PPWR recycled content calculations How should teams calculate and verify Article 7 recycled content?

For packaging in scope, Article 7 requires each plastic part of packaging placed on the market to contain a minimum percentage of recycled content recovered from post-consumer plastic waste. The calculation is not made across a whole company or brand portfolio by default; the regulation states that it is calculated per packaging type and format as an average per manufacturing plant and year.

Teams should therefore build their working records around those same boundaries: packaging type and format, plastic part, manufacturing plant, calendar year, and the evidence that the recycled content came from qualifying post-consumer plastic waste. This is the operational structure to prepare before the Commission's detailed methodology applies.

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.