# Legal recycled-content minimums are climbing faster than most brand pledges

> Where a brand target and a law measure the same thing, the legal minimums for 2030 often sit at or above the brand's own goal, and they rise by 1 to 10 percentage points a year against 0.3 to 2.2 points for most corporate goals.

Publisher: Strategic Packaging Insights  
Published: 2026-10-14  
Last updated: 2026-10-14  
Page: https://www.strategicpackaginginsights.com/insights/recycled-content-pledge-gap/

**Where a brand target and a law measure the same thing, the legal minimums for 2030 often sit at or above the brand's own goal, and they rise by 1 to 10 percentage points a year against 0.3 to 2.2 points for most corporate goals.**

Strategic Packaging Insights (SPI) set the 29 recycled-content targets in its Buyers Database against the 6 recycled-content rules in its Regulation Tracker and two related laws. Most pairs cannot be compared, because a global company average and a market rule measure different things, so this analysis compares only like with like, sorts the pledges into four types and prices what a shortfall costs where a law sets a figure.

## Executive summary

Recycled content has moved from a voluntary pledge to a legal floor in five of the markets SPI tracks. California has required 25% postconsumer plastic in redemption-value beverage containers since 1 January 2025 and requires 50% from 1 January 2030. India's Category I rigid plastic packaging needs 30% recycled plastic in 2025-26 and 60% from 2028-29. The EU sets 30% for single-use plastic beverage bottles from 2030 under both the Single-Use Plastics Directive and the Packaging and Packaging Waste Regulation (PPWR). New Jersey and Colombia have their own ladders, and the UK taxes any plastic component below 30%.

The brand side looks different. Of the 23 targets in Exhibit 1 with a goal and a reported figure, 4 sit at or above their goal. Most of the others aim lower and move slower than the laws: SPI calculates that the legal ladders require 1 to 10 points of increase a year to 2030, while most open brand goals need 0.26 to 2.2 points.

The deeper problem is measurement. 14 of those 23 targets are company-wide plastic averages, and 5 more mix materials. Laws measure per market, per category and, in the EU, per plastic part and per manufacturing plant each year. A global average cannot show compliance in any one market, and SPI found only 4 targets in Exhibit 1 that line up closely enough with a law to compare as numbers.

Where they do line up, the results split. Diageo's PET bottles, at 44% recycled content in fiscal 2026, clear the EU's 30% bottle floor for 2030. Dabur India's Category I figure of 2% for FY 2025-26 sits 28 points below India's 30% level for the same year.

The cost of a gap is now calculable in two markets. In California a shortfall costs USD 0.20 per pound, so each point a manufacturer misses on 10 million pounds of containers costs USD 20,000. In the UK, a component that slips below 30% recycled plastic pays GBP 228.82 per tonne on its full weight, and pre-consumer plastic stops counting from 1 April 2027.

For leaders, the action is to rebuild recycled-content reporting around the laws' own units, to contract resin by market and plant rather than by group, and to treat the steepest ladders (California containers, Colombian PET, Indian Category I) as the real demand signal for postconsumer resin.

## Key findings

1. The SPI Buyers Database holds 29 recycled-content targets; 14 fell due by 2025, of which 4 are reported met, 5 missed and 5 either not reported or behind (SPI Buyers Database, 14 October 2026 snapshot).
2. From 1 January 2030, California's plastic beverage containers carrying the California Redemption Value need a 50% annual average of postconsumer recycled plastic, up from 25% since 2025, with shortfalls charged at USD 0.20 per pound ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/), CalRecycle, consulted 14 October 2026).
3. The PPWR sets 30% recycled content for single-use plastic beverage bottles from 2030 and up to 65% by 2040, met for each plastic part as an average per manufacturing plant and per year ([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/), recitals 40 and 41).
4. India's Category I rigid plastic packaging must contain 30% recycled plastic in 2025-26, rising to 50% in 2027-28 and 60% from 2028-29; the first returns fell due on 30 June 2026 ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/), G.S.R. 237(E)).
5. SPI analysis: 14 of the 23 targets in Exhibit 1 are company-wide plastic averages and 5 mix materials, so only 4 can be set against a legal minimum as numbers.
6. SPI analysis: the legal ladders in the tracker require 1 to 10 points of increase a year to 2030; most brand goals with a later deadline require 0.26 to 2.2 points a year, Marico's being the exception at about 7.
7. SPI calculation: a beverage manufacturer with 10 million pounds of CRV plastic containers that holds 25% postconsumer content into 2030 would face USD 500,000 a year in California shortfall penalties at the published rate.

## The legal minimums in the tracker

6 rules in the SPI Regulation Tracker carry the recycled-content type: [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/) and [PR-EU-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-005/) under the PPWR, [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/) under the Single-Use Plastics Directive, [PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/) in California, [PR-US-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-010/) in New Jersey and [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/) in India. Two further rules set recycled-content levels or thresholds inside a different type: Colombia's Law 2232 of 2022 ([PR-CO-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/colombia/pr-co-002/), a ban rule whose Article 17 sets levels for PET bottles) and the UK Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/), a tax that applies below 30% recycled plastic).

Exhibit 2 shows the levels; the definitions behind them decide every comparison that follows.

**EU Single-Use Plastics Directive ([PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).**  Member States must ensure that PET beverage bottles up to three litres 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 that Member State's market (Article 6(5), Directive (EU) 2019/904). Glass or metal bottles with plastic caps are outside Part F. The counting method changed this year: Implementing Decision (EU) 2026/1425 of 30 June 2026 repealed the 2023 method, kept the weight formula and added chemically recycled plastic under mass balance rules, recycler certificates and conditions for recycled plastic made outside the EU, with plastic from OECD-decision countries counting from 21 November 2027 (EUR-Lex, consulted 14 October 2026).

**EU PPWR ([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/)).**  Plastic packaging must contain minimum shares of post-consumer recycled plastic from 2030, including 30% for single-use plastic beverage bottles, rising to up to 65% by 2040 (Legislative Observatory summary). Recitals 40 and 41 require the minimum to be met for each plastic part, calculated as an average per manufacturing plant and per year. The Commission's guidance, Notice C/2026/3084 of 10 June 2026, confirms two exemptions that manufacturers apply themselves and document in the technical file: plastic parts under 5% of the unit's weight (Article 7(5)(b)) and qualifying food-contact packaging where no suitable authorised recycling technology exists (Article 7(5)(a)). The EUR-Lex summary also lists exceptions for pharmaceutical packaging, medical devices, infant food, dangerous goods and compostable plastics. The percentages for other plastic categories sit in Article 7(1); SPI has not yet confirmed them against the official text, so they are not compared here.

**California ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)).**  Beverage manufacturers that fill or import plastic containers subject to the California Redemption Value must meet an annual average of postconsumer recycled plastic across their containers: 15% from 2022, 25% from 1 January 2025 and 50% from 1 January 2030 (CalRecycle, consulted 14 October 2026). CalRecycle's regulations divide postconsumer weight by postconsumer plus virgin weight, in pounds, with caps and labels included. Shortfalls are penalised at USD 0.20 per pound. From 2025 the CalRecycle director may review the standard each year, on the director's own motion or on a petition from an association representing at least 35% of reporting manufacturers.

**New Jersey ([PR-US-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-010/)).**  Plastic beverage containers need 15% postconsumer content from 2024, 20% from 2027 and 25% from 2030, rising in three-year steps to 50% in 2044, with hot-fill containers capped at 30%. Rigid plastic containers from 8 fluid ounces to 5 gallons need 10% from 2024, 20% from 2027 and 30% from 2030, reaching 50% in 2036 (NJDEP Recycled Content Law FAQ, 12 May 2025). Wine and liquor bottles are excluded, as are rigid containers for FDCA-regulated drugs, devices and cosmetics. Section 11 allows a waiver of at least two years, for a USD 1,000 fee, where supply is inadequate.

**India ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)).**  Producers, importers and brand owners must use category-wise shares of recycled plastic: Category I 30%, 40%, 50% and 60% from 2025-26 to 2028-29 onwards; Category II 10%, 10%, 20% and 20%; Category III 5%, 5%, 10% and 10%, counted on the plastic layers only (G.S.R. 237(E), 31 March 2026). Recycled plastic must meet IS 14534:2023. Uses where a law, FSSAI, CDSCO or a mandatory Indian Standard does not permit recycled plastic are exempt if declared in the annual return, importers can no longer count recycled plastic already inside imported material, and unmet 2025-26 food-contact shares may be carried forward for three years. The amendment gave CPCB six months to issue audit guidelines; SPI has not yet confirmed that they have been issued as of 14 October 2026.

**Colombia ([PR-CO-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/colombia/pr-co-002/)).**  Article 17 of Law 2232 of 2022 requires PET bottles for treated drinking water to contain at least 50% recycled material by 2025 and 90% by 2030, and PET bottles for other drinks 20% by 2025, 35% by 2030, 40% by 2035 and 60% by 2040, where technical and health rules allow. The material may be national postconsumer or the producer's own post-industrial material, with national postconsumer material the majority.

**UK Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).**  Not a minimum but a cliff: GBP 228.82 per tonne from 1 April 2026 on each plastic packaging component with less than 30% recycled plastic, and nothing at or above it (Finance Act 2021, section 45 as amended). From 1 April 2027 pre-consumer plastic stops counting, and chemically recycled plastic can count through certified mass balance; HMRC published draft certification regulations on 6 October 2026, with comments open to 21 December 2026.

Outside the tracker, Washington State also sets 25% postconsumer content for plastic beverage containers from 2026 to 2030 and 50% from 2031, averaged by weight per producer (RCW 70A.245.020, as given in the SPI rule analysis for [PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)). SPI has not yet added it as a rule.

## The brand pledges in the database

In the 14 October snapshot, 22 companies hold the 29 recycled-content targets out of 148 packaging targets in the database. Exhibit 4 shows that the 2025 deadline was the first real test: of the 14 targets due by then, 4 are reported met. Exhibit 1 sets each company's goal against its latest reported figure, and three patterns stand out before any law enters the picture.

**The scopes vary widely.**  Some goals cover all plastic packaging (Unilever, Colgate-Palmolive, Kimberly-Clark, PepsiCo, Mars). Some cover all packaging materials (Diageo's 2030 goal, The Estée Lauder Companies, Target, The Coca-Cola Company's primary packaging goal). Some are narrower: Diageo's PET bottles, HEINEKEN's bottles and cans, The Coca-Cola Company's rPET share of PET. Retailers set goals for own-brand or private-brand ranges only. L'Oréal counts recycled and biobased material together: it reports 50% recycled or biobased plastics in 2025 and now aims for 50% of all packaging materials from recycled or biobased sources by 2030 (L'Oréal 2025 Universal Registration Document).

**The same company can report two figures.**  Carrefour reports 24.0% recycled plastic in packaging in 2025 against its 30% goal, and its registration document also reports 13.4% recycled plastic in total plastic packaging (Carrefour 2025 Universal Registration Document, 27 March 2026). The difference is the denominator, and any comparison with a law has to start by asking which denominator the law uses.

**Progress can be fast.**  Walmart's estimated postconsumer content in North America private-brand plastic packaging rose from 8.2% in FY2025 to 12.0% in FY2026, and globally from 7.6% to 10.7% (Walmart FY2026 ESG). The Lidl and Kaufland divisions reached 26%, up six percentage points in a year (Schwarz Group, 27 May 2026). Reckitt went from 8% in 2023 to 12% in 2024 (Reckitt Sustainability Report 2025). Gains of 3 to 6 points in a year are larger than the annual pace most open goals require, a point the pace analysis returns to.

Companies say why the climb is hard. Unilever, which reports meeting its 25% goal in 2025, set out the constraint in December 2025.

> "Limited demand and supply, combined with complex market dynamics, make PCR more expensive than virgin plastic."

***Unilever** , Senior Procurement Manager, Plastic Sustainability, quoted in a unilever.com news article, 18 December 2025*

The same article notes that recycled plastic "must meet the same safety, performance and regulatory standards as virgin plastic", which is the food-contact constraint that India's exemption and the PPWR's Article 7(5)(a) both recognise.

## Four kinds of pledge, and which ones a law can test

To compare pledges with laws, SPI sorted the 23 targets in Exhibit 1 by what they measure. Four types emerge, and the type decides whether a legal minimum can be set against the target at all.

SPI analysis

The database is weighted towards the types a law cannot test. 19 of the 23 targets in Exhibit 5 are portfolio averages or mixed-material goals. They are useful for showing direction across a company, but the market rules now set the floor in each place they apply, and a portfolio average is no longer the number that decides cost or market access in California, India, the EU or the UK.

In practice: Dabur India.

Dabur set its goal at the 2025-26 legal levels: 30%, 10% and 5% recycled content in Category I, II and III plastic packaging of non-food items by FY 2026. It reports 2%, 6% and 1% for FY 2025-26, and SPI records the goal as missed (Dabur Business Responsibility and Sustainability Report FY 2025-26). It is the only target in the database written against a legal level category by category. The rules allow exemptions where a law or statutory body does not permit recycled plastic, if declared in the annual return. SPI does not assess whether any company complies; check with counsel.

In practice: ITC Limited.

ITC reports its recycled plastic by format rather than as one average: 35.5% in rigid packaging and 4.5% in flexible packaging in FY 2025-26, against 2030 goals of 60% and 20% "where permitted" by food and drug rules (ITC ESG Fact Book FY 2025-26, in the SPI Buyers Database profile). Its overall recycled content across 73,762 tonnes of plastic packaging was 3.22%, a figure the company reports on a different page and does not reconcile with the format split. The format split maps closely onto India's Category I (rigid) and Category II (flexible) levels, which is the comparison an average cannot give; the category mapping is SPI's reading.

## Comparing like with like

SPI matched each legal minimum with the brand targets whose scope comes closest, and recorded what still differs. Where nothing matches, Exhibit 6 says so.

Four pairs are close enough to set side by side as numbers. Exhibit 7 shows them, with the scope difference in each label.

**Beverage bottles.**  Diageo's 44% recycled content in PET bottles in fiscal 2026 is above the 30% that the PPWR and the Directive set for 2030, and above California's 25% for 2025 (Diageo ESG Reporting Index 2026). Its figure is global, and spirits bottles may fall outside some scopes: New Jersey excludes liquor bottles, and California's rule covers only containers with the California Redemption Value. The Coca-Cola Company reports that 20% of the PET it used globally in 2025 was rPET, and aims for 30% to 35% by 2035 (The Coca-Cola Company 2025 Environmental Update). That 2035 global goal sits at or below several 2030 legal levels for beverage bottles in individual markets: 30% in the EU, 35% for Colombian PET bottles of drinks other than water and 50% in California.

SPI analysis

A global average below a market's floor does not mean that market's bottles fall short, because a company can put more recycled resin into the markets that require it. California's own rule shows how: it averages across a manufacturer's whole CRV container volume, so high-content lines can offset low ones. It does mean that the global target is no longer the binding one. From 2030 the market rules set the floor in each place, and the global figure becomes a by-product of meeting them.

**India.**  ITC's rigid figure of 35.5% sits above the 30% Category I level for 2025-26 and below the 50% that applies from 1 April 2027; its flexible figure of 4.5% sits below the 10% Category II level. Dabur sits below all three of its category levels. Marico aims for a 60% r-PCR share in non-food packaging by 2030 "as per applicable regulatory standards", and reports 32.2% recycled content in its non-edible portfolio for FY 2025-26 (Marico ESG Data Book FY 2025-26, September 2026). Its 60% matches the Category I level that applies from 2028-29, but its figure combines categories, so it cannot be set against the levels one by one.

SPI analysis

The Indian pairs show a rigid and flexible split that the global averages hide. ITC's rigid figure is eight times its flexible figure, and Dabur's Category II figure is three times its Category I figure, so the gap can sit in either format. SPI's companion piece on [flexible packaging](https://www.strategicpackaginginsights.com/insights/flexible-packaging-recyclability-gap/) finds the same split in recyclability.

## How each law counts the percentage

The level is only half of a recycled-content rule. The other half is the unit it is measured in, and here the laws diverge sharply.

SPI analysis

The EU change is the one most companies have not yet reflected. The Directive's 30% is a national average, so no single company fails it. The PPWR moves the duty onto each manufacturer and each plastic part, averaged per plant per year. A group that meets 30% on average across its European bottle plants could still have one plant below the line. Recycled resin will need to be contracted, tracked and documented plant by plant, which is a procurement design question as much as a sustainability one.

The UK is moving the other way on what counts. HMRC's policy paper explains why pre-consumer plastic will stop counting from 1 April 2027.

> "will address a tax loophole which undermines the environmental objectives of the tax"

***HM Revenue and Customs** , policy paper on mass balance and removal of pre-consumer plastic, GOV.UK, 26 November 2025*

The same paper notes that "many businesses regard the use of pre-consumer waste as good practice rather than recycling", which is why a component's recycled share may fall on paper in April 2027 without any change to the pack.

## The pace gap

The gap that matters most is not today's distance but the speed each side must move. SPI calculated the average increase per year that each legal ladder and each open brand goal requires.

The method is simple and checkable: California's level doubles from 25% to 50% over five years, so the ladder requires 5 points a year; PepsiCo's goal moves from 18% in 2025 to 40% by 2035, which requires 2.2 points a year (PepsiCo Packaging page, 13 August 2026).

SPI analysis

Among the brand goals still open, only Marico's and ITC's flexible goal need a pace of the kind most legal ladders demand, and both are tied to India's rules. The others need between 0.26 and 2.2 points a year. The fastest observed year-on-year gains in the database are larger: about 3.8 points for Walmart in North America, 4 points for Reckitt and 6 points for Lidl and Kaufland. So the slow pace of most corporate goals reflects a choice of ambition, not a ceiling on what supply chains have shown they can do in a year.

In practice: Mondelēz International.

The group goal is 5% recycled plastic content by 2030, with 3.7% reported, the slowest required pace in Exhibit 9 (Mondelēz Goals and progress). At brand level the figure is far higher: Cadbury sharing bars made and sold in the UK and Ireland are wrapped in flexible plastic with 80% certified recycled content, through mass balance and advanced recycling, covering about 300 million bars and about 600 tonnes of recycled plastic a year (Mondelēz UK release, 16 May 2025, in the SPI Buyers Database profile). The case shows that a low group average can coexist with a market-specific pack far above the UK's 30% line, and that mass balance is how flexible film is reaching such levels.

In practice: Walmart.

Walmart missed both 2025 goals, 20% postconsumer content in North America private-brand plastic packaging and 17% globally, reporting 12.0% and 10.7% for FY2026 (Walmart FY2026 ESG). Its one-year gain of about 3.8 points in North America is still one of the larger gains observed in the database, and ahead of the 3.3 points a year that New Jersey's rigid container ladder requires to 2030.

SPI analysis

For resin buyers and converters, the steep legal ladders are where demand for documented postconsumer resin will rise first: California CRV containers, Colombian PET and Indian Category I rigid packaging. In each, a brand's global goal is not a useful forecast of what will be required on the pack.

## What a shortfall costs: two scenarios

Two of the laws publish a price for falling short, which allows the gap to be costed. Each scenario below uses one currency, sourced rates and stated volumes; the volumes are illustrative, not any company's figures.

**SPI calculation**  The 2030 requirement on 10,000,000 lb is 50%, or 5,000,000 lb of postconsumer plastic. At 40% the manufacturer uses 4,000,000 lb, so it is 1,000,000 lb short and owes 1,000,000 x USD 0.20 = USD 200,000. At 25% it is 2,500,000 lb short and owes USD 500,000. Each percentage point is 100,000 lb, or USD 20,000. The penalty is set per pound, so it scales with volume: a manufacturer with 100 million pounds would face ten times these amounts.

**SPI calculation**  A component at 32% recycled plastic, of which 5 points are pre-consumer scrap, counts as 27% from 1 April 2027 and becomes taxable on its full weight. If 300 of 1,000 tonnes move below the line, the tax is 300 x GBP 228.82 = GBP 68,646 a year at the April 2026 rate. The rate is uprated each April, so later years will differ.

SPI analysis

The two regimes punish different things. California charges for the missing pounds only, so the cost of a shortfall grows smoothly. The UK charges the whole component once it slips below 30%, so the cost jumps. A pack that serves both markets therefore needs a resin plan for California's average and a per-component margin above 30% for the UK, with the margin built from postconsumer or certified material rather than scrap.

## What each number measures

SPI analysis

One inference does hold across scopes. A weighted average below 30% means that some of the plastic in it, by weight, is below 30%. So every company whose company-wide average for plastic is under 30% uses some plastic packaging, somewhere, below the 30% level the UK tax uses. Whether any of that packaging is a UK component cannot be read from the average, and an average above 30% would not prove that every component clears it either.

## Industry reaction

Regulators frame the rules as demand policy for recycled resin. CalRecycle describes the purpose of AB 793 in market terms.

> "The law will help improve the market for recycled plastic by increasing the demand and, therefore, increasing the scrap value"

***CalRecycle** , regulator, Plastic Minimum Content Standards and Reporting page, consulted 14 October 2026*

CalRecycle's page ties that scrap value to material collected through California's container programme, which is the mechanism behind the 50% step in 2030.

The quotes from Unilever and HMRC earlier in this piece add the two other sides: the company view that postconsumer resin costs more than virgin plastic, and the tax authority's view that pre-consumer scrap was a loophole. Together they explain why the brand ladders are shallow and the legal ones steep: the laws are written to pull supply forward, while pledges are written against today's supply.

## What leaders should do now

1. **Head of sustainability reporting, by the 2026 annual report:**  publish recycled content in the laws' own units alongside the global figure: by market, by category, postconsumer only, and for India by Category I, II and III.
2. **Chief procurement officer, by 31 March 2027:**  contract postconsumer resin by plant and by market for 2030, since the PPWR averages per plant per year and California per manufacturer, and stop relying on group-wide volume agreements alone.
3. **UK finance and tax lead, before 1 April 2027:**  list every plastic component that reaches 30% only with pre-consumer scrap, and either replace that share with postconsumer or certified material or budget the tax at GBP 228.82 per tonne.
4. **US beverage operations lead, by the 1 March 2027 report:**  model the 2030 California shortfall at USD 0.20 per pound for each CRV container line and decide which lines carry high recycled content to offset others.
5. **India packaging lead, by 1 April 2027:**  map every pack to Category I, II or III, document any exemption in the annual return, and plan Category I sourcing for 50% in 2027-28 and 60% from 2028-29.
6. **EU regulatory lead, within a month of adoption:**  read the PPWR Article 7(8) calculation act, due by 31 December 2026, and align supplier certificates and plant averages with it.
7. **Board sustainability committee, at the next target review:**  retire or restate any 2030 or 2035 goal that sits below a 2030 legal level in a major market, so the public goal is not weaker than the law.

## Questions for your board

- Which of our recycled-content targets can be tested against a law, and which are portfolio averages that no regulator will accept?
- In which plants and markets would we fall short of the PPWR, California or India levels if 2030 began today?
- What would a shortfall cost us in California penalties and UK Plastic Packaging Tax, at our real volumes?
- How much of our reported recycled content is pre-consumer scrap, and what happens to it on 1 April 2027?
- Is our postconsumer resin contracted by plant and market, or only at group level?
- Does any public goal of ours now sit below the legal minimum in a market we sell in?

## What to watch

- **21 Dec 2026:**  comments close on HMRC's draft chemical recycling certification regulations for the Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).
- **31 Dec 2026:**  the PPWR Article 7(8) implementing act on calculating and checking recycled content, and the Article 7(9) recycling technology criteria, are due ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **1 Mar 2027:**  California beverage manufacturers report on plastic containers filled or imported in 2026 ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)).
- **1 Apr 2027:**  pre-consumer plastic stops counting towards the UK's 30% threshold ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)), and India's Category I level rises to 50% ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)).
- **21 Nov 2027:**  the EU bottle method starts counting recycled plastic from OECD-decision countries ([PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).
- **1 Jan 2028:**  the Commission's assessment of possible PPWR recycled-content derogations is due ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **1 Apr 2028:**  India's Category I rigid plastic packaging must contain 60% recycled plastic ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)).
- **1 Jan 2030:**  California's minimum rises to 50% ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)), and the EU's 30% for single-use plastic beverage bottles applies ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/), [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).

## Methodology

- **Data used:**  the SPI Buyers Database live snapshot of 14 October 2026, with 29 recycled-content targets out of 148, and the SPI Regulation Tracker's 6 recycled-content rules plus [PR-CO-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/colombia/pr-co-002/) and [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/), with SPI's rule analysis of 14 October 2026. SPI opened CalRecycle's AB 793 page, HMRC's policy paper of 26 November 2025 and Unilever's article of 18 December 2025 on 14 October 2026.
- **Classification:**  the four pledge types in Exhibit 5 are SPI's reading of each target's stated scope, applied to the 23 targets with a numeric goal and a reported figure.
- **Matching rule:**  a brand target and a law are compared as numbers only where both cover the same packaging type and material basis; every remaining difference is stated.
- **Pace:**  (end level minus start level) divided by years between them, using the low end of any range.
- **Scenarios:**  the California and UK scenarios use published rates and illustrative volumes stated in each exhibit; each stays in one currency and nothing is converted.
- **Cut-off:**  14 October 2026.
- **Limitations:**  company figures are company-reported and not audited by SPI. PPWR percentages for plastic categories other than single-use beverage bottles sit in Article 7(1), which SPI has not yet confirmed against the official text, so they are not used. ITC's format figures and its overall figure are not reconciled in its own report. Nothing here is a compliance finding or legal advice; check with counsel. Corrections follow the [corrections policy](https://www.strategicpackaginginsights.com/corrections/).

## Sources

1. SPI Buyers Database, live snapshot 14 October 2026, and company profiles. /data/packaging-buyers-database/ (consulted 14 October 2026)
2. SPI Regulation Tracker and SPI rule analysis for PR-EU-004, PR-EU-005, PR-EU-016, PR-US-009, PR-US-010, PR-IN-002, PR-CO-002 and PR-GB-001, 14 October 2026. /data/packaging-regulation-tracker/ (consulted 14 October 2026)
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14. Washington State Legislature, RCW 70A.245.020, Postconsumer recycled content. [https://app.leg.wa.gov/RCW/default.aspx?cite=70A.245.020](https://app.leg.wa.gov/RCW/default.aspx?cite=70A.245.020) (as given in SPI rule analysis, consulted 14 October 2026)
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17. ITC Limited, ESG Fact Book FY 2025-26. [https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf](https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
18. Marico, ESG Data Book FY 2025-26. [https://sustainability.marico.com/uploads/1790752760463-esg-data-book-marico-2026-final-pdf.pdf](https://sustainability.marico.com/uploads/1790752760463-esg-data-book-marico-2026-final-pdf.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
19. Diageo, ESG Reporting Index 2026, and The Coca-Cola Company, 2025 Environmental Update. [https://www.diageo.com/~/media/Files/D/Diageo-V2/Diageo-Corp/esg/2026/esg-reporting-index-2026.pdf](https://www.diageo.com/~/media/Files/D/Diageo-V2/Diageo-Corp/esg/2026/esg-reporting-index-2026.pdf) and [https://www.coca-colacompany.com/content/dam/corporate/us/en/reports/2025-environmental-update/2025-environmental-update.pdf](https://www.coca-colacompany.com/content/dam/corporate/us/en/reports/2025-environmental-update/2025-environmental-update.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
20. Mondelēz International, Goals and progress, and Mondelēz UK, Cadbury's iconic purple packaging is now using 80 percent recycled plastic, 16 May 2025. [https://www.mondelezinternational.com/snacking-made-right/reporting-and-disclosure/goals-and-progress/](https://www.mondelezinternational.com/snacking-made-right/reporting-and-disclosure/goals-and-progress/) and [https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/cadburys-iconic-purple-packaging-is-now-using-80-percent-recycled-plastic-3386958?site=uk](https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/cadburys-iconic-purple-packaging-is-now-using-80-percent-recycled-plastic-3386958?site=uk) (as given in SPI Buyers Database, consulted 14 October 2026)
21. Walmart, FY2026 ESG: Waste and circularity, and Schwarz Group, press release of 27 May 2026. [https://corporate.walmart.com/purpose/esgreport/waste-and-circularity](https://corporate.walmart.com/purpose/esgreport/waste-and-circularity) and [https://gruppe.schwarz/en/press/archive/2026/the-companies-of-schwarz-group-successfully-conclude-their-joint-plastic-strategy](https://gruppe.schwarz/en/press/archive/2026/the-companies-of-schwarz-group-successfully-conclude-their-joint-plastic-strategy) (as given in SPI Buyers Database, consulted 14 October 2026)
22. PepsiCo, Packaging, and Keurig Dr Pepper, 2025 Impact Report. [https://www.pepsico.com/our-impact/esg-topics-a-z/packaging](https://www.pepsico.com/our-impact/esg-topics-a-z/packaging) and [https://www.keurigdrpepper.com/wp-content/uploads/2026/06/impact-report.pdf](https://www.keurigdrpepper.com/wp-content/uploads/2026/06/impact-report.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
23. L'Oréal, 2025 Universal Registration Document, and Carrefour, 2025 Universal Registration Document. [https://www.loreal-finance.com/eng/2025-universal-registration-document/en/article/51/](https://www.loreal-finance.com/eng/2025-universal-registration-document/en/article/51/) and [https://www.carrefour.com/sites/default/files/2026-04/CFR2025_URD_EN_PDF_MEL_270326_0.pdf](https://www.carrefour.com/sites/default/files/2026-04/CFR2025_URD_EN_PDF_MEL_270326_0.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
24. Henkel, New sustainability targets for 2030, 14 April 2026, and HEINEKEN, Brew a Better World 2025 progress. [https://www.henkel.com/press-and-media/press-releases-and-kits/2026-04-14-henkel-announces-new-sustainability-targets-for-2030-2148156](https://www.henkel.com/press-and-media/press-releases-and-kits/2026-04-14-henkel-announces-new-sustainability-targets-for-2030-2148156) and [https://www.theheinekencompany.com/sites/heineken-corp/files/2026-02/brew-better-world-2025-progress.pdf](https://www.theheinekencompany.com/sites/heineken-corp/files/2026-02/brew-better-world-2025-progress.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)
25. Reckitt, Sustainability Report 2025; Unilever, Annual Report and Accounts 2025; Colgate-Palmolive, 2025 Sustainability and Social Impact Report; other company reports linked from each SPI Buyers Database profile. [https://eu-assets.contentstack.com/v3/assets/blt93c8bc7a598af9f0/blt8d0848c0b02e7e52/69cd46220c530c95012e3f8d/Reckitt_Sustainability_Report_2025.pdf](https://eu-assets.contentstack.com/v3/assets/blt93c8bc7a598af9f0/blt8d0848c0b02e7e52/69cd46220c530c95012e3f8d/Reckitt_Sustainability_Report_2025.pdf), [https://www.unilever.com/files/unilever-annual-report-and-accounts-2025.pdf](https://www.unilever.com/files/unilever-annual-report-and-accounts-2025.pdf) and [https://www.colgatepalmolive.com/content/dam/cp-sites-aem/corporate/corporate/common/pdf/cp-2025-ssi-report.pdf](https://www.colgatepalmolive.com/content/dam/cp-sites-aem/corporate/corporate/common/pdf/cp-2025-ssi-report.pdf) (as given in SPI Buyers Database, consulted 14 October 2026)