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

The legal minimums in the tracker

6 rules in the SPI Regulation Tracker carry the recycled-content type: PR-EU-004 and PR-EU-005 under the PPWR, PR-EU-016 under the Single-Use Plastics Directive, PR-US-009 in California, PR-US-010 in New Jersey and 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, a ban rule whose Article 17 sets levels for PET bottles) and the UK Plastic Packaging Tax (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). 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caps are outside Part F. The counting method changed this year: Implementing Decision (EU) 2026/1425 of 30 June 2026 repealed the 2023 method, kept the weight formula and added chemically recycled plastic under mass balance rules, recycler certificates and conditions for recycled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, 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). 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). 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). 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). 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). 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). SPI has not yet added it as a rule.

The brand pledges in the database

In the 14 October snapshot, 22 companies hold the 36 recycled-content targets out of 179 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.

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.

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.

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.

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.

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.

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).

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.

What each number measures