From 1 January 2030 plastic packaging must contain a minimum share of recycled material. Of all the requirements in the PPWR legislation, this is the only one you cannot solve with a better design or a thicker dossier. The material has to exist, and it has to be available to buy.
That is exactly where the tension lies.
The shares
| Packaging type | 2030 | 2040 |
|---|---|---|
| PET, in food contact | 30% | 50% |
| Non-PET plastic, in food contact | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| Other plastic (no food contact) | 35% | 65% |
The shares apply to packaging that is at least 5% plastic by weight. A cardboard box with a thin PE window therefore usually falls outside; a cardboard cup with a PE coating often does not.
Three conditions that make it hard
Only post-consumer recyclate counts. Material that a consumer actually threw away and that has been collected and processed. Production waste — trim waste, start-up waste, rejected runs that go back into the extruder — does not count, however circular that may be in itself.
The share is an average per plant per year. Not per packaging. That gives some slack: you can offset a difficult SKU with an easy one. But it also means that per production site you must be able to demonstrate what went down the line that year.
For food contact there is barely any material. Recyclate that may come into contact with food must comply with Regulation 1935/2004 and with the EU rules for recycled plastic in food-contact materials. For PET that chain exists — bottle-to-bottle has been running for years. For non-PET, think PP trays and PE film, food-grade recyclate is scarce to absent.
That is why the share for non-PET food is 10% and not 30%. And that is why the next paragraph is the most important part of this page.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
The calculation method does not yet exist
How you calculate the recycled-content share will be laid down in a delegated act. It must be in place by 31 December 2026 at the latest.
Among other things, it will decide whether chemical recycling on a mass-balance basis counts. That sounds technical and it is business-critical. In chemical recycling, waste plastic is broken down to its building blocks and repolymerised. The result is chemically identical to virgin material and therefore suitable for food contact. But in the plant it runs through the same installation as fossil feedstock, and you cannot tell the molecules apart afterwards.
Mass balance is the accounting solution: you buy in so many tonnes of recyclate, so you may sell so many tonnes of output as recyclate. Whether that will be allowed to count towards the PPWR shares, and if so under which allocation rules, has not been decided.
For non-PET food packaging, the feasibility of 10% in 2030 and 25% in 2040 depends almost entirely on this. There is no mechanical route that supplies food-grade PP in those volumes.
Take this into account in your supplier contracts: if you lock yourself in now on a price for mechanical recyclate, you are stuck once the act allows mass balance and the market shifts.
The exemptions
Exempt from the recycled-content obligation are:
- compostable plastic (Article 9)
- medicinal products and veterinary medicinal products
- medical devices and in-vitro diagnostics
- food for special medical purposes
- packaging that is less than 5% plastic by weight
- food-contact packaging where recyclate would conflict with the requirements of Regulation 1935/2004
That last exemption will be reviewed before 2035. Do not count on it staying in place.
The incentive is already running ahead
You do not have to wait until 2030 to benefit. Verpact doubled the recyclate discount on the waste-management fee to €0.20 per kilo, against a plastic tariff of €1.22 per kilo — the tariffs as they applied in 2025. They are set anew each year; check verpact.nl for the current amounts.
That means a switch to recyclate partly pays for itself before the obligation takes effect. See EPR registration under the PPWR.
What you can do now
- Determine the plastic weight share for each packaging. Below 5%: no obligation. That often covers more SKUs than you think.
- Split your portfolio into food contact and non-food contact. The routes and the availability differ fundamentally.
- Start with the 35% category. Other plastic without food contact — transport film, secondary packaging, industrial packaging. There, post-consumer recyclate is available, and the highest share applies precisely there.
- Test now, not in 2029. Recyclate behaves differently on the line: colour variation, odour, strength, processing temperature. You do not solve that in a quarter.
- Shift towards PET where possible for food contact. There the chain already exists.
- Ask your recyclate supplier for chain-of-custody evidence. Post-consumer, not post-industrial, with certification. Your technical dossier must demonstrate this — see declaration of conformity.
And keep an eye on the delegated act of late 2026. That is the moment this page has to be rewritten, and the moment the whole market starts moving at once.