recycled content: a 100% virgin pack can be perfectly recyclable, and a PCR-rich pack can be hard to recycle. | Separate obligation (Article 6), both apply to the same pack |
The procurement rules for recycled content
→ Article 7 counts only recycled content recovered from post-consumer plastic waste.
→ Any recycled content claim must specify post-consumer origin to qualify.
→ A certificate that does not state the post-consumer origin of the waste does not prove Article 7 compliance; ask for the origin on the batch documentation, not the label on the granule.
The PPWR targets: Article 7 by category and date
Flexible PE and PP food packaging is governed by category (b), contact-sensitive packaging made from plastics other than PET, with 10% recycled content from 2030 and 25% from 2040. The full picture by category:
| Category (Article 7) | Typical examples | From 1 Jan 2030* | From 1 Jan 2040 |
| (a) Contact-sensitive, PET as major component (excl. single-use beverage bottles) | Thermoformed PET trays and films for food | 30% | 50% |
| (b) Contact-sensitive, plastics other than PET (excl. single-use beverage bottles) | Flexible PE and PP films and pouches for food, cosmetics, supplements, feed; EcoMonoFilm monomaterial food packaging | 10% | 25% |
| (c) Single-use plastic beverage bottles (whatever the polymer) | Bottles for water and soft drinks, most often PET, but the category also includes HDPE and PP | 30% | 65% |
| (d) Other plastic packaging | Pallet stretch film, industrial sacks, carrier bags, packaging for non-contact-sensitive products | 35% | 65% |
* Or 3 years from the entry into force of the implementing act on the methodology, whichever is the latest (Article 7(1)). The highlighted row is the one that governs flexible PE and PP food packaging.
When the thresholds become mandatory
The timing runs on three fixed points. The PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026. There is no minimum recycled content obligation at that date. The Article 7 thresholds apply from 1 January 2030, or three years from the entry into force of the implementing act on the methodology, whichever is the latest. If the methodology enters into force after 1 January 2027, the deadline moves accordingly.
Where the waste must come from (Article 7(3))
Not every post-consumer granule on the world market qualifies. The waste must have been collected in the EU under the PPWR and the waste framework rules, or in a third country under equivalent separate collection standards. And it must have been recycled in installations meeting EU environmental rules or their equivalent. For procurement this means the traceability of the waste origin becomes part of the compliance file, especially for imported recycled granules. The equivalence assessment and certification for third countries will be regulated through implementing acts.
Exemptions (Article 7(4) and (5))
The thresholds do not apply to, among others: immediate packaging of medicinal products and, under conditions, their outer packaging; plastic packaging of medical devices and in vitro diagnostics; compostable plastic packaging; and packaging for food intended for infants and for special medical purposes. Crucially for flexible packaging, any plastic part below 5% of the total weight of the packaging unit is also exempt. That spares components such as degassing valves and zippers. A safety valve protects food packaging too. Where recycled content would create a risk for human health and non-compliance with Regulation (EC) No 1935/2004, the thresholds do not apply to that packaging.
Methodology and verification (Article 7(8) to (11))
Status at the time of writing: the official calculation and verification methodology has not yet been published. The Commission must adopt it by 31 December 2026, together with sustainability criteria for recycling technologies and the equivalence methodology for third countries. From 1 January 2029, or 24 months from the entry into force of the implementing act, whichever is later, calculation and verification must follow the adopted rules. They may include mandatory third-party audits.
The PPWR text does not use the term mass balance and does not settle how chemically recycled content will be allocated. Any recycled content figure declared today rests on voluntary schemes and supplier documentation. Categorical claims on chemical recycling allocation are speculation until the methodology is adopted.
The commercial upside: EPR modulation (Article 7(7))
Extended producer responsibility fees may be modulated according to the recycled content percentage used in packaging. The wording is permissive, so implementation depends on each Member State and scheme. The direction is clear: recycled content is positioned not only as an obligation but as a potential fee advantage.
Built-in review clauses
The thresholds are firm in the text but not beyond adjustment. By 1 January 2028 the Commission must assess the need for derogations for the non-PET categories, precisely the ones covering PE and PP films, where suitable recycling technologies are not available. By 12 February 2032 it must review the application of the 2030 thresholds and the feasibility of the 2040 ones. Investment planning should treat the 2040 levels as a confirmed direction with a level subject to review.
A recurring confusion: Article 5 is not the recycled content article
Searches about PPWR recycled content often surface Article 5, and the two get conflated in supplier correspondence. They are different obligations with different dates. Article 5 governs restrictions on substances in packaging, including the PFAS limits for food-contact packaging that apply from 12 August 2026. Recycled content is Article 7, with thresholds applying from 1 January 2030 at the earliest. A pack must satisfy both, but confirming PFAS compliance says nothing about recycled content, and vice versa. Both are declared through the same conformity system: the PPWR Declaration of Conformity covers the applicable requirements of Articles 5 to 12.
Recycled content and food contact: can PCR be used in food packaging?
Yes, under conditions. Recycled plastic may be used in food packaging only if it comes from a process compliant with Regulation (EU) 2022/1616, with decontamination performance evaluated by EFSA and the process registered in the Union register. The finished pack must meet the migration rules for plastics. The PPWR thresholds do not suspend food safety law; Article 7(5) makes food safety an explicit limit on the obligation. The framework runs in parallel with the PPWR. Regulation (EC) No 1935/2004 sets the general requirements for all food contact materials, and Regulation (EU) No 10/2011 governs plastics specifically. Regulation (EU) 2022/1616 is the act that decides, in practice, whether and how PCR can enter a food pack. It makes quality assurance, declarations of compliance and batch traceability mandatory along the chain.
The practical picture by polymer
| Polymer | Food contact with PCR today |
| rPET | Mature route: EFSA-evaluated decontamination processes for post-consumer PET have been authorised for years, and food-grade rPET is commercially available at scale. |
| rPE / rPP, mechanical recycling | Difficult route: polyolefins absorb contaminants more readily than PET, and demonstrating decontamination to the required level remains the core challenge. Food-contact mechanical rPE and rPP are the exception today, not the rule. That is exactly why Article 7(12) requires the Commission to reassess the non-PET categories by 2028, with possible derogations. |
| rPE / rPP, chemical recycling | Depolymerisation or pyrolysis followed by repolymerisation yields polymer of virgin-equivalent purity, which simplifies food safety. Industrial availability and cost remain the main limits. How it will count towards Article 7 depends on the pending methodology. |
Safety questions, answered factually
Search data shows the most asked safety question is about BPA. Bisphenol A is not intentionally used in polyethylene or polypropylene production. Concerns about it relate mainly to polycarbonate and epoxy linings, different materials from the polyolefin films covered here. More broadly, food-contact PCR is not simply recycled plastic put next to food. It is material from an EFSA-evaluated decontamination process, in a pack whose migration compliance is tested for the intended use.
Quality, cost and sourcing: what PCR means in a real structure
PCR is not a specification; it is an origin. Two batches of post-consumer rPE can differ meaningfully in melt flow index, gel and impurity content, colour, odour and batch-to-batch consistency. The difference comes from the collection stream, the recycler’s technology and the degree of sorting. Integrating it into flexible film is engineering work. It means source selection, dosing into the layers where the impact on optics and surface properties is lowest, and validation on the extrusion line and on the customer’s packing line. At the 10% level required for food packaging in 2030, the mechanical impact in a well designed co-extruded structure is manageable. Higher shares demand progressively more careful source control.
Cost and the EPR angle
On cost, the honest answer is that PCR is not automatically cheaper or more expensive than virgin. Pricing follows oil prices, collection efficiency and the supply-demand balance for quality post-consumer material, and it moves. What is structural rather than cyclical is the EPR angle. Article 7(7) allows producer responsibility fees to be modulated by recycled content. That can turn PCR from a cost line into a fee advantage as Member State schemes implement it.
The supplier questions on recycled content origin
The questions to put to any supplier of recycled granules follow directly from the law:
→ What is the documented post-consumer origin of the waste, per batch?
→ In which country was the waste collected, and on what equivalence basis if outside the EU?
→ Which recycling installation produced the material, and does it carry chain-of-custody certification?
→ Can you provide the technical data sheet and batch certificates?
→ For food contact: what is the process status under Regulation (EU) 2022/1616, and where is its Union register entry?
For customers building recycled content into monomaterial structures, the supplier-side documentation that feeds the compliance file comes with the films delivered. That is the information transfer obligation of Article 16 PPWR. The structural side of that work is covered on the monomaterial PE page and the wider sustainability section.
Frequently asked questions
What does 20% or 30% PCR mean?
That 20% or 30% of the material, by weight, comes from post-consumer recycled sources rather than virgin polymer. Under the PPWR the figure applies per plastic part of the packaging and is calculated as an annual average per manufacturing plant. It is not measured on each individual pack.
Is PCR a type of plastic?
No. PCR describes an origin, not a polymer. Post-consumer recycled material exists as rPE, rPP, rPET and other polymers. The properties come from the polymer and the recycling process. The PCR label only tells you the material was recovered from products used by end users.
What is the difference between rPET and PCR?
They answer different questions. rPET names the polymer, recycled PET; PCR names the waste origin, post-consumer. Post-consumer rPET is both at once, while rPET made from industrial scrap is recycled PET but not PCR. The two terms are complementary, not alternatives.
What is the difference between recycled content and PCR?
Recycled content is the umbrella: any material that went through a recycling process, post-consumer or pre-consumer. PCR is the post-consumer subset. The distinction is decisive under the PPWR, because Article 7 counts exclusively recycled content recovered from post-consumer plastic waste.
Does pre-consumer or post-industrial material count towards the PPWR targets?
No. Material from manufacturing waste, including a converter’s own reprocessed scrap, does not come from products placed on the market. It is not post-consumer plastic waste under Article 3(1), point (48). Reusing it in production remains legitimate industrial practice; it simply does not count towards Article 7.
Do the PPWR recycled content targets apply from 2026?
No. The PPWR applies generally from 12 August 2026. The minimum recycled content thresholds apply from 1 January 2030, or three years from the entry into force of the implementing act on the methodology, whichever is the latest. Before that date there is no percentage obligation, only preparation work worth doing.
Does chemically recycled content count towards the PPWR targets?
In principle yes, if the input is post-consumer plastic waste: the PPWR defines recycled content by the origin of the waste, not by the recycling technology. What is not settled is how chemically recycled content will be measured and allocated. That depends on the calculation and verification methodology the Commission must adopt by 31 December 2026. Categorical claims about chemical recycling allocation are premature until it is published.
Can recycled content be mass balanced under the PPWR?
The PPWR text does not use the term mass balance and does not settle the question. Chain-of-custody schemes based on mass balance, such as ISCC PLUS, are voluntary industry certifications, not a form of PPWR recognition. Whether and how mass balance accounting will be accepted for Article 7 depends on the pending methodology. Until then, any categorical claim in either direction is speculation.
What documentation is needed to prove PPWR recycled content compliance?
The recycled content percentage is demonstrated in the technical documentation drawn up under Annex VII. It is declared through the EU Declaration of Conformity drawn up under Article 39 and Annex VIII. Supplier evidence of the post-consumer origin of the waste supports it, per batch. The full documentation chain, with a downloadable template, is covered in the PPWR Declaration of Conformity guide.
Is PCR plastic food safe?
It can be, under conditions. Recycled plastic for food contact must come from a process compliant with Regulation (EU) 2022/1616, with decontamination performance evaluated by EFSA and the process registered in the Union register. The finished pack must meet the migration requirements of Regulation (EU) No 10/2011. For rPET this route is mature; for mechanically recycled rPE and rPP it remains the exception today.
Does PCR plastic contain BPA?
Bisphenol A is not intentionally used in polyethylene or polypropylene, the polymers of flexible packaging films. BPA concerns relate mainly to polycarbonate and epoxy materials. Food-contact PCR additionally passes an EFSA-evaluated decontamination process and migration testing for the intended use. That is what its declaration of compliance documents.
Is PCR plastic compostable?
No, and the two are opposites in the PPWR’s logic. PCR polyolefins are conventional plastics whose end-of-life route is mechanical recycling. Compostable plastic packaging is a separate category, and it is expressly exempt from the recycled content thresholds under Article 7(4). Bio-based origin does not count as recycled content either.
Is PCR more expensive than virgin plastic?
Sometimes, not always. PCR pricing follows oil prices, collection efficiency and demand for quality post-consumer material, so the premium fluctuates and can invert. The structural factor working in PCR’s favour is Article 7(7): EPR fees may be modulated by recycled content percentage, depending on each Member State scheme.
How is the recycled content percentage verified?
Today, through voluntary schemes and supplier documentation, since the official methodology has not been published. The Commission must adopt the calculation and verification methodology by 31 December 2026, and it may include mandatory independent third-party audits. From 1 January 2029, or 24 months from the act’s entry into force, whichever is later, verification must follow those rules. Manufacturers and importers demonstrate compliance in the technical documentation behind the PPWR Declaration of Conformity.
Related resources
The complete guide, in PDF format
White paper: Recycled Content in Plastic Packaging under the PPWR (PDF)
A 31-page technical guide: Article 7 quoted paragraph by paragraph from the Official Journal English text, the PCR and PIR distinction, the thresholds per packaging category, the food contact framework, the Commission guidance on who the manufacturer is, the environmental claims regime, 34 frequently asked questions and 11 myths checked against the Regulation. Free download, no registration.
PPWR Declaration of Conformity (DoC)
How recycled content is declared in practice: the conformity document behind Articles 5 to 12, who draws it up and signs it, the Annex VIII structure, and a free Word template.
Monomaterial PE for Flexible Packaging
The structures recycled content goes into: MDO-PE and PE sealant webs, barrier and sealing behaviour, and where the all-PE route fits.
Flexible Packaging Sustainability
The regulatory context: the PPWR timeline, design for recycling, and why recyclable rarely means recycled.
Technical Glossary for Flexible Packaging
127 searchable terms: polymers, barriers, processes, packaging types and properties relevant to PCR-content structures.
PPWR & Legal Glossary
73 searchable terms: recyclability classes, PFAS, recycled content, eco-modulated EPR and Declaration of Conformity.
The recycled content documentation comes with delivery
Send your current structures and product requirements. Films delivered come with the technical data sheet, material declarations and per-batch recycled content certificates where the structure contains rPE or rPP. This is the information a supplier must provide under Article 16 PPWR, not a consultancy service.
The Annex VII technical documentation, the annual average per manufacturing plant and the EU Declaration of Conformity remain with the packaging manufacturer.