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Packaging rule · European Union · Recycled content

SUP Directive: recycled content in plastic beverage bottles

Recycled content rule covering plastic in the European Union, set by European Parliament and Council of the EU. Applies since 1 January 2025.

By the SPI teamRule ID PR-EU-016Source consulted 14 October 2026Verified 14 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
European Union
Authority
European Parliament and Council of the EU
Rule type
Recycled content
Materials
Plastic
Status
In force Enacted
Rate or target
25%25% for PET bottles from 2025; 30% for all beverage bottles from 2030 (Member State average). Covers bottles up to three litres, not glass or metal bottles with plastic caps or lids, nor bottles for special medical foods.
Adopted or published
5 June 2019
Applies from
1 January 2025
From the source

“from 2030, beverage bottles listed in Part F of the Annex contain at least 30 % recycled plastic, calculated as an average”

Official source EUR-Lex: Directive (EU) 2019/904Official (government or regulator) · consulted 14 October 2026

Deadlines

Key dates

  1. Adopted or published 7 years ago

  2. Applies from 1 year and 9 months ago

  3. Source consulted by the SPI team 1 day ago

  4. Re-checked by a second SPI team member 1 day ago

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

PET beverage bottles must contain at least 25% recycled plastic from 2025, and all single-use plastic beverage bottles at least 30% from 2030, calculated as a national average.

In practice

Directive (EU) 2019/904 requires Member States to ensure that PET beverage bottles contain at least 25% recycled plastic from 2025, and all beverage bottles in Part F of the Annex at least 30% from 2030, in each case as an average across bottles placed on the market in that Member State (Article 6(5)). Bottle makers, recyclers and beverage brand owners are affected through the national measures used to deliver the average. The 30% step overlaps with the PPWR 2030 recycled-content target for single-use plastic beverage bottles.

Where the record is unclear

  • Article 6(5) required implementing rules on calculation and verification by 1 January 2022; their adoption was not confirmed on the pages consulted.
  • How the directive's national-average target and the PPWR 2030 bottle target will interact was not confirmed.
  • Whether Member States place the obligation on individual producers was not checked.

Where it sits in the tracker

  • One of 18 packaging rules we track in the European Union, of which 3 are recycled content rules.
  • In all, 6 recycled content rules are tracked across 3 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

Article 6(5) of Directive (EU) 2019/904 sets two recycled plastic floors for the beverage bottles in Part F of the Annex: from 2025, PET bottles must contain at least 25% recycled plastic, and from 2030 all Part F bottles at least 30%, each calculated as an average across all such bottles placed on the market in the Member State1. Part F covers bottles of up to three litres with their caps and lids, and leaves out glass or metal bottles with plastic caps and bottles holding special medical liquid foods1. The obligation sits with the Member State, which chooses how to reach the average.

Recital 17 gives the reason: a mandatory minimum recycled content for bottles should pull recycled plastic into the market and support demand for collected material1. Member States report the result every year under Article 13(1)(e), electronically within 18 months of the end of each reporting year, with 2023 as the first reporting year for this item1.

How the percentage is counted changed in 2026. Implementing Decision (EU) 2026/1425 of 30 June 2026 repealed the 2023 method in Decision (EU) 2023/2683, kept the weight formula, and added chemical recycling with mass balance rules, recycler certificates and conditions for recycled plastic from outside the EU23.

Duties

Who must do what

Member States

  • Ensure the national average reaches 25% recycled plastic in PET beverage bottles from 2025 and 30% in all Part F bottles from 2030 (Article 6(5))1.
  • Collect weight data from economic operators, calculate the share with the Annex I formula of Decision (EU) 2026/1425 and report it with a quality check report (Articles 2, 3, 4 and 9)2.
  • Check reported data on a risk basis and recognise recycler certificates issued in other Member States (Article 8)2.

Food business operators placing bottles on the market

  • Supply the plastic and recycled plastic weights of each bottle part, body, cap or lid, label and sleeve, as the Member State requests2.
  • Hold the batch declarations passed down the chain and keep records for at least five years (Article 8(3))2.

Preform and bottle converters

  • Declare the recycled share of each part from the declarations received for each batch, so the recycled weight can be summed per part2.
  • Pass certificates downstream to the next operator (Article 8(10))2.

Recyclers and mass balance operators

  • Where mass balance is used, keep accounts per facility for periods of up to three months, never run a negative balance and never move attributed amounts between facilities or companies (Article 7(7) and (8))2.
  • Obtain annual facility verification, or every three years for SMEs, with certificates on the Annex IV model (Article 8(5) and (9))2.
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. Is the bottle single-use, made of plastic and three litres or smaller?

    If yes
    It is a Part F bottle and counts toward the national average.
    If no
    Bottles over three litres, and other formats such as cartons, fall outside Part F.

  2. Is PET the major component of the bottle?

    If yes
    It counts in both the 25% PET figure from 2025 and the 30% all-bottle figure from 2030.
    If no
    It enters only the 30% figure from 2030.

  3. Is the recycled plastic made from post-consumer waste?

    If yes
    It can count as recycled plastic.
    If no
    Pre-consumer waste and production scrap are excluded (recital 15).

  4. Was the recycling, including sorting, carried out in the EU?

    If yes
    The material can count now.
    If no
    Recycled plastic from countries covered by the OECD decision counts only from 21 November 2027, and from other third countries only under an EU agreement or arrangement.

  5. Is the part non-plastic, such as a paper label?

    If yes
    It is left out of both plastic weight and recycled weight.
    If no
    Caps, lids, labels and sleeves made of plastic all count in the bottle's weight.
Checklist

Compliance checklist

  1. Find out how your Member State reaches the average

    By Now

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. The Directive sets a national average, so check whether each market imposes a per-producer quota, a reporting duty or a fiscal incentive.

    Evidence to keep Country table of transposing measures and any producer-level obligation.

  2. Collect part-level weights

    By Now

    Record plastic weight and recycled share for body, cap, label and sleeve of every bottle SKU, since Decision (EU) 2026/1425 sums all plastic parts.

    Evidence to keep Part weight sheet per SKU tied to supplier batch declarations.

  3. Check the origin of recycled PET

    By 2027-11-21

    Material recycled outside the EU in OECD-decision countries counts only from this date; before it, only EU-recycled post-consumer plastic can be credited.

    Evidence to keep Recycler location and sorting site for each batch of recycled resin.

  4. Decide on chemically recycled feedstock

    By Now

    Chemical recycling now counts, but mass balance accounting brings facility accounts, three-month periods and annual certificates; weigh that against mechanical recycled PET.

    Evidence to keep Certificates on the Annex IV model and mass balance statements per period.

  5. Keep the documentation trail

    By Now

    Keep every batch declaration and certificate for at least five years so that a Member State's risk-based check can trace each figure.

    Evidence to keep Five-year archive of declarations and certificates per supplier.

  6. Extend recycled content to non-PET bottles

    By 2030-01-01

    The 30% average covers every Part F bottle from 2030, including HDPE and other polymers, and runs alongside the PPWR 2030 target.

    Evidence to keep Supply plan for recycled resin by polymer for 2030.

Enforcement

Enforcement and penalties

Who enforces
Member States, through the bodies their transposing laws name; Member States also verify reported data under Article 8 of Decision (EU) 2026/1425.
Powers
Authorities can audit batch declarations, certificates and mass balance accounts and run on-site verification of inputs, outputs and allocations (Article 8(6))2.
Enforcement so far
Member State results for 2025 must be reported within 18 months, so by mid-2027; no published EU-wide comparison was found in the texts opened.

Penalties

BreachPenaltyLegal basis
Breach of national rules that implement the recycled content requirementNo figure in the Directive; national law fixes the sanctionDirective (EU) 2019/904, Article 141

The Directive's target is a national average, so a Member State that misses it faces Commission scrutiny rather than any single company. Businesses face sanctions only where national law turns the average into a producer duty or a reporting obligation.

Connections

How it fits with other rules

  • PPWR: 2030 minimum recycled content in plastic packaging PR-EU-004
    The PPWR sets 30% recycled content for single-use plastic beverage bottles from 2030, the same figure as this Directive's second step. Its own calculation method under PPWR Article 7(8) was due by 31 December 2026, and recital 32 of Decision (EU) 2026/1425 signals possible alignment of the two methods.
  • PPWR: 2040 minimum recycled content in plastic packaging PR-EU-005
    The PPWR raises the bottle figure to 65% by 20404. Investment in recycled PET supply for the 2025 and 2030 averages is the base for that later step.
  • PPWR: 90% separate collection of beverage containers (deposit systems) PR-EU-007
    Deposit systems required by the PPWR from 2029 feed cleaner post-consumer PET into recycling. Because only post-consumer plastic counts under Decision (EU) 2026/1425, collection quality limits how fast the averages can rise.
  • UK Plastic Packaging Tax PR-GB-001
    The UK Plastic Packaging Tax also uses a 30% recycled content figure, but as a tax threshold rather than a national average. A bottle supplied to both markets is measured twice under different rules.
  • SUP Directive: tethered caps on plastic beverage containers PR-EU-015
    Tethered caps on the same bottles count in the plastic weight under the 2026 method, so a heavier virgin cap lowers the recycled share unless the cap also contains recycled plastic.
Timeline

History of the rule

  1. Directive (EU) 2019/904 published with the 25% and 30% bottle targets.

  2. Deadline for implementing rules on calculating and checking recycled content (Article 6(5)).

  3. First reporting year for recycled content in Part F bottles (Article 13).

  4. Implementing Decision (EU) 2023/2683 sets the first method, counting mechanical recycling only.

  5. 25% average for PET bottles applies.

  6. Implementing Decision (EU) 2026/1425 adopted; published 3 July 2026, repealing the 2023 method.

  7. Today

  8. Recycled plastic from OECD-decision countries starts to count.

  9. 30% average for all Part F bottles applies.

  10. Commission review of Decision (EU) 2026/1425 due (Article 10).

Questions

Questions

Does every PET bottle need 25% recycled content?

No. Article 6(5) of Directive (EU) 2019/904 sets 25% from 2025 as an average across all PET beverage bottles placed on the market in a Member State. Individual bottles can be above or below it unless national law sets a per-producer rule.

Does chemically recycled PET count toward the EU bottle target?

Yes, since Implementing Decision (EU) 2026/1425 of 30 June 2026. The earlier 2023 method counted only mechanical recycling, while the new one counts other methods under mass balance rules with yearly certificates.

Can imported recycled PET be counted?

Recycling, including sorting, must take place in the EU for now. Recycled plastic from OECD-decision countries counts from 21 November 2027, and from other countries only where the EU has an agreement or arrangement.

Are caps and labels part of the recycled content calculation?

Yes. The 2026 method counts the body, cap or lid, and plastic labels and sleeves in both plastic weight and recycled weight. Non-plastic parts such as paper labels are left out.

When will results for the 25% target be published?

Article 13 gives Member States 18 months after each reporting year to report. Results for 2025, the first year of the 25% target, are therefore due by mid-2027.

Glossary

Definitions

recycled plastic
Plastic that was post-consumer plastic waste before recycling, with the recycling, including sorting, carried out in the EU; pre-consumer waste is excluded (Decision (EU) 2026/1425, Article 1(1)).2
eligible material
Post-consumer waste and material derived from it, which covers outputs of chemical recycling where the composition changes (Decision (EU) 2026/1425, Article 1(7)).2
PET bottle
A beverage bottle whose major component is PET, which counts toward the 25% figure (Decision (EU) 2023/2683, Article 1).3
Sources

Sources for this analysis

  1. EUR-Lex: Directive (EU) 2019/904, OJ L 155, 12.6.2019 (Articles 6(5), 13 and 14; Annex Part F; recital 17) Official · Consulted 14 October 2026
  2. EUR-Lex: Commission Implementing Decision (EU) 2026/1425 on calculating, checking and reporting recycled plastic content in single-use plastic beverage bottles Official · Consulted 14 October 2026
  3. EUR-Lex: Commission Implementing Decision (EU) 2023/2683 of 30 November 2023 (repealed) Official · Consulted 14 October 2026
  4. European Parliament Legislative Observatory: Regulation (EU) 2025/40 summary Official · Consulted 14 October 2026
  5. European Commission Green Forum: PPWR implementation timeline Official · Consulted 14 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 14 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Changed: rate note

  3. Verified by a second SPI team member

  4. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-EU-016 and the source. Corrections are logged in this history.

Other jurisdictions

Recycled content rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
California minimum recycled content for plastic beverage containers (AB 793)PR-US-009California, United StatesRecycled contentPlasticIn force1 January 2022
New Jersey Recycled Content Law (P.L.2021, c.391)PR-US-010New Jersey, United StatesRecycled contentPlastic, Paper and board, GlassIn force18 January 2024
Recycled content in plastic packaging (PWM Rules Schedule II, revised 2026)PR-IN-002IndiaRecycled contentPlasticIn force31 March 2026

Every recycled content rule in the tracker

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