Requirements for recycled content in packaging are becoming increasingly important as a result of new European environmental regulations. The wide variety of packaging materials in circulation accounts for a significant share of total waste volumes and is therefore a key focus of regulatory measures.
With the EU regulation on recycled content in packaging and packaging waste, companies will be held more accountable in the future. A clear objective of this approach is to conserve resources and strengthen a functioning circular economy. In this article, we provide you with comprehensive information on this topic.
What do the EU requirements for recycled content in packaging look like?
The growing consumption of packaging over recent decades has led to increasing pressure on the environment and waste management systems. For this reason, modern recycling systems are more essential than ever. One material resulting from these processes is known as recyclate.
As a material that can be returned to the cycle, packaging materials require specific recycled content requirements. The aim is to minimize the use of virgin raw materials and instead promote higher levels of reuse.
This is not only about the quantity of recycled material used, but about a fundamental rethink in packaging design. Packaging should be designed so that, after use, it can be efficiently collected, sorted, and recycled, while also complying with the requirements of the Packaging Act.
Some of the key requirements for regulating recycled content in packaging in the EU by 2026 include:
- Reducing packaging volume already at the product development stage
- Avoiding non-recyclable or problematic materials
- Increasing the recycled content of packaging
- Improving actual recyclability in real-world operations
The PPWR as the new foundation of European packaging policy
With the new recycled content requirements for packaging, the EU is replacing the previous directive from the 1990s that served as the legal framework for many years. These changes are a central component of the European Green Deal and therefore take a much broader approach. A comprehensive harmonization of key processes across all Member States is planned – similar to the Waste Framework Directive.
For the first time, the PPWR considers packaging holistically across its entire life cycle. This means that not only the disposal of packaging is subject to recycled content requirements, but that these must also be considered during conception, design, and manufacturing. Uniform labeling, standardized terminology, and harmonized design requirements create transparency and make implementation easier for internationally active companies. These measures also take into account and simplify reporting obligations for packaging in online trade.
Recyclability and minimum recycled content quotas
A central element of the recycled content requirements for packaging is the introduction of binding minimum quotas for recycled material, especially for plastic packaging. The specific recycled content share will be determined depending on the packaging type and its intended use and will be gradually increased. Companies are therefore not only required to use the LUCID packaging register and EPR registration numbers, but must also prepare and digitize the necessary data in detail.
At the same time, the concept of recyclability is being more precisely defined. From 2030 onwards, only packaging that meets clearly defined technical criteria may be placed on the market. These include in particular:
- Sortability in existing collection and separation systems
- Material compatibility with established recycling processes
- Avoidance of composite materials that are difficult to separate
- Exclusion of certain harmful substances from 2026 onwards
In addition, a Europe-wide classification system will be introduced to assess compliance with recycled content requirements and evaluate the recycling performance of individual packaging. In the long term, only materials that meet these requirements will remain on the market.
Introduction and timeline of the new requirements
The recycled content requirements for packaging will be implemented step by step. From August 2026, recycled-content packaging will become mandatory in the EU. In this first phase, key obligations will come into force, including bans on certain packaging formats, harmonized labeling, and initial control mechanisms.
Between 2027 and 2029, further technical specifications will follow, such as calculation methods for waste prevention or the evaluation of alternative raw materials. From 2030, full recyclability of all packaging materials in circulation is planned. Waste reduction and the associated conservation of resources will also be further expanded. These are long-term goals in which the recycled content regulations for packaging represent an essential first step.
Which companies and sectors are affected by the recycled content requirements for packaging?
The recycled content regulations for packaging affect all companies that place packaging on the European market. This includes manufacturers, retailers, importers, as well as companies with private labels. Sectors with particularly high packaging volumes are especially affected, such as e-commerce, food retail, gastronomy, and take-away concepts. In the future, all actors along the entire supply chain will be more strongly obligated. There will also be a stronger focus on monitoring obligations for online marketplaces and sales bans following EPR violations.
This results in concrete fields of action for companies:
- Adapting existing packaging solutions
- Reviewing suppliers and material sources
- Documenting recyclability and recycled content shares
- Aligning internal processes with new control and verification obligations
Packaging from third countries will also be subject to the same requirements in the future. This is particularly important for internationally oriented sectors such as the textile industry. You can find more information on EPR for textiles and EPR for mattresses on our blog.
Reuse, substance bans, and circular economy
In addition to recycled content requirements for packaging, reuse is becoming a stronger focus. Reusable packaging will become mandatory for certain applications. Standardized formats for transport packaging such as crates, boxes, or pallets are intended to facilitate exchange between European market participants and promote reuse.
There is also a stronger focus on minimizing and banning substances that are harmful to human and animal health. Particular attention must be paid to materials from retailers outside the EU. By conducting early checks and aligning with recycled content requirements for packaging, you can avoid conflicts and manage the new rules effectively.
Recycled content requirements for packaging as a strategic challenge
The new requirements are not only a legal obligation but are increasingly becoming a strategic competitive factor. Transparent and reliable recycled content requirements for packaging strengthen a company’s sustainability profile and improve its position with business partners, customers, and investors.
At the same time, the demands on internal processes, documentation, and traceability are increasing. The earlier you integrate recycled content requirements for packaging into your processes and decision-making, the better positioned you will be to make secure decisions for your company. We are happy to support you with our expertise in addressing all your questions and uncertainties.
FAQ: Recycled Content Requirements for Packaging
What do recycled content requirements for packaging specifically mean for companies?
Recycled content requirements for packaging oblige companies to design packaging so that it is recyclable and contains a defined share of recycled material. The aim is to reduce the use of virgin raw materials and promote effective material cycles. Companies must adapt their packaging technically, organizationally, and in terms of documentation. This affects design, material selection, and verification alike.
Which packaging falls under the recycled content requirements?
The requirements apply to all packaging placed on the EU market. This includes sales, shipping, and transport packaging. Packaging from third countries is also affected once it is offered on the EU market. Exceptions are only provided in clearly defined special cases.
Which sectors are particularly affected by recycled content requirements for packaging?
The EU recycled content requirements for packaging affect all sectors, but some are particularly impacted. These include e-commerce, food retail, gastronomy, and take-away services. These sectors use large volumes of single-use packaging, resulting in a particularly high need for adjustments in materials and processes.
Why are recycled content requirements for packaging also a strategic issue?
The requirements are not only a legal obligation but also influence a company’s market position. Sustainable packaging solutions strengthen the trust of customers, partners, and investors. At the same time, the demands on transparency and data quality increase. Those who act early gain clear competitive advantages.
What documentation obligations arise from recycled content requirements for packaging?
The EU requirements for packaging create extensive documentation obligations for companies. Recycled content shares, material compositions, and recyclability must be verifiable. This data is central for EPR reporting and official inspections. Digital preparation of this information therefore becomes indispensable.
