EU PPWR Recycled Plastic Content Rules: Call for Evidence

The European Commission has published a call for evidence on the future calculation and verification of recycled plastic content under the EU Packaging and Packaging Waste Regulation (PPWR).

The initiative concerns an implementing act under Article 7(8) of the PPWR. It is intended to establish a harmonised method for calculating and verifying recycled content recovered from post-consumer plastic waste collected and recycled within the European Union.

The future act is also expected to set the format of the technical documentation needed to demonstrate compliance.

Three related measures

The call for evidence forms part of a wider package of three planned Commission measures related to recycled plastic content in packaging.

• Rules for calculating and verifying recycled plastic content in packaging.
• Sustainability criteria for plastic recycling technologies.
• Conditions for recognising plastic recyclates, or articles containing recycled plastic, imported from non-EU countries.

Together, these measures are expected to determine which recycled materials can be counted towards PPWR recycled-content targets and how companies will need to document this.

Data and verification requirements

The forthcoming rules may require extensive data on recycled-content quantities, material quality, recycling processes, traceability and environmental performance. Information on emissions may also be relevant when assessing the sustainability of recycling technologies.

Companies using recycled plastics should therefore consider whether they can obtain reliable and verifiable information from material suppliers, recyclers, compounders and converters. This includes evidence supporting the origin of the feedstock and the post-consumer status of plastic waste.

Expected timeline

The Commission has indicated that adoption of the implementing act is planned for the fourth quarter of 2026. However, a draft legal text had not yet been published when the call for evidence was launched, so the timetable may change.

The call for evidence does not introduce new obligations by itself. It is an early stage in the preparation of the implementing rules that will support the PPWR recycled-content requirements.

What this means for companies

Packaging manufacturers, brand owners, importers and recyclers should use this period to assess the availability and quality of recycled-content data across their supply chains.

Early preparation may help companies identify gaps in chain-of-custody documentation, supplier declarations, material traceability and data systems before detailed verification requirements are adopted.

Source: European Commission, Packaging and packaging waste – sustainability criteria for plastic recycling technologies ; and Regulation (EU) 2025/40 on packaging and packaging waste.