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Article 7 has separate 2030 and 2040 minimum percentages for four plastic-packaging categories. For 2030, or three years from the Article 7(8) implementing act if later, the minimums are 30% for contact-sensitive PET packaging except single-use plastic beverage bottles, 10% for other contact-sensitive plastic packaging except single-use plastic beverage bottles, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging.

For 2040, the same categories rise to 50%, 25%, 65%, and 65%. Teams should not copy these percentages into a product decision without first checking the packaging category, exclusions, timing rule, and any later delegated or implementing act that changes the applicable calculation or target.

Article 7 does not leave teams free to invent a final compliance methodology. It requires the Commission to adopt implementing acts by 31 December 2026 establishing the methodology for calculating and verifying the percentage of recycled content recovered from post-consumer plastic waste collected and recycled within the Union, plus the format for the Annex VII technical documentation.

The Article 7(11) transition rule says the calculation and verification for the 2030 targets must comply with that implementing act by 1 January 2029 or 24 months from the implementing act's entry into force, whichever is later. Until then, teams can prepare data structures and evidence using Article 7's boundaries, but should keep the method change-controlled and update it when the implementing act is adopted.

Before running the percentage check, confirm that the packaging is actually subject to Article 7(1) or (2). Article 7 excludes listed medical, veterinary, contact-sensitive, compostable, dangerous-goods, infant and young-child food, and medicinal-product-related packaging cases, and it also excludes food-contact plastic packaging where the recycled-content quantity would threaten human health and breach Regulation (EC) No 1935/2004.

Article 7 also excludes any plastic part representing less than 5% of the total weight of the whole packaging unit. The Commission's 2026 guidance says the Article 7(5) food-contact and under-5% exemptions apply directly without a separate Commission or authority approval, but the manufacturer must substantiate them in the technical documentation.

For the food-contact health exemption, the guidance expects the file to identify the polymer in every plastic part that represents at least 5% of the packaging unit and to show both that Annex I to Regulation (EU) 2022/1616 lists no suitable recycling technology for that polymer and that no industrial-scale technology is available for compliant manufacture. Do not turn that evidential example into a broader exemption for all food-contact plastic.

A practical record should show the Article 7 path from classification to evidence. It should identify the packaging unit, each plastic part assessed, the Article 7 category, manufacturing plant, year, recycled-content input, post-consumer plastic waste basis, applicable exception checks, and the method version used.

The record should also flag whether the final Commission implementing-act methodology has been applied. If not, mark the result as a planning or readiness calculation, not as a final Article 7 verification. Recalculate after a material, supplier, packaging format, manufacturing plant, recycled-input source, or methodology version changes.

Packaging placed on the market from 11 February 2025 is reusable only if it satisfies all Article 11 conditions. The package must be conceived, designed, and placed on the market to be re-used multiple times, designed for as many rotations as possible under normally predictable use, and capable of emptying, unloading, refilling, reloading, and reconditioning without losing its intended function.

The Commission's 2026 guidance resolves the timing point: the Article 11 criteria apply to packaging placed on the market from 11 February 2025, but authorities can enforce them only after the Regulation's general application date of 12 August 2026. Reusable packaging placed on the market before 11 February 2025 does not have to be retrofitted to Article 11 and is protected from the Article 15(8) bring-into-conformity, withdrawal, or recall duty.

The reusable claim also has to preserve health, safety, hygiene, product quality, traceability, safety information, and end-of-life recyclability. A thicker single-use pack, a returnable shipping container with no collection route, or a marketing claim without technical documentation should not be treated as enough.

Economic operators who make reusable packaging available in a Member State for the first time must ensure a re-use system is in place in that Member State. The system must include an incentive to collect the packaging and meet Annex VI requirements. Use of an existing compliant re-use system can satisfy that obligation.

Economic operators that make use of reusable packaging must participate in one or more re-use systems, ensure the systems meet Annex VI Part A, and ensure packaging is reconditioned under Annex VI Part B before it is offered again for use by end users. Closed loop users also have to return packaging to collection points approved by the system operator.

Reusable packaging placed on the market from 12 February 2029, or 30 months after the relevant implementing act enters into force if later, must carry a label telling users that the packaging is reusable. More information on reusability, the available re-use system, and collection points must be provided through a QR code or another standardised, open digital data carrier, unless the Article 12 derogation for open loop systems without a system operator applies.

For the take-away sector, final distributors in the HORECA sector that sell hot or cold beverages or ready-prepared food in take-away packaging must, by 12 February 2028, give consumers the option to obtain those products in reusable packaging within a re-use system. They must tell consumers at the point of sale and offer the reusable-packaging option at no higher cost and under no less favourable conditions than the same product in single-use packaging.

Keep evidence that proves both sides of the claim: the packaging qualifies as reusable and the operational system makes re-use possible in practice. The record should connect Article 11 technical information, Article 26 system compliance, Article 27 participation and reconditioning, Annex VI governance, and any Article 12 labelling or Article 33 take-away obligation that applies.

Do not use reusable language before the system operates in practice. The file should show who operates the system, who participates, how packaging returns, how reconditioning works, and what data is collected. Reassess after the packaging design, cleaning or repair process, participant network, collection route, return incentive, intended use, or relevant delegated or implementing act changes.

Under Article 3 of Regulation (EU) 2025/40, service packaging is an item designed and intended to be filled at the point of sale in order to dispense the product. The point-of-sale filling fact matters more than the commercial name used by the supplier.

Teams should classify each relevant item by its actual use: whether it is filled at the point of sale, whether it performs a packaging function, and whether it is single-use or reusable.

Take-away packaging is a defined subset of service packaging. It covers service packaging filled at attended points of sale with beverages or ready-prepared food that are packaged for transportation and immediate consumption at another location without further preparation, and that are typically consumed from the packaging.

That means a restaurant, cafe, canteen, or similar HORECA workflow should not stop at the generic service packaging classification. It should also decide whether the facts meet the take-away packaging definition.

For HORECA final distributors that make hot or cold beverages or ready-prepared food available in take-away packaging, the PPWR adds operational obligations. By 12 February 2027, those businesses must provide a system for consumers to bring their own container to be filled. By 12 February 2028, they must give consumers the option of reusable packaging within a system for reuse.

The Regulation also requires point-of-sale information for those options and says the own-container or reusable-packaging option must be offered at no higher cost and under no less favourable conditions than the same product in single-use packaging. A final distributor may refuse an end user's container when it is visibly dirty, unsuitable, or creates a hygiene risk; the operator bears no liability for hygiene or food-safety issues caused by the end user's container. Micro-enterprises are exempt from Article 33's reusable-packaging offer, but not from Article 32's own-container system.

For extended producer responsibility, the PPWR definition of producer expressly includes manufacturers, importers, or distributors that make available service packaging for the first time in the relevant Member State fact patterns. Recital 122 adds an important small-business point: where small businesses fill service packaging at the point of sale, the producer should be the manufacturer, distributor, or importer that first makes that packaging available in the Member State.

The Commission's 2026 guidance confirms that this rule applies whether the service packaging is single-use or reusable. For a domestic supply, identify the manufacturer, importer, or distributor established in the Member State that first supplies the empty service packaging there. For a direct cross-border supply to end users in another Member State, apply the separate Article 3(15)(c) distance-supply route.

Keep evidence that proves the classification and the resulting obligation, not just a generic PPWR note. A useful service-packaging record should show the item, point-of-sale workflow, material, single-use or reusable status, supplier chain, Member State, and whether the case is takeaway food or beverage packaging.

For HORECA cases, the evidence file should also include the Article 32 and Article 33 implementation record: own-container process, reusable-packaging option, point-of-sale notices, pricing parity checks, and any micro-enterprise analysis. Reassess after the item, supplier, point-of-sale workflow, food-preparation step, consumption pattern, business status, or Member State supply route changes.