The PPWR asks EU plastic packaging for about twice today's recycled plastic by 2030, and non-PET food packs have the least supply

What Article 7 says, paragraph by paragraph

Article 7 runs to 15 paragraphs. Paragraphs 1 and 2 set the floors, paragraphs 4 and 5 take packs out, paragraphs 8 to 10 hand the counting rules to the Commission, and paragraphs 12 to 15 are review and adjustment clauses (Exhibit 2). The live Ledger piece on brand pledges against legal minimums covers how the EU bottle floor compares with company goals; this piece covers every category, the counting acts and supply.

The 2040 levels are set out in the European Parliament’s summary of its first-reading position of 24 April 2024, which the Parliament’s page for the adopted text notes corresponds to the final act, Regulation (EU) 2025/40. The summary lists the four 2040 categories as “(b) 25% for contact sensitive packaging made from plastic materials other than PET; (c) 65 % for single use plastic beverage bottles; (d) 65 % for plastic packaging other than referred to before.” Its point (a) is 50% for contact-sensitive PET packaging other than drinks bottles (Legislative Observatory, consulted 21 October 2026).

The 2030 tier is confirmed in the Commission’s own FAQ. Its August 2026 edition files a pallet wrapping film under Article 7(1)(d) at 35%, a beverage carton under Article 7(1)(b) at 10% and a single-use PET drinks bottle under Article 7(1)(c) at 30% (European Commission DG ENV, PPWR FAQ, KH-01-26-068-EN-N). The 30% for point (a), contact-sensitive packaging with PET as the major component, is reported in Food Packaging Forum’s summary of the Council-adopted text (9 January 2025) and appears in the German text of Article 7(1)(a) as reproduced by LX Gesetze; SPI has not yet confirmed the English wording of point (a) against the Official Journal text.

Three features of the article set it apart from the Single-Use Plastics Directive. The duty sits on the manufacturer, not the Member State: the Directive’s 30% for 2030 is a national average across all bottles (PR-EU-016), while Article 7 is met per plastic part, per plant and per year (PR-EU-004, recitals 40 and 41). It covers sales, grouped and transport packaging, which the FAQ confirms. And it counts only plastic recovered from post-consumer waste, so the pre-consumer scrap that some company figures still include does not qualify.

Who is outside the targets

Exemptions come in two kinds (Exhibit 3). Article 7(4) removes whole categories, and Article 7(5) removes packs or parts on a case-by-case basis. The Commission’s guidance says both 7(5) exemptions apply directly, without being granted, but must be documented in the technical file; for food-contact packs the file must name the polymer of each part of 5% or more and show that Annex I to Regulation (EU) 2022/1616 lists no suitable recycling technology for it (Commission Notice C/2026/3084, 10 June 2026).

The food-contact exemption is narrower than it reads. It is tied to the absence of an authorised technology for the polymer, so a pack loses it once a suitable technology is listed for that polymer. The FAQ also confirms that the obligation covers milk caps, which are food-contact parts but not infant food, and that stocks supplied to manufacturers before the start date get no run-out period.

The acts that decide how the share is counted

Three acts are due by 31 December 2026, and each changes which tonnes count (Exhibit 4). The Commission ran one call for evidence for the package, published on 14 August 2026 under the recycling-technology initiative and closed on 16 September 2026 with 82 responses; it covered the calculation rules, the technology criteria and imports, and the Commission said no impact assessment would be carried out (Have Your Say initiative 19033; Packaging Europe, 17 August 2026). On 21 October 2026 the portal listed the Article 7(8) implementing decision, the Article 7(10) implementing decision and the Article 7(9) delegated decision for adoption in the fourth quarter of 2026, each with its draft still marked as upcoming (initiatives 18753, 18752 and 19033).

The template for the calculation act already exists for bottles. Implementing Decision (EU) 2026/1425 of 30 June 2026 sets the method for the Directive’s bottle target: recycled content is the weight of recycled plastic over the weight of all plastic in bottles, including caps, lids and labels. Mechanically recycled content takes the share declared under Regulation (EU) 2022/1616; other routes use a mass balance with proportional allocation, in which fuels and losses count as zero, accounts run for up to three months, a negative balance is never allowed and attributed amounts cannot move between facilities. Operators using mass balance need annual third-party certification, every three years for small and medium-sized firms (EUR-Lex, published 3 July 2026). Plastic from OECD countries counts from 21 November 2027; plastic from other countries counts only where EU arrangements ensure equivalent standards.

Industry positions in the call for evidence pull in different directions. Cefic, the chemical industry association, asked for rapid regulatory certainty for chemical recycling, a fuel-use exclusion principle and equivalent calculation and traceability rules for imports (Cefic, 17 September 2026). IK, the German plastic packaging industry association, told Packaging Europe it expected the acts to delay the recycled-content requirements by at least several months (17 August 2026).

That delay is not a side issue, because the start date is tied to the calculation act. The FAQ states that the 2030 requirements apply from 1 January 2030 or three years after the Article 7(8) act enters into force, whichever is later, so any entry into force after 1 January 2027 moves the start (Exhibit 5). Implementing Decision (EU) 2026/1425 entered into force on the twentieth day after publication, which SPI uses as the gap in the scenarios.

Four exposure tiers, and the packs in each

The four categories carry different risks, so SPI sorts them on two tests: how far the floor rises from 2030 to 2040, and whether a food-grade or fit-for-purpose recyclate route exists today. Combined, they give four exposure tiers (Exhibit 6), each pointing to a different first move.

Tier 1, drinks bottles. The bottle floor is the one with a ready supply chain. Under Regulation (EU) 2022/1616, post-consumer mechanical PET recycling was one of two technologies authorised when the regulation took effect, the other being recycling from closed and controlled product loops (Finnish Food Authority, updated 21 January 2025). Article 50 then requires Member States to collect 90% of single-use plastic drinks bottles separately by 1 January 2029, mostly through deposit systems (PR-EU-007). The exposure is price and volume: SPI calculates that EU27+3 drinks bottles at their 2022 tonnage need about 933 kilotonnes of recycled PET at 30% and about 2,022 kilotonnes at 65%.

Tier 2, other PET food packs. Trays, punnets and jars already averaged 44% recycled content in 2022 (ICIS and Plastics Recyclers Europe, May 2024), so the 30% floor for 2030 is behind most of them. The 2040 step to 50% is the risk, because trays draw on the same food-grade flake as bottles, and bottles must reach 65%. In 2022 bottles took 48% of rPET output and sheet and trays 25%.

Tier 3, non-PET food packs. This is where the numbers are smallest and the problem is hardest. A yogurt pot in PP or a milk bottle in HDPE needs 10% from 2030, but its recycled plastic must meet food-contact law. Packs in this tier have four possible routes: chemically recycled plastic counted by mass balance, if the 7(8) and 7(9) acts accept it; the 7(5)(a) exemption, which lasts only while no suitable technology for the polymer is listed; a derogation after the 7(12) assessment, which explicitly covers point (b); or bio-based feedstock, if the Article 8 review leads to legislation.

Tier 4, everything else. Non-food packaging can use mechanically recycled plastic without food-contact approval, so access is easier. The problem is scale. On SPI’s base case this tier holds most of the tonnage, and the 2040 floor of 65% is close to double the 2030 floor of 35%. Plastics Recyclers Europe reports that installed recycling capacity reached 13.5 million tonnes in 2024 while about 300 kilotonnes closed, the largest reduction it has recorded (November 2025).

Food-grade recycled plastic: what the supply data show

Official and industry data describe a market that has grown, but slowly and unevenly by polymer (Exhibit 8). Plastics Europe reports that 2.5 million tonnes of post-consumer recycled plastic went into European packaging in 2024, 12.5% of 20.3 million tonnes converted, up 0.4 million tonnes; across all applications the figure was 7.4 million tonnes, or 14.1% (Plastics Europe, May 2026). Chemically recycled plastic was about 0.1 million tonnes, roughly 0.2% of conversion.

PET is the one polymer with a food-grade loop at scale. In 2022 about 1.9 million tonnes of rPET flake were produced in EU27+3, and bottles took 48% of rPET use, of which around 82% was for food contact (Exhibit 9). SPI calculation: 82% of the roughly 910 kilotonnes used in bottles is about 746 kilotonnes, which matches 24% of 3,110 kilotonnes of bottles, so the two figures in the report agree.

Views on whether PET supply will suffice differ. Petcore Europe’s president told Argus Media that Europe has enough rPET capacity for 2030 and that idle lines could restart, and that, on the association’s data, imported volumes are not needed to reach recycled-content levels (Argus Media, 23 January 2026). Plastics Recyclers Europe points to closures and to the pressure on food-contact rPET from strict EU safety and quality standards (November 2025).

For other polymers the official picture is thinner. SPI has not yet confirmed any EU-wide figure for food-grade recycled PP, HDPE or PE placed on the market, and Plastics Europe’s report gives no food-contact split. What is confirmed is the legal frame: from 10 July 2023 only recycled plastic from authorised technologies, or from the development of a novel technology, may stay on the market for food contact, and from 10 October 2024 collection and pre-processing must be certified by a third party (Finnish Food Authority, updated 21 January 2025). SPI has not yet confirmed whether Annex I to Regulation (EU) 2022/1616 has been extended beyond PET mechanical recycling and closed product loops since then.

Imports are being narrowed at the same time. Recital 17 of Implementing Decision (EU) 2026/1425 notes that exports of plastic waste to non-OECD countries are prohibited from 21 November 2026 until 21 May 2029, and Article 7(3) and 7(10) require recyclate made outside the EU to meet equivalent collection and recycling standards. Around 16% of the recycled plastics used in Europe depend on imports (Plastics Europe, May 2026).

Bio-based feedstock and the review clauses

Bio-based plastic does not count toward the Article 7 floors, which refer only to recycled content recovered from post-consumer plastic waste. Article 8 opens a possible route. By 12 February 2028 the Commission must review the technological development and environmental performance of bio-based plastic packaging (Green Forum PPWR timeline). In the text as reproduced by LX Gesetze, the review takes account of the sustainability criteria in Article 29 of Directive (EU) 2018/2001 and may lead to a proposal that sets sustainability requirements and targets for bio-based feedstock, and that allows the Article 7(1) and 7(2) targets to be met with bio-based feedstock where no suitable recycling technology is available for food-contact packaging under Regulation (EU) 2022/1616. SPI has not yet confirmed that wording against the Official Journal text.

The review clauses decide how firm the numbers are. Article 7(12) requires an assessment by 1 January 2028 of derogations for points (b) and (d) and of the exemption list, where suitable recycling technologies are not authorised or not available in practice, with safety requirements for contact-sensitive packs taken into account (Commission Notice C/2026/3084; Green Forum). Article 7(13) lets the Commission adjust the floors by delegated act where unavailable or excessively priced recycled plastic makes them excessively difficult to meet. Article 7(14) requires a report by 12 February 2032 on the 2030 floors and on whether the 2040 floors can be reached, which may come with a proposal to amend them, and Article 7(15) a review of recycled content in non-plastic packaging by the same date.

Recycled content also has a fee effect. Article 7(7) allows EPR fees to be modulated by recycled content. Verpact in the Netherlands already gives EUR 0.20 per kg off its plastic tariff for at least 10% post-consumer content in contact-sensitive packs or 20% in others, within a combined cap of EUR 0.60 per kg (Verpact Regeling Tariefdifferentiatie Plastic 2026, in the SPI fee-market notes), and the UK Plastic Packaging Tax uses a 30% threshold, covered in the plastic packaging taxes piece.

Scenarios: how much recycled plastic the floors call for

SPI estimated the post-consumer recycled plastic the floors would require across European packaging, using only published tonnages and the Article 7 percentages (Exhibits 11 and 12). The unknown input is how much of the non-PET tonnage is contact-sensitive, so SPI runs three cases: 70%, 50% and 30% of non-PET packaging in contact-sensitive uses.

The method is simple. PET tonnage comes from the 2022 split: 3,110 kilotonnes of drinks bottles at the bottle floor, and the other 1,885 kilotonnes, trays, other bottles, films and other uses, treated as contact-sensitive PET. Non-PET tonnage is 20.3 million tonnes of 2024 packaging conversion less about 5.0 million tonnes of PET, or about 15.3 million tonnes. Each tonne is multiplied by its floor.

SPI calculation: in the base case, drinks bottles need 3,110 x 30% = 933 kilotonnes, other PET 1,885 x 30% = 566 kilotonnes, contact-sensitive non-PET 7,650 x 10% = 765 kilotonnes and other non-PET 7,650 x 35% = 2,678 kilotonnes, a total of 4,941 kilotonnes. The gap to the 2.5 million tonnes used in 2024 is about 2.4 million tonnes, or 1.7 to 3.2 million tonnes across the three cases.

Drinks bottles are worth reading on their own. At 2022 tonnage the bottle category needs about 187 kilotonnes more recycled PET to move from the 2022 average of 24% to 30%, and about 1,276 kilotonnes more to reach 65%. If Member States collect 90% of 3,110 kilotonnes by 2029, about 2,799 kilotonnes of bottles would be collected each year; SPI has not modelled sorting and recycling yields, so the usable flake will be lower, and trays and fibres draw on the same pool.