PPWR Article 7: Is It Really 30% Recycled Content by 2030?

Someone told you that from 2030, your plastic packaging needs 30% recycled content. Maybe it was a supplier, a consultant or a trade article. Now you are trying to work out what that means for your company.

Here are the numbers. They come from Article 7 of the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40. Each figure is the minimum share of recycled content, recovered from post-consumer plastic waste, in the plastic part of your packaging (Art. 7(1), Art. 7(2)).

So yes, 30% is in the table. But it applies to only two of the four categories (Art. 7(1)(a), Art. 7(1)(c)). If your packaging is neither contact-sensitive nor a beverage bottle, your number is 35% (Art. 7(1)(d)). If it is contact-sensitive but not made mainly from PET, it is 10% (Art. 7(1)(b)).

The numbers are right. Almost everything else in “30% by 2030” is not. The rule is not measured per product. 2030 is not necessarily the date. And your packaging may be exempt altogether. We go through each point below, with the article reference behind every claim, so you can check it yourself against the official text of Regulation (EU) 2025/40.

Does the recycled content rule apply per product or per plant?

Per plant. This is the point most explainers get wrong, and it changes how you should think about the whole rule.

Recycled content under Article 7 is calculated as an average per manufacturing plant and per year, for each packaging type and format listed in Table 1 of Annex II (Art. 7(1)). A single product does not pass or fail on its own. What passes or fails is the annual average of one packaging type and format, coming out of one plant.

That has consequences in both directions.

It gives you room. A producer can put one product on the market at 12% recycled content and another at 48% and still be compliant, as long as both fall under the same packaging type and format, come from the same plant, and the annual average clears the threshold (Art. 7(1)). You do not have to push every SKU to the line.

It also works against you. A product can be dragged down by its neighbours. A pouch with 40% recycled content does not make you compliant if everything else of that packaging type and format from the same plant pulls the average below the threshold (Art. 7(1)). And a second plant producing the same format has its own average, judged on its own (Art. 7(1)).

Most importantly, it means the question producers usually ask their suppliers is not the question the Regulation asks. “Does this film contain 30% recycled plastic?” tells you about one input. The Regulation asks about the average across everything of that type and format your plant produces in a year (Art. 7(1)). Nobody can answer that for you. It comes from your own production data.

Is 1 January 2030 really the deadline?

Not necessarily. The binding date in Article 7(1) is, word for word:

“1 January 2030 or 3 years from the date of entry into force of the implementing act referred to in Article 7(8), whichever is the latest”

The date depends on an implementing act the Commission has to adopt under Article 7(8). That act is due by 31 December 2026 (Art. 7(8)). It has not been adopted.

The arithmetic is simple. If the implementing act enters into force on or before 1 January 2027, three years later is on or before 1 January 2030, and 1 January 2030 is the binding date. If it enters into force later, the binding date moves back by the same amount. An act that enters into force in June 2027 would push the date to June 2030 (Art. 7(1)).

So the binding date cannot be computed today. It could be 1 January 2030. It could be later. Anyone who gives you a firm date is guessing, and we would be guessing too if we gave you one.

This does not mean you can relax. 1 January 2030 is the earliest possible date, and it stays in play until the implementing act is adopted (Art. 7(1)). It does mean you should be careful with anyone selling you a packaging redesign against a fixed deadline.

The 2040 thresholds work differently. Article 7(2) sets them from 1 January 2040, and they are not tied to the implementing act in the same way (Art. 7(2)).

Is my packaging exempt from the recycled content targets?

Possibly. Article 7 does not apply to all plastic packaging. The exemptions in Article 7(4) and 7(5) include, among others (Art. 7(4), Art. 7(5)):

• immediate packaging of medicinal products, and outer packaging where it is critical to product quality
• contact-sensitive packaging of medical devices
• contact-sensitive packaging of in-vitro diagnostic devices
• compostable plastic packaging
• packaging for the transport of dangerous goods
• contact-sensitive packaging for infant and young-child food, and for food for special medical purposes
• cases where recycled content would pose a risk to human health or lead to non-compliance with food-contact rules
• packaging of supplies and components used in manufacturing medicinal products, where it has to meet the medicine’s quality standards (Art. 7(4)(h))
• any plastic part that makes up less than 5% of the total weight of the whole packaging unit (Art. 7(5)(b))

The last one surprises people. It works at the level of the part, not the package. Labels and sleeves often weigh less than 5% of the whole packaging unit, which takes them out of the calculation (Art. 7(5)(b)). Closures and lids may or may not fall under the line. Weigh them rather than assume.

Article 7(4) contains one more point, 7(4)(h): packaging of supplies and components used in manufacturing medicinal products, where the packaging has to meet the medicine’s own quality standards (Art. 7(4)(h)). It is not consumer packaging, which is why it reads oddly beside the rest. Before you rely on any exemption, read its exact wording in the official text. Several of them come with conditions, and the conditions decide whether you are in or out.

What proof will I be asked for?

Article 7(6) says: “Compliance with the requirements set out in paragraphs 1 and 2 of this Article shall be demonstrated by manufacturers or importers in the technical information concerning the packaging referred to in Annex VII.”

Read it carefully, because it is easy to over-read. The duty is to demonstrate compliance with the thresholds in paragraphs 1 and 2. Those thresholds do not bind yet. So this is not a separate obligation that applies today: it is how you will have to show compliance once they do (Art. 7(6)).

There is a second reason it cannot be finished today. The same implementing act that fixes the binding date also establishes “the format for the technical documentation referred to in Annex VII” (Art. 7(8)). That act has not been adopted, so the format you will eventually have to produce does not exist yet.

None of which makes it something to leave alone. The underlying work is slow regardless of what the final format looks like: knowing, per plant and per year, which packaging types and formats you produce, how much plastic goes into them, and how much of that plastic is recycled content with evidence of where it came from (Art. 7(1), Art. 7(3)). Gathering that takes far longer than the calculation, and none of it is wasted whatever the format turns out to be.

What should I do this year?

Three things, and one thing to avoid.

1. Establish your current plant average per packaging type and format. For each plant, list the packaging types and formats you produce according to Table 1 of Annex II, the plastic weight of each, and the share of post-consumer recycled content (Art. 7(1)). Leave out plastic parts under 5% of the unit’s weight (Art. 7(5)(b)). This gives you your starting point and the size of your gap.
2. Start collecting provenance evidence from your suppliers. The Regulation sets conditions on where recycled content has to come from for it to count (Art. 7(3)). A supplier’s word that a material is “30% recycled” is not evidence. Ask each supplier what documentation they can provide on the origin of the recycled material. Expect this to take months, especially for suppliers who have never been asked.
3. Check whether an exemption applies to any of your packaging, using the official wording rather than a summary, including this one (Art. 7(4), Art. 7(5)).

What to avoid: redesigning your packaging against a date nobody can compute yet. The binding date depends on an implementing act that has not been adopted (Art. 7(1), Art. 7(8)). Plan against your gap, not against a calendar someone else made up.

It comes down to one number

Everything above comes back to one number: your plant-level annual average of recycled content, per packaging type and format (Art. 7(1)).

Your supplier cannot give you that number. Neither can an article that says “30% by 2030”. It comes from your own production data, and until you have it, you do not know whether you have a problem, how big it is, or where it sits.

Once you have that number, our free checker tells you what Article 7 makes of it. You enter one product’s packaging and your plant average, and it reports which requirements apply, which are met, and which do not bind yet, with the article reference behind every result. It does not calculate the average for you: that comes from your own production data, and it is the part nobody can do on your behalf. It will not tell you your deadline either, because nobody can yet. It tells you where you stand.