PPWR: What Businesses Need to Know About Post‑Consumer Recyclates
Assess post-consumer recyclates for the specific application
Article 7 of Regulation (EU) 2025/40 establishes minimum recycled-content requirements from post-consumer plastic waste for certain plastic packaging. The applicable requirement depends on the packaging category, use, exemptions and relevant application date. A single quota for all packaging containing plastic would be an oversimplification.
Record origin and supporting evidence
Post-consumer recyclates concern material recovered from plastic waste after products have been used. Production residues are a separate category. Counting material towards PPWR requirements depends on compliance with the legal conditions for origin, collection, recycling and verification; describing a material as PCR is not sufficient.
Material from third countries is likewise not automatically eligible merely because it comes from used products. Applicable equivalence requirements and evidence must be assessed. Supplier information should identify the actual material stream and grade.
Distinguish recycling processes and calculation rules
The terms mechanical or chemical recycling alone do not establish eligibility. Article 7 provides for supplementary rules on calculating and verifying recycled content, criteria for recycling technologies and evidence for third-country materials. The rules in force and the associated documentation are decisive when selecting a specific material.
Biobased does not automatically mean PCR
Biobased plastic feedstock and recycled content from post-consumer plastic waste are different categories. Article 8 provides for a review of biobased plastic packaging by 12 February 2028 and potentially subsequent legislative proposals. This does not establish general permission to replace PCR with biobased feedstock. A fixed exchange ratio is not presented here as an applicable rule.
Assess material and packaging together
For automotive and co-packing applications, material properties, processing, product protection, potential contact requirements and traceability should be examined together. Recycled content alone establishes neither recyclability of the finished package, a particular environmental impact nor compliance with every PPWR requirement.
FEURER discusses technical packaging requirements, possible material specifications and necessary verification steps with customers. Actual recycled-content use depends on the selected design, available material grades and required evidence.
Legal reference: Regulation (EU) 2025/40, particularly Articles 7 and 8. Supplementary legal acts and applicable conditions must be considered for each project.
Editorially updated in September 2026. General statements on eligibility, biobased substitutes and PPWR compliance have been revised.
