Calculating recycled content: step by step

You do not calculate recycled content under PPWR Art. 7 per packaging item but as an annual average per manufacturing plant and per packaging type: post-consumer recyclate divided by the total plastic used in the same category. Staggered minimum quotas apply from 2030 (30/10/30/35%) and rise sharply from 2040 (50/25/65/65%). The evidence runs through the technical documentation (Annex VII) and the EU declaration of conformity (Annex VIII).

What is recycled content under the PPWR?

Recycled content is the share by mass of recycled plastic in a plastic packaging item. The PPWR (Art. 7) obliges manufacturers and importers to use a minimum share of post-consumer recyclate in every plastic part of their packaging. The aim is to create demand for recyclate and close the material loop.

An important distinction: recycled content (Art. 7) is a different topic from recyclability (Art. 6, assessment grades A/B/C). Recyclability asks whether a piece of packaging can be recycled; recycled content asks how much recycled material is already in it. Both obligations apply in parallel and must not be confused.

How high are the minimum quotas in 2030 — and 2040?

The quotas are staggered by packaging type. The lower stages apply from 1 January 2030 and rise sharply from 1 January 2040. What matters throughout is the PET or non-PET character of contact-sensitive packaging and the special category of single-use beverage bottles.

How do I calculate recycled content per manufacturing plant?

You do not calculate a value per individual item but a weighted annual average. The formula is: mass of post-consumer recyclate used divided by the total mass of plastic used — in each case for one manufacturing plant, one calendar year and one packaging type or format. You then compare the result against the minimum quota of the relevant category.

• Categorise the packaging: contact-sensitive PET / contact-sensitive non-PET / single-use beverage bottles / other.
• Per category and manufacturing plant, record the total plastic mass used over the year.
• Determine the share of evidenced post-consumer recyclate within it (secure proof of origin).
• Recycled content = recyclate mass ÷ total plastic mass × 100, as the annual average of the category.
• Check against the minimum quota (2030 or 2040) and document the gap per category.

Worked example — category “other plastic packaging”, target quota 35% from 2030: a manufacturing plant produces 200 tonnes of this packaging in one year. Batch A (120 t) contains 45% post-consumer recyclate, batch B (80 t) only 20%. Total recyclate mass = 120 t × 45% + 80 t × 20% = 54 t + 16 t = 70 t. Annual average = 70 t ÷ 200 t = 35%. The quota is therefore met exactly — even though batch B at 20% sits clearly below it on its own. That is precisely the point of the averaging principle: weaker batches may be offset by stronger ones.

Does every individual packaging item have to meet the quota?

No. The quota applies as an annual average per manufacturing plant and packaging type — not per individual item. A single bottle or tray therefore does not have to hit the percentage exactly. What matters is that the recycled content of the whole category, averaged over the calendar year, reaches or exceeds the minimum quota.

What counts as post-consumer recyclate?

Only post-consumer recyclate counts — that is, recycled material from plastic waste that arose at end users and was separately collected. Your own production waste that was never placed on the market (post-industrial or pre-consumer) does not count. This distinction is the most common source of error and decides how solid your evidence is.

Which packaging is exempt?

Art. 7 names several exemptions from the recycled-content obligation. For this packaging you do not have to meet the minimum quota — but you should document the exemption so that it can be evidenced in an inspection.

• Compostable plastic packaging.
• Packaging for dangerous goods.
• Contact-sensitive food packaging where recyclate would pose a health risk.
• Packaging units whose plastic share is below 5% of total weight.
• Further special cases in the pharmaceutical and medical field (see Art. 7 in detail).

How do I evidence recycled content in the declaration of conformity?

You document the recycled content achieved in the technical documentation under Annex VII and confirm conformity in the EU declaration of conformity (DoC) under Annex VIII. The evidence has to cover the categorisation, the calculated annual average per manufacturing plant and the proof of origin for the post-consumer recyclate. Once the implementing act lays down the binding methodology, align the calculation exactly with it.

Legal basis

PPWR Art. 7 (minimum recycled content)

PPWR date of application

12.08.2026 (Art. 71)

Quotas apply from

01.01.2030 · tightened from 01.01.2040

Calculation basis

Annual average per manufacturing plant & packaging type

Countable

post-consumer recyclate only

Evidence

Technical documentation (Annex VII) + DoC (Annex VIII)

For material purchasing and packaging development that means: categorise early, secure proof of origin for recyclate contractually, and work out the gap to 2030 today. That way you avoid short-notice supply bottlenecks for certified post-consumer recyclate.

• Regulation (EU) 2025/40 (PPWR), Art. 7 — minimum recycled content in plastic packaging.
• PPWR Art. 6 — recyclability (a separate topic, assessment grades A/B/C).
• PPWR Art. 71 — entry into force and date of application (12.08.2026).
• PPWR Annex VII — technical documentation; Annex VIII — EU declaration of conformity.
• Note: not legal advice. The binding methodology follows from the implementing act.