Packaging regulation, push for recycled content

The Regulation of December 19, 2024, No. 2025/40 on packaging and packaging waste was published in the Official Journal on January 22, 2025, and comes into force on February 11, 2025 (with application starting from August 26, 2026).

Particularly, this regulation, also called PPWR (Packaging and packaging waste regulation) amends the 2019/1020/EU Regulation and repeals 2019/904/EU Directive.

The primary goal is to reduce packaging waste. To achieve this, the regulation mandates that by 2030, all packaging must be recyclable and contain a minimum percentage of recycled material.

Article 7 of the Regulation stipulates that by January 1, 2030, plastic packaging must contain a minimum amount of recycled material. Additionally, financial contributions for producers who use recycled materials in their packaging will be adjusted accordingly.

In particular, the plastic component of packaging placed on the market must contain the following minimum percentage of recycled content recovered from post-consumer plastic waste, depending on the packaging format:

  • 30% for contact-sensitive packaging made primarily of polyethylene terephthalate (PET);
  • 10% for contact-sensitive packaging made from plastics other than PET, excluding single-use plastic beverage bottles;
  • 30% for single-use plastic beverage bottles;
  • 35% for all other plastic packaging types.

These targets become more ambitious starting January 1, 2040. In fact, from this date onward, the plastic component of packaging must contain the following minimum percentage of recycled content recovered from post-consumer plastic waste, depending on the packaging format:

  • 50% for contact-sensitive plastic packaging, excluding single-use plastic beverage bottles;
  • 25% for contact-sensitive packaging made from plastics other than PET;
  • 65% for single-use plastic beverage bottles;
  • 65% for all other plastic packaging types.

These percentages must be documented in the technical specifications for the packaging (paragraph 5).

Moreover, by January 1, 2027, the financial contributions paid by producers to fulfill the extended producer responsibility (so-called “EPR”) obligations under Article 45 of the aforementioned Regulation will be adjusted based on the recyclability performance class of the packaging and also on the percentage of recycled content used in the packaging (Article 7, paragraph 7).

To achieve the objectives, by December 31, 2026, the Commission must adopt implementing acts establishing the methodology for calculating and verifying the percentage of recycled content recovered from post-consumer plastic waste.

Highly relevant for certification purposes is Article 12 of the Regulation, which governs the labelling of packaging. It states that when packaging containing recycled content, as per Article 7, is marked with a label providing information on the percentage of recycled content, such a label must comply with the specifications set out in the relevant implementing act and must be based on the aforementioned methodology.

The label may be accompanied by a QR code or another type of digital data support affixed to the packaging, containing information on the destination of each separate packaging component to facilitate sorting by consumers.

Of great importance is also Article 63, which regulates green public procurement in relation to the purchase of packaging.

To encourage the demand and supply of eco-friendly packaging, the Commission shall adopt, by February 12, 2030, implementing acts specifying the mandatory minimum requirements for public procurement in cases where packaging or packaged products represent more than 30% of the estimated contract value or the value of products used by the services covered by the contract.

The mandatory minimum requirements for green public procurement are based on the provisions set out in Articles 5 to 11, including the mandatory recycled content requirements outlined in Article 7 of the relevant Regulation.

Therefore, certification of recycled content will play an increasingly central role, particularly for plastic packaging but also for other materials.

For any information about the ReMade certification info@remade.it