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

> Article 7 of Regulation (EU) 2025/40 sets four recycled-content floors for plastic packaging, 30%, 10%, 30% and 35% from 2030 and 50%, 25%, 65% and 65% from 2040, and on SPI's estimate the 2030 tier alone needs about 4.2 to 5.7 million tonnes of post-consumer recycled plastic a year, against 2.5 million tonnes used in European packaging in 2024.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/ppwr-recycled-content-targets-2030-2040/

**Article 7 of Regulation (EU) 2025/40 sets four recycled-content floors for plastic packaging, 30%, 10%, 30% and 35% from 2030 and 50%, 25%, 65% and 65% from 2040, and on SPI's estimate the 2030 tier alone needs about 4.2 to 5.7 million tonnes of post-consumer recycled plastic a year, against 2.5 million tonnes used in European packaging in 2024.**

The four floors land very differently. Single-use PET drinks bottles have an authorised food-grade route and a deposit system behind them, while food-contact packs in PP, HDPE, PE and PS face the lowest numbers but have no mechanical food-grade route of their own, and the rules that decide what counts are still being written.

## Executive summary

The Packaging and Packaging Waste Regulation (PPWR) turns recycled content from a brand pledge into a market-access condition for every plastic part of every pack placed on the EU market. Article 7 sets four categories. From 1 January 2030, or three years after the Commission's calculation act enters into force if that is later, contact-sensitive PET packaging needs 30% post-consumer recycled plastic, other contact-sensitive plastics 10%, single-use plastic drinks bottles 30% and everything else 35%. From 2040 the levels become 50%, 25%, 65% and 65%. Each share is met per plastic part, as an average per manufacturing plant and per year, and documented in the technical file (Commission PPWR FAQ, August 2026).

The volume is the first issue. On SPI's estimate, the 2030 tier needs about 4.2 to 5.7 million tonnes of post-consumer recycled plastic a year across European packaging, against 2.5 million tonnes used in packaging in 2024 (Plastics Europe, May 2026). At 2040 levels the need, at 8.6 to 11.1 million tonnes, is above the 7.4 million tonnes Europe used in all applications in 2024.

The second issue is food-grade supply, and it splits the market. PET bottles have an authorised mechanical route and deposit systems that must collect 90% of bottles by 2029; members of UNESDA, the soft drinks association, reached 60.3% recycled PET in 2025. Food-contact packs in other polymers do not have a comparable route, so their 10% floor depends on chemical recycling, mass-balance counting and the exemptions in Article 7(5) and 7(12).

The third issue is timing. The Article 7(8) act on calculating and checking recycled content, the Article 7(9) criteria for recycling technologies and the Article 7(10) rules for imported recyclate are all due by 31 December 2026. On 21 October 2026 the Commission's portal listed each one for adoption in the fourth quarter of 2026, with no draft yet published.

For leaders, three moves matter now: sort every plastic part into its Article 7 category and plant, contract food-grade supply by plant rather than group-wide, and build a 2030 plan that works under both a fuel-use-excluded mass balance and a mechanical-only reading until the acts are adopted.

## Key findings

1. Article 7 sets 30%, 10%, 30% and 35% for its four plastic categories in the 2030 tier and 50%, 25%, 65% and 65% in the 2040 tier, each per plastic part and averaged per plant and year (Commission PPWR FAQ, August 2026; Legislative Observatory, 24 April 2024).
2. The 2030 tier starts on 1 January 2030 or three years after the Article 7(8) act enters into force, whichever is later; an act in force on 1 March 2027 would move the start to 1 March 2030 (Commission PPWR FAQ; SPI calculation).
3. **SPI calculation:**  the 2030 tier needs about 4.2 to 5.7 million tonnes of post-consumer recycled plastic a year in EU27+3 packaging, 1.7 to 2.3 times the 2.5 million tonnes used in 2024, before exemptions.
4. European plastics recycling capacity reached 13.5 million tonnes in 2024, but about 300 kilotonnes closed during the year, and Plastics Recyclers Europe says growth falls short of the 6% a year the PPWR targets require (November 2025).
5. In 2022 the average PET drinks bottle in EU27+3 held 24% recycled content and the average PET tray 44%, while UNESDA members reached 60.3% recycled PET in 2025 (ICIS and Plastics Recyclers Europe, May 2024; UNESDA, July 2026).
6. **SPI analysis:**  contact-sensitive packaging in plastics other than PET is the most exposed category: its floor is the lowest, but no mechanical food-grade technology other than PET recycling and closed product loops was authorised when Regulation (EU) 2022/1616 took effect, so supply depends on acts not yet adopted.
7. Bio-based plastic does not count toward Article 7 today; Article 8 asks the Commission to review bio-based plastic packaging by 12 February 2028, and the review may lead to a proposal letting bio-based feedstock stand in where no suitable food-contact recycling technology exists.

## 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](https://www.strategicpackaginginsights.com/insights/recycled-content-pledge-gap/) 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](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1784253) 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)), while Article 7 is met per plastic part, per plant and per year ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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.

SPI analysis

The per-part rule changes the unit of work. A bottle body at 65% recycled PET can still fail if its cap or label weighs 5% or more of the unit and contains no recycled plastic, because each such part carries its own floor. Only parts under 5% are exempt under Article 7(5)(b), and the FAQ adds that adhesives, inks and paints are not plastic for this purpose.

## 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.

SPI analysis

The bottle decision is the clearest signal of how the PPWR act may treat chemically recycled plastic, but it is not the PPWR act. Article 7(8) also asks the Commission to assess available technologies, including output quality, energy demand and greenhouse gas emissions, and the 7(9) criteria could exclude some processes. A 2030 plan that relies on mass-balance volumes should carry a fallback until both acts are adopted.

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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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).

SPI analysis

The risk ranking runs against the size of the numbers. The 10% floor for tier 3 is the lowest in the article, but it is the one a brand may be unable to meet at any price in 2030, because the qualifying supply depends on rules not yet adopted. The 35% and 65% floors in tier 4 can be met, and the risk there is cost and capacity.

## 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).

In practice: Danone.

Danone's 2025 Universal Registration Document, published on 4 March 2026, says evian and Volvic bottles used 100% rPET in 2025, Volvic in Europe excluding labels and caps (SPI Packaging Buyers Database, Danone profile). The bodies are already above the 2040 drinks bottle floor of 65%. Because Article 7 applies per plastic part, any cap or label that is 5% or more of the unit's weight needs its own 30% from 2030; SPI has not seen Danone's cap weights or cap recycled content.

In practice: Henkel.

Henkel's Sustainable Impact Report 2025, published on 14 April 2026, says European liquid detergent bottle bodies up to 3 litres for Persil, Spee, X-TRA and Le Chat contain 65% post-consumer recycled plastic, adding 541 tonnes of recycled plastic in 2025. Group-wide, recycled materials in consumer goods packaging stood at 28% and the new 2030 goal is at least 35% (SPI Packaging Buyers Database, Henkel profile). Detergent bottles fall in the other-plastics category, so the bodies already meet the 2040 floor of 65%, while the group average sits below the 2030 floor of 35% that applies to every other part in that category.

In practice: Mondelez International.

Mondelez UK said on 16 May 2025 that Cadbury sharing bars made and sold in the UK and Ireland use wrappers with 80% certified recycled plastic, from advanced recycling under mass balance with ISCC certification, about 600 tonnes of recycled plastic a year across about 300 million bars (SPI Packaging Buyers Database, Mondelez profile). A chocolate wrapper is a contact-sensitive non-PET pack, so in Ireland the PPWR floor would be 10% from 2030 and 25% from 2040. Whether mass-balance content counts toward those floors depends on the Article 7(8) and 7(9) acts.

## 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.

SPI analysis

The bio-based route, if it comes, is aimed at tier 3. It would need a review in 2028, a legislative proposal and its adoption, so it is unlikely to help a pack placed on the market in early 2030. It is a reason to keep bio-based options in development, not a 2030 compliance plan.

In practice: L'Oréal.

L'Oréal's 2025 Universal Registration Document reports 50% recycled or biobased plastics in its packaging in 2025, and its realigned goal is to source 50% of all packaging materials from recycled or biobased sources by 2030 (SPI Packaging Buyers Database, L'Oréal profile). Under Article 7 only the post-consumer recycled part of that figure counts, and only for EU-placed packs, per part and per plant. SPI has not yet confirmed which L'Oréal packs fall in the contact-sensitive categories, which depends on the Article 3 definitions.

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.

SPI analysis

The 2040 numbers are a planning case, not a fixed figure. The 7(12) assessment covers only points (b) and (d), so drinks bottles and contact-sensitive PET have no derogation route before 2032. Brands should treat the PET floors as firm and the non-PET food floor as the one most likely to move.

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](https://www.strategicpackaginginsights.com/insights/plastic-packaging-taxes-2026/).

## 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.

SPI analysis

The scenarios point to a bigger issue than any single pack. Even with a 15% cut in tonnage, the 2040 floors ask packaging alone to absorb about as much post-consumer recycled plastic as every European sector used in 2024. Either capacity grows faster than the stalled 2024 rate, or the 2032 review moves the 2040 numbers. Brands should plan for the first and prepare for the second.

## Industry reaction

> "Europe’s plastic recycling sector faces mounting pressures. The new rules on chemical recycling are part of the answer to that challenge. With clearer rules in place for chemically recycled content, we give industry the certainty it needs to invest and innovate."

***European Commission** , Jessika Roswall, Commissioner for Environment, Water Resilience and a Competitive Circular Economy, [press release IP/26/1467](https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1467), 30 June 2026*

The release accompanied the adoption of the bottle method in Decision (EU) 2026/1425, which Member States' representatives backed in February 2026.

> "We call for the smooth and timely adoption of the necessary secondary legislation"

***UNESDA Soft Drinks Europe** , trade association, [progress report on EU Agri-Food Code commitments](https://transition-pathways.europa.eu/system/files/media/document/2026-07/UNESDA%20Progress%20Report%20-%20EU%20Agri-Food%20Code%20Commitments%20-%20July%202026_FINAL_0.pdf), July 2026*

UNESDA ties that request to clarity on how PPWR recycled-content targets will be calculated, and in the same report cites high rPET prices and asks for fair access to food-grade feedstock.

> "The strain of these market pressures is especially evident for food-contact rPET, which is subject to strict safety and quality standards required by EU legislation."

***Plastics Recyclers Europe** , recyclers' association, [Plastics Recycling Industry Figures 2024](https://plasticsrecyclers.eu/wp-content/uploads/2025/11/Statistics_2025_Final.pdf), November 2025*

The same report says installed capacity is growing more slowly than the 6% a year the PPWR targets would require.

## What leaders should do now

1. **Packaging and compliance leads, by 31 March 2027:**  sort every plastic part above 5% of unit weight into its Article 7 category and its manufacturing plant, and flag which parts rely on the 7(4) or 7(5) exemptions, with the evidence each needs in the technical file.
2. **Procurement, before 2027 supply contracts are signed:**  contract food-grade rPET and recycled polyolefins by plant, not group-wide, because the share is averaged per plant and year; ask suppliers for 2022/1616 process registration and third-party certificates.
3. **Regulatory affairs, within a month of each act's adoption:**  read the Article 7(8), 7(9) and 7(10) acts when they are adopted (planned for the fourth quarter of 2026), confirm the start date they set and check with counsel how mass-balance and imported recyclate will count.
4. **Category managers for non-PET food packs, by mid-2027:**  build two 2030 plans for each tier 3 format, one with chemically recycled content under mass balance and one without, and test whether the 7(5)(a) exemption applies today.
5. **Finance teams, in the 2027 budget:**  price recycled resin at 2030 floors for tiers 1 and 4 and include any EPR modulation that rewards recycled content, such as Verpact's discount.
6. **Innovation teams, before the 12 February 2028 review:**  keep bio-based and closed-loop options in development for tier 3 packs, as a fallback rather than the base plan.
7. **Boards, at the next strategy review:**  ask for the 2040 resin need by category against today's contracted supply, because the 2040 floors are close to all recycled plastic Europe used in 2024.

## Questions for your board

- Which of our EU packs fall in each Article 7 category, and in which plants are they made?
- How many plastic parts above 5% of unit weight have no recycled content today, including caps and labels?
- What share of our planned 2030 recycled content comes from mass balance, and what happens if the 7(8) or 7(9) act excludes it?
- Do we have contracted food-grade supply for non-PET food packs, or are we relying on an exemption?
- How would a later start date, after the calculation act, change our 2030 investment timing?
- What is our 2040 recycled resin need by category, and who will supply it?

## What to watch

- **21 Nov 2026:**  EU exports of plastic waste to non-OECD countries become prohibited until 21 May 2029, keeping more collected plastic inside the EU (Implementing Decision (EU) 2026/1425, recital 17).
- **31 Dec 2026:**  the Article 7(8) calculation act, the 7(9) technology criteria and the 7(10) equivalence act are due; the Commission plans adoption in the fourth quarter of 2026 ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **21 Nov 2027:**  recycled plastic from OECD countries starts to count toward the Single-Use Plastics Directive bottle target ([PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).
- **1 Jan 2028:**  the Commission's Article 7(12) assessment of derogations for points (b) and (d) is due.
- **12 Feb 2028:**  the Article 8 review of bio-based plastic packaging is due.
- **1 Jan 2029:**  Member States must collect 90% of single-use plastic drinks bottles separately ([PR-EU-007](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-007/)).
- **1 Jan 2030:**  earliest start of the 2030 tier, later if the 7(8) act enters into force after 1 January 2027 ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **12 Feb 2032:**  the Article 7(14) report on the 2030 floors and the 2040 levels is due ([PR-EU-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-005/)).

## Methodology

- **Data used:**  the SPI Regulation Tracker and rule notes for [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/), [PR-EU-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-005/), [PR-EU-007](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-007/), [PR-EU-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-011/) and [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/); the SPI Packaging Buyers Database profiles for Danone, Henkel, Mondelez and L'Oréal; official EU sources (Commission FAQ, Commission Notice C/2026/3084, Implementing Decision (EU) 2026/1425, Legislative Observatory, Green Forum and Have Your Say pages) and industry data from Plastics Europe, Plastics Recyclers Europe, ICIS and UNESDA, consulted 21 October 2026.
- **Article 7 text:**  the 2030 points (b), (c) and (d) and the start rule come from the Commission FAQ; the 2040 levels from the Legislative Observatory summary of Parliament's position; point (a) for 2030 and the paragraph map in Exhibit 2 also draw on the German text of Articles 7 and 8 as reproduced by LX Gesetze. SPI has not yet confirmed the English wording of Article 7 against the Official Journal text.
- **Scenarios:**  EU27+3 tonnage (Plastics Europe 2024; ICIS and Plastics Recyclers Europe 2022 PET split) multiplied by the Article 7 floors; non-PET tonnage split by SPI's 70%, 50% and 30% contact-sensitive assumptions; exemptions not deducted; the Article 43 per capita cut applied as a flat tonnage cut in Exhibit 12. Tonnes only, no currencies.
- **Tiers:**  an SPI planning device built from the floors and the authorised food-contact technologies, not a legal classification.
- **Cut-off:**  21 October 2026.
- **Limitations:**  data years and geographic scopes differ; company figures are self-reported and cover named packs; the counting acts are not adopted. This is business analysis, not legal advice; check with counsel.

## Sources

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