Part 3: What needs to be done now
Minimum Recycled Content Quotas: Quotas Increase Significantly by 2040
Starting January 1, 2030, mandatory minimum recycled content quotas will apply to packaging for the first time. Contact-sensitive PET plastic packaging must then contain 30% recycled content. Packaging that is not made of PET must initially only contain 10%, while single-use beverage bottles are already subject to a 30% requirement. All other packaging must contain at least 35% recycled content. These quotas will increase significantly by 2040 – to 50% for contact-sensitive PET, 25% for other contact-sensitive packaging, and 65% for all other packaging.
Regulatory Framework and Exemptions
The quotas apply per manufacturing facility and calendar year. Only post-consumer recyclate that has been collected and recycled in accordance with EU directives is permitted. Third-country recyclates should only be allowed if they meet equivalent environmental standards. Exemptions from the minimum recycled content quota apply, among others, to pharmaceutical packaging, packaging with less than 5% plastic content, and compostable packaging.
Proof Requirements and Certification
By the end of 2026, the EU Commission will present binding methods for calculating and verifying the recycled content. Manufacturers must document compliance with the quotas – for example, through certificates such as ISCC PLUS – and may need to be audited by independent third parties. For food contact packaging, strict requirements of EU Regulation 2022/1616 apply in parallel, particularly regarding the approval of recycling technology by EFSA.
Recommendation for Practice
Companies should revise their packaging concepts early and secure suitable recyclate sources. Particularly in the area of food contact, materials and technologies must be carefully examined for regulatory compliance. The development of recyclable mono-materials and the integration of verification systems into the supply chain should also be initiated now in order to implement them on time and reliably by 2030.
Contact Dr. Daniel Wachtendorf: +49 441 94986 -22
