Rules for the calculation and verification of recycled content in plastic packaging

The Federation of the Food and Drink Industries of the Czech Republic (FFDI CZ) welcomes the opportunity to comment on the implementing and delegated acts under Article 7 of the Packaging and Packaging Waste Regulation (PPWR). We support the objective of increasing the use of high-quality recycled plastic in packaging and developing a strong EU market for secondary raw materials.

Publish clear calculation rules and worked examples for food-contact bags, liners, flexible bulk packaging, wrapping and straps, including multi-component packaging. Establish a standard supplier evidence format covering recycled-content calculation, post-consumer origin, traceability and verification status.

Contribution to the debate on European criteria for recycled materials from third countries – Article 7 of Regulation (EU) 2025/40 The discussion promoted by the European Commission on recycled content verification methodologies, sustainability criteria for plastic recycling and recognition of materials from third countries is relevant for strengthening the circular economy and for building transparent conditions…

Filed in Portuguese · English published by the European Commission

The Implementing Decision developed under the Single-Use Plastics Directive provides a fuel-use-excluded mass balance methodology. The VTCR supports using this methodology as the starting point for the PPWR, with targeted improvements based on lessons learned. Reopening the entire methodology would create unnecessary delay and uncertainty. Key recommendations: 1. Adopt the Implementing Act without delay!

Verpact supports a single, harmonised and practical EU methodology for calculating and verifying recycled content in plastic packaging. Based on our experience in the Netherlands, we consider clear rules on the calculation and aggregation level, data availability, responsibilities across the value chain, chain of custody, acceptable evidence and the recognition of existing certification systems particularly…

Brazilian company over 50 years old in plastic production, processing and recycling (mechanical and advanced by pyrolysis) and ISCC PLUS certification, contributes in dual quality: as an advanced recycling operator (Article 7 (8) and (9)) and as a third country operator (Article 7 (10)). It operates pyrolysis of plastic waste from Brazil, exclusively processing post-consumer household waste.

Filed in Portuguese · English published by the European Commission

We welcome the Commissions initiative to establish harmonised rules for the calculation and verification of recycled plastic content. A simple, reliable and EU-wide methodology is essential to provide legal certainty and a level playing field. The machinery and equipment manufacturing industry is an important part of the plastics value chain.

Eurochambres continues to raise concerns regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR), as smaller businesses in particular are struggling with the regulations complex requirements and the absence of key secondary legislation.

FEIQUE, the Spanish Federation of the Chemical Industry, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the harmonisation of rules for calculating and verifying recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR).

CLEPA, the European Association of Automotive Suppliers, representing over 3.000 companies, from multi-nationals to SMEs, supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, directly employing 1.7 million people in the EU, welcomes this initiative and the opportunity to submit its comments in the file attached.

The transition to a more circular economy for plastics must remain economically viable. The Packaging and Packaging Waste (PPWR) secondary legislation should ensure that recycled content targets are implemented in an economically viable manner.

Treating these 3 implementing acts provided for in the PPWR in the same initiative is relevant in order to have an overview of the issues at stake here. Recycling of plastic is essential to promote increased circularity of plastic material in Europe and can also contribute to minimising the footprint associated with plastic waste management.

Filed in Portuguese · English published by the European Commission

CEFLEX--the Circular Economy for Flexible Packaging initiative--welcomes the opportunity to respond to this call for evidence. We invite the Commission to take into account the supply-side and investment implications of the three PPWR Article 7 secondary legislative acts when designing the rules.

The Polish Union of the Cosmetics Industry supports increasing the use of recycled plastics in packaging. However, the current PPWR component-by-component approach is not workable for many complex cosmetic packaging formats. Recycled-content requirements apply to individual plastic packaging parts, while compliance is calculated as an annual average for each packaging type and format per manufacturing plant.

Methodology for recycled content Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Promeco welcomes the opportunity to respond to the Call for Evidence on sustainability criteria for recycling technologies under Article 7(8) of EU PPWR regulation. Promeco is a leading Italian waste-to-value technology provider, with chemical recycling technology as a key portfolio focus. Please find our feedback attached.

LyondellBasell (LYB) welcomes the opportunity to contribute to this call for evidence. We support the Commissions ongoing efforts to consider industry and other perspectives whilst ensuring timely completion of PPWR secondary legislation. LYB is a large multinational chemical and polyolefins manufacturing company that has anchored its strategy on sustainability.

Chemelot is one of Europes largest integrated chemical and materials clusters. The cluster combines existing large-scale chemical production infrastructure with current and planned activities in mechanical and advanced recycling, circular feedstock processing and the production of circular polymers and materials.

About Dow Dow (NYSE: DOW) is one of the world’s leading materials science companies, serving customers in high-growth markets such as packaging, infrastructure, mobility and consumer applications. Our global breadth, asset integration and scale, customer-focused innovation and leading business positions enable us to achieve profitable growth and help deliver a sustainable future.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

According to the Conversio study Current Status and Forecast of Demand and Availability of Post-Consumer Recyclates in 2030 there will be a gap of recycled plastics with respect to mandatory requirements for packaging but also for future mandatory requirements in other sectors and for voluntary use.

ANFAC, the Spanish Association of Automobile and Truck Manufacturers, considers that the methodology provided for in Article 7 (8) of Regulation (EU) 2025/40 on packaging and packaging waste will be a key element in ensuring a harmonised application of recycled content requirements across the European Union.

Filed in Spanish · English published by the European Commission

OMV is undertaking the largest transformation in its history. To support this ambition, OMV is developing circular, renewable and synthetic fuels and chemicals projects, including solutions based on green hydrogen and biogenic CO. These products will offer customers a lower-carbon value proposition and support the transition to a more sustainable chemicals value chain.

Eurima welcomes the opportunity to provide feedback on the calculation and verification of recycled content under the Packaging and Packaging Waste Regulation. We support a robust methodology grounded in verified physical material flows that protects fair competition and rewards investment in recycling. Please find our detailed recommendations attached.

Avenue des Gaulois 9 B-1040 Brussels Belgium Tel: [phone removed] TR: 107438267901 AIM FEEDBACK www.aim.be European Commission’s call for evidence on secondary legislation implementing Article 7 of the Packaging and Packaging Waste Regulation September 2026 AIM, the European Brands Association, represents manufacturers of branded consumer goods across the food and beverage, personal and homecare, apparel…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The scale-up of chemical recycling is an opportunity to advance the EUs objective of creating a competitive circular economy that reduces GHG emissions and boosts EU raw material autonomy. The mass balance (MB) decision for recycled content under the Packaging and Packaging Waste Regulation (PPWR) must prioritize the competitive scale-up of chemical recycling assets in the EU to avoid heavy reliance on imports to…

Eastman welcomes the Commissions initiative to consider industry perspective when developing harmonized rules for calculating and verifying recycled content in plastic packaging. Our position is to maintain a credible FUE MB method for recycling and seek additional policy mechanism to value up the recovered plastics waste which becomes fuel.

Indaver PlasticsChemicals supports the objectives of the Packaging and Packaging Waste Regulation (PPWR) to reduce packaging waste, increase packaging circularity, reduce dependence on virgin fossil resources and stimulate investments in high-quality recycling solutions.

EuPC welcomes the opportunity to contribute to the Call for Evidence on the forthcoming implementing measures under Article 7(8), (9) and (10) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Our position paper enclosed sets out industry priorities for a calculation and verification framework: an inclusive, fair and transparent calculation methodology and a credible, proportionate certification and…

Inter IKEA Group welcomes the opportunity to provide input to the European Commissions Call for Evidence related to the two upcoming implementing acts related to Article 7 of the Packaging and Packaging Waste Regulation (PPWR). For nearly 80 years, packaging has been a cornerstone of the IKEA business model.

Please find our formatted comments in the attachment. The Food Packaging Forum Foundation (FPF) welcomes the opportunity to provide evidence for the harmonization of rules for calculating and verifying recycled content in plastic packaging.

Response to the call for evidence on the implementing act establishing the methodology for calculating and verifying recycled content recovered from post-consumer plastic waste, and the format for technical documentation.

The Advisory Board for Finnish PROs appreciates the opportunity to provide a statement on the European Commission's initiative to harmonise rules for calculating and verifying recycled content in plastic packaging. Harmonisation Is Essential for Transparency and Fair Competition The Advisory Board for Finnish PROs would like to thank the Commission for its efforts to harmonise the rules.

Versalis, Enis chemical company, welcomes the recognition of chemical recycling and its complementarity with mechanical recycling, as well as the acknowledgment of the fuel-use-excluded mass balance approach under the SUPD Implementing Act published on 3 July 2026.

For calculating and verifying recycled plastic content, the EU should move away from "credit" mass balance systems that decouple reporting from physical reality. This means prioritising segregation and controlled blending models, and allowing only rolling average mass balance at site level.

Flexible Packaging Europe (FPE), the material-neutral EU association representing suppliers of flexible packaging materials, supports a timely implementation of the harmonised rules for calculating and verifying recycled content in plastic packaging. Detailed feedback can be found attached.

NMWE supports the Packaging and Packaging Waste Regulation (PPWR) goal of expanding the EU market for high-quality recycled plastics. However, secondary legislation must be practical, timely, and fair. It is important to build on the existing regulatory framework by taking into account the requirements already established under Regulations (EU) 2022/1616 and SUPD.NMWE sets out the following sector-specific…

Confapi, the Italian Confederation of Small and Medium-Sized Private Industry, which represents 118.00 small and medium-sized industrial companies with more than 1.3 million employees, shares the general objective of supporting circularity, reducing the use of primary raw materials and stimulating demand for high-quality recycled plastic, as provided for in Regulation (EU) 2025/40 on packaging and packaging waste.

Filed in Italian · English published by the European Commission

European Plastics Circularity (EPC) Coalition position paper on the equivalency criteria under Article 7 of the Packaging and Packaging Waste Regulation (PPWR) To ensure a level playing field for recycled plastics in Europe and guarantee that EU-originating waste is recycled We, the undersigned organisations across the European plastics and packaging value chain call on the European Commission to ensure that…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

OCTAL Position OCTAL SAOC FZC / Alpek Polyester Middle East supports the establishment of a harmonized methodology for calculating and verifying recycled plastic content in packaging placed on the EU market. Uniform rules will provide legal certainty, reduce divergent interpretations among Member States and support the investments required across recycling and packaging supply chains.

The Federazione Carta e Grafica welcomes your participation in the public consultation on the implementing provisions on the calculation and verification of recycled content in plastic packaging laid down in the Regulation on Packaging and Packaging Waste (PPWR). Please find attached the comments and contributions drawn up by the Association.

Filed in Italian · English published by the European Commission

Dear Sir, Madam, The Austrian Federal Economic Chamber (WKO) thanks the initiative entitled ‘Harmonising the rules for calculating and verifying recycled content in plastic packaging’ for the opportunity to comment and requests that the opinion in the Annex be taken into account.

Filed in German · English published by the European Commission

The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.

Our goal is a successful circular economy for plastics and chemicals. Europe needs to expand its recycling infrastructure and markets rapidly and create competitive conditions that enable companies to compete globally and Member States to meet their targets.

This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries.

1 Consultation on harmonised rules for the calculation and verification of plastic recycled content in packaging Avantium welcomes the Commission’s initiative to establish harmonised rules for the calculation and verification of plastic recycled content in packaging under Article 7 of Packaging and Packaging Waste Regulation (EU) 2025/40.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to consultation on a call for evidence for secondary legislation under the Packaging and Packaging Waste Regulation. Introduction Royal Vopak welcomes the opportunity to provide input on the European Commission's Call for Evidence for secondary legislation under the Packaging and Packaging Waste Regulation (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UNESDA’s Response to the EU Call for Evidence on PPWR Recycled Content Requirements UNESDA Soft Drinks Europe welcomes the opportunity to contribute to the European Commission’s call for evidence on the implementation of the recycled content provisions under Article 7 of the Packaging and Packaging Waste Regulation (PPWR), in particular regarding: • Rules for calculating and verifying recycled content in plastic…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Article 7.8 of Regulation (EU) 2025/40 mandates the Commission to adopt an implementing act establishing a harmonised methodology for calculating and verifying the recycled content of packaging. Verification schemes already operate at national level, built on internationally recognised standards and third-party certification.

The Polish Association of the Cosmetics and Detergents Industry (PSPKD) welcomes the opportunity to contribute to the Commissions work on the calculation and verification of recycled content under Article 7 of the PPWR. PSPKD supports clear, harmonised and workable rules that allow compliance to be demonstrated in a proportionate and practical way.

Filed in Polish · English published by the European Commission

As a consumer goods manufacturer with operations in multiple global markets, we have identified three areas of particular concern in relation to the creation of harmonised rules for calculating recycled content that we would appreciate the Commission addressing through the forthcoming implementing acts.

Elipso supports the development of a European circular plastics economy, provided that the PPWR targets for the incorporation of recycled materials do not in any way compromise health safety or existing sectoral regulations.

Filed in French · English published by the European Commission

Thailand PPWR consortium is a platform where government, academic, private, and NGO sectors are collaboratively discussed and agreed to recommend all relevant feedbacks submitted into the EU system regarding Article 7(8), 7(9), and 7(10) of PPWR by the key consortium representatives.

EU REGULATIONS AND INTERNATIONAL AFFAIRS DEPARTMENT INTERNATIONAL REGULATIONS OFFICE Ref. Ares(2026)8795741 - 16/09/2026 ORLEN’S POSITION ON THE DRAFT IMPLEMENTING ACT UNDER THE PACKAGING AND PACKAGING WASTE REGULATION (PPWR) CONCERNING THE CALCULATION AND VERIFICATION OF RECYCLED CONTENT IN PLASTIC PACKAGING 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe, welcomes the upcoming secondary legislation under Article 7 PPWR on the calculation and verification of recycled content.

Question on Article 7(5), point (a), of Regulation (EU) 2025/40 A company produces flexible plastic packaging, of which approximately 95 % is intended for contact with food. The remaining 5 % is packaging for non-food applications.

Filed in German · English published by the European Commission

MOL Groups position on the harmonisation of rules for calculating and verifying recycled content in plastic packaging (Article 7(8)) MOL Group welcomes the Commissions efforts to establish a harmonised methodology for the calculation and verification of recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR).

Plastové obaly a recyklované materiály – pravidla pro recyklaci, dovoz a obsah recyklovaného materiálu Stanovisko HK ČR Hospodářská komora České republiky (HK ČR) vítá možnost vyjádřit se k připravovaným prováděcím pravidlům v návaznosti na nařízení PPWR. HK ČR podporuje cíle směřující k rozvoji oběhového hospodářství a efektivnímu využívání recyklovaných materiálů.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Industry of the Czech Republic welcomes the European Commission's initiative regarding the forthcoming implementing and delegated acts intended to regulate the calculation, verification, and import of recycled plastic content in packaging pursuant to Article 7 of the Packaging and Packaging Waste Regulation (PPWR). We have long supported the transition towards a circular economy.

The Association of Plastic Recyclers (APR) appreciates the opportunity to provide comments on the European Commissions Call for Evidence regarding implementing and delegated acts under Article 7.8 of Regulation (EU) 2025/40.

As the European association representing manufacturers of self-care products, including non-prescription medicines, medical devices, and food supplements, AESGP supports the main objectives of the Packaging and Packaging Waste Regulation (PPWR) to promote circularity and contribute to a more resource-efficient packaging system across the European Union.

Position Stockholm, 2026-09-16 Henrik Oxfall IKEM:s position om Beräkning och verifiering av återvunnet plastmaterial i förpackningar Inledning EU:s förordning om förpackningar och förpackningsavfall (PPWR) innebär att återvunnet innehåll blir en central del av den europeiska omställningen till en cirkulär ekonomi.

Filed in Swedish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Plastics Europe supports the development of a methodology under Article 7(8) that rewards the use of recycled plastics across all packaging components, provides legal certainty through clear definitions, and preserves the flexibility needed for manufacturers to comply efficiently. We continue to support a fuel-use excluded mass balance approach, but urge some changes compared to the SUPD rules.

APPLiA members fully support the transition to a circular economy, the proposed framework for mandating minimum recycled content faces severe structural, technical, and regulatory barriers. Setting rigid, legally binding recycled-content thresholds in the absence of analytical verification methods will impose heavy administrative and financial burdens on compliant EU operators.

Detergents Europe, representing Europes cleaning and hygiene products industry, supports the PPWRs objective of a circular packaging economy. We aim to increase post-consumer recycled (PCR) content in plastic packaging and advance more circular, sustainable solutions in our sector.

The Thailand PPWR Consortium welcomes the opportunity to provide feedback on the development of the methodology for the calculation and verification of recycled content under Article 7(8) of Regulation (EU) 2025/40. Thailand is an important manufacturing and supply-chain partner for the European market, including for plastics, packaging, converted products, parts, components and recycled materials.

FEDIAF, the European Pet Food Industry Federation, welcomes the opportunity to respond to this call for evidence. Our central point is this: pet food packaging is contact-sensitive packaging carrying the full Article 7 obligation, and for the non-PET multilayer flexibles that dominate our sector, chemical recycling counted on a mass-balance basis is the only route to compliant material.

Please find attached joint EPRO and EXPRA feedback to the consultation on the following topics: Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging (implementing act under article 7(8)). Packaging and packaging waste sustainability criteria for plastic recycling technologies (delegated act under article 7(9)).

Contribution to the European Commission Call for Evidence Implementation of Article 7 of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) Plastic packaging – harmonisation of rules for calculating and verifying recycled content in plastic packaging Packaging and packaging waste – sustainability criteria for plastic recycling technologies Schreiner Group GmbH & Co.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PPWR CALL FOR EVIDENCE SK Chemicals' Position on Secondary Legislation for Recycled Content under the PPWR Regulation (EU) 2025/40 on packaging and packaging waste SK Chemicals produces chemically recycled PET (CR PET) and chemically recycled copolyesters through a chemical recycling process in which waste PET is depolymerised to monomer-level intermediates and purified.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Brussels, 16 September 2026 Calculating and verifying recycled content from post-consumer plastic waste INTRODUCTION The document proposes a robust verification methodology aligned with Article 7(8) of the Packaging and Packaging Waste Regulation (PPWR), which requires calculating and verifying recycled content from post-consumer plastic waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Repsol PPWR Article 7(8): Methodology for the Calculation and Verification of Recycled Content in Plastic Packaging Executive Summary and Priority Policy Asks Repsol supports a harmonised EU methodology under Article 7(8) of Regulation (EU) 2025/40 that ensures credible recycled-content claims while enabling the investment needed to meet PPWR targets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response from Dansk Retursystem to the EU call for evidence on PPWR recycled content requirements Dansk Retursystem welcomes the opportunity to contribute to the Commission call for evidence on the implementation of the recycled provisions under article 7 of the PPWR.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

LG Energy Solution Wrocław sp. z o.o. adres korespondencyjny: ul. LG 1 A, Biskupice Podgórne, 55-040 Kobierzyce, Dolnośląskie, Poland NIP: 8961550941, REGON: 364187232, KRS: 0000614214, Kapitał Zakładowy: 4 648 372 000,00 PLN Sąd Rejonowy dla Wrocławia-Fabrycznej we Wrocławiu, VI Wydział Gospodarczy Krajowego Rejestru Sądowego OL/2026/C/001/ Biskupice Podgórne, 15 September 2026 Call for Evidence: Packaging and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Suzuki Motor Corporation welcomes the European Commissions Call for Evidence on recycled content under Articles 7(8), 7(9) and 7(10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback. We support the objective of promoting the use of recycled materials while ensuring a high level of environmental protection and protection of human health.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the call for evidence on harmonisation of rules for calculating and verifying recycled content in plastic packaging.

Henkel supports the objective of increasing recycled plastic content in packaging and establishing harmonized EU rules that are practical, enforceable, and supportive of a circular economy. 1. Workable Recycled Content Calculation and Verification (Art. 7(8)) The methodology must be practical and implementable across complex packaging portfolios.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Unionplast welcomes the European Commission’s objective of establishing harmonised rules for the calculation and verification of recycled plastic content in packaging, for the assessment of the sustainability of recycling technologies and for the verification of the equivalence of recycled materials from third countries.

Filed in Italian · English published by the European Commission

FoodDrinkEurope supports increasing the use of high-quality post-consumer recycled plastic (PCR) in packaging and developing a strong EU market for secondary raw materials. For food and drink packaging, Article 7 PPWR must be implemented in a way that safeguards food safety, product quality, shelf life and food waste prevention, while remaining technically feasible and enforceable across global supply chains.

ANFACO-CYTMA considers that the future implementing act provided for in Article 7(8) of the PPWR laying down uniform rules for the implementation of the requirements on recycled content in plastic packaging should contribute to achieving the objectives of the circular economy and the incorporation of recycled material through a harmonised, transparent and uniformly applicable methodology across the European Union.

Filed in Spanish · English published by the European Commission

The Association of the Chemical Industry of the Czech Republic (SCHP ČR) supports the establishment of a harmonised methodology for calculating and verifying the recycled content of plastics in packaging throughout the EU, in order to ensure the consistent application of the PPWR requirements and to support the objectives of the circular economy.

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050.

The International Carbon Black Association (ICBA) welcomes the opportunity to provide feedback to this call for evidence. We thank you for taking the time to consider our views, concerns and suggestions which we have summarized in the attached document.

Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and brand owners. DI welcomes the opportunity to provide input to the development of harmonised EU rules for calculating and verifying recycled content in plastic packaging.

EDANA, the international association representing the nonwovens industry and its value chain, would like to thank the European Commission for the opportunity to provide input on the following initiatives related to the Packaging and Packaging Waste Regulation (PPWR): Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging; Conditions for importing recycled…

Agbiz makes this submission on behalf of the South African agri-food export sector, focusing on the conditions for using recyclate from third countries (Article 7(10)) and the sustainability criteria for recycling technologies (Article 7(9)), where the risk to agri-food trade is greatest and on which the Commission has expressly invited evidence. What is at stake.

Corporate Public Affairs Contact person: [name removed] [email removed] [phone removed] September 16, 2026 Michelin’s contribution to the call for evidence on the Draft Implementing Act on calculation and verification of plastic recycled content in packaging (art.7.8 PPWR) I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Agbiz makes this submission on behalf of the South African agri-food export sector, focusing on the conditions for using recyclate from third countries (Article 7(10)) and the sustainability criteria for recycling technologies (Article 7(9)), where the risk to agri-food trade is greatest and on which the Commission has expressly invited evidence. What is at stake.

Medicines for Europe, representing the generic, biosimilar, and value-added medicines manufacturers across Europe welcomes the opportunity to contribute to the call for evidence on Plastic packaging harmonisation of rules for calculating and verifying recycled content in plastic packaging. Please find our submission attached.

PCEP welcomes the European Commission's initiative to establish harmonised rules for calculating and verifying recycled content in plastic packaging. As the organisation representing stakeholders across the polyolefin value chain, PCEP considers that a clear, consistent and legally certain methodology is essential to support the implementation of the recycled content requirements under Article 7 PPWR.

Evonik, a European world leader in chemistry, welcomes the opportunity to provide feedback on the public consultation on the harmonization of rules for calculating and verifying recycled content in plastic packaging.

Feedback to the EU-Commission’s Call for Evidence on the PPWR recycled content requirements (Last updated: 15. September 2026) The Food Industries Association of Austria (FIAA) welcomes the opportunity to provide feedback on the minimum recycled content in plastic food and drink packaging according to Article 7 PPWR.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Recycling Europe recommends that the future Implementing Act under Article 7(8) of the PPWR is built around the following principles (further details in attachment): 1) Replicate under PPWR the mass balance calculation methodology agreed under the recently adopted SUPD Implementing Decision.

Current Situation in China Calculation Method: The weight percentage method is adopted, which is consistent with the EU logic. Verification Means: The mass balance method is predominantly used for supply chain ledger audits, with laboratory testing serving as a supplement. It should be noted that some small enterprises have incomplete ledgers, and the traceability chain at the recycling end is fragmented.

Fonterra supports the objective of increasing recycled content in plastic packaging. However, Article 7 must be implemented in a way that protects food safety and product performance, accommodates global and seasonal food supply chains, and does not create a de facto barrier to trade for third-country exporters. 1. Assess material against the actual packaging application.

TCP Circular Submitted by: Subject Date Ref. Ares(2026)8764928 - 15/09/2026 Dr. Christian Lach, Managing Director of TCP Circular Response to call for evidence on the implementing act on Article 7(8) of Regulation (EU) 2025/40 (PPWR) August 26th, 2026 TCP Circular welcomes the opportunity to respond to this call for evidence on the implementing act on Article 7(8) of Regulation (EU) 2025/40 (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Meat Industry Association of New Zealand (MIA) supports the objectives of the EU Packaging and Packaging Waste Regulation (PPWR) to reduce packaging waste, improve recyclability, and strengthen the circular economy. However, implementation must recognise the realities of global food supply chains and the essential role packaging plays in food safety, shelf life, product integrity, and food waste reduction.

SEMI Europe welcomes the opportunity to contribute to the development of harmonised rules for calculating and verifying recycled content in plastic packaging under Article 7(8) of the Packaging and Packaging Waste Regulation.

ALPLA welcomes the call for evidence on the PPWR implementing act under Article 7(8) on recycled-content calculation and verification as a key opportunity to establish a transparent, accurate and workable framework for recycled-content claims across the European Union (EU).

Plastic Energy Technology Ltd (Plastic Energy) welcomes the opportunity to respond to the European Commissions Call for Evidence on the implementing act under Article 7(8) of the PPWR, concerning the calculation and verification of recycled content in plastic packaging.

Encina submits these comments from the perspective of a developer of advanced recycling technology and a prospective supplier of circular feedstocks. Please see the attachment for Encinas complete feedback. Encina is a United States-based technology developer working to produce circular chemicals and decarbonize the global chemicals industry.

bobine is a French chemtech start-up dedicated to the electrification and decarbonization of industrial processes. Its proprietary technology, combining heterogeneous catalysis and electromagnetic induction, runs entirely on electricity and converts the pyrolysis gas or oil derived from post-consumer polyolefin waste (PE/PP), which cannot be recycled today, into virgin-quality monomers suitable for food-contact…

**Please find the feedback in the attachment, too.** NewClimate Institute conducts research on corporate climate accountability. We engage because Art. 7(8) methodology design will determine whether recycled-content claims are credible and comparable and lead to an actual increase in recycled content. This concerns our work in verifying corporate claims on climate and sustainability outcomes.

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish harmonised rules for the calculation and verification of recycled content in plastic packaging under Article 7 of the Packaging and Packaging Waste Regulation (PPWR).

Imperial Brands welcomes the opportunity to contribute to the Commission's Call for Evidence on the implementation of Article 7 of Regulation (EU) 2025/40 (PPWR). Our contribution focuses on the calculation and verification of recycled content, sustainability criteria for recycling technologies and conditions relating to recycled content originating from third countries.

The German Aerospace Industries Association (BDLI) welcomes the opportunity to provide feedback on the planned implementing and delegated acts under Articles 7(8-10) of the Packaging and Packaging Waste Regulation (PPWR). The BDLI represents more than 300 companies across the German aerospace industry.

RCTP welcomes the European Commissions work on the secondary legislation under Article 7 of the Packaging and Packaging Waste Regulation (PPWR) and wishes to highlight the following points: Recognition of closed-loop mechanical recycling in the sustainability criteria; Ensuring that recycled content targets are calculated based on the average of all manufacturing sites; Recognition of existing assessment methods for…

Kolmar Group AG EXTERNAL USE Ref. Ares(2026)8755699 Page 1 of 5 - 15/09/2026 Kolmar Group AG’s response to Call for Evidence on the Implementing Act on Article 7(8) of Regulation (EU) 2025/40 (PPWR) “Mass balance” INTRODUCTION Kolmar Group AG welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(8) of Regulation (EU) 2025/40 (PPWR), which will establish the calculation and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As an industry initiative committed to accelerating circularity for flexible packaging across Europe, the Flexible Packaging Initiative (FPI) welcomes the European Unions ambition to boost the transition towards a circular economy through the PPWRs implementing and delegated acts.

BlueAlp welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(8) of Regulation (EU) 2025/40 (PPWR), which will establish the calculation and verification methodology for recycled content attributed to plastic packaging through mass balance accounting.

The Brewers of Europe highlights in the attached submission five central imperatives: prioritising food-contact safety and availability - Mandated recycled content quotas must be backed by a sufficient, high-quality, and food-grade supply of recyclate (specifically food-grade rPET), including by ensuring that beverage producers retain fair access to rPET generated through well-functioning Deposit Return Systems.

CONAI and COREPLA welcome the contribution to the consultation of the European Commission launched from 14 August to 16 September 2026, on the implementing act provided for in Article 7(8) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) to establish the methodology for the calculation and verification of recycled content in plastic packaging, recovered from post-consumer plastic waste, as well as…

Filed in Italian · English published by the European Commission

EFPIA, representing the innovative, research-based pharmaceutical industry in Europe, welcomes the European Commission's efforts to establish a clear and harmonised methodology for the calculation and verification of post-consumer recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR).

As a leading European mechanical recycler, Veolia welcomes the entry into force of the Packaging and Packaging Waste Regulation, which serves as a decisive lever for packaging circularity in Europe. However, the success of these objectives depends entirely on the robustness of the upcoming secondary legislation. 1.

The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.

CEPE inputs address the proposed sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation. The inputs are intended to provide technical and sector-specific considerations for the development and assessment of the harmonisation of rules for calculating and verifying recycled content in plastic packaging.

Call for Evidence on upcoming implementing and delegated acts relating to recycling and recycled content/materials under the Packaging and Packaging Waste Regulation (PPWR) Ref. Ares(2026)8748943 - 15/09/2026 IBMA, the International Biocontrol Manufacturers Association represents the biocontrol industry, with over 200 member companies globally.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Recycling rates alone do not yet create a circular economy. Functioning source streams, sufficiently available and qualitatively suitable recyclates, economically viable conditions and implementation without additional competitive disadvantages for European plastics processing are crucial: Consider availability as a key condition/economic availability: Availability does not only mean physical existence.

Filed in German · English published by the European Commission

The rules for calculating and verifying recycled content in plastic packaging should support investment in chemical recycling capacity in Europe, including by operators such as Plast Eco Oy. Scaling this capacity requires access to larger volumes of hard-to-recycle plastic waste and a mass-balance framework that recognises the full chemical recycling value chain, including processing and upgrading in refineries.

BEWI welcomes the European Commissions initiative to establish harmonised rules for calculating and verifying recycled content in plastic packaging under Art 7 of the PPWR. BEWI operates across the plastic value chain as a manufacturer of packaging, insulation, construction products & components, as well as a major collector and recycler of post-consumer plastic waste in Europe.

Tobacco Europe contributes to the European Commissions Call for Evidence on implementing Article 7 of the PPWR, supporting its circularity objectives while advocating a practical, technology-neutral approach that recognises robust mass-balance methodologies, ensures traceability and reflects market readiness and packaging-specific requirements.

Comments of the Czech Republic on the Proposed Delegated Act under Article 7(8) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic supports the development of a harmonised methodology for calculating and verifying the recycled plastic content in packaging, ensuring a uniform application of the PPWR requirements across the European Union while enabling effective verification of compliance…

Feedback of Bioeksen Ar-Ge Teknolojileri A.Ş. (Türkiye) manufacturer of CE-marked in vitro diagnostic medical devices (Regulation (EU) 2017/746) placed on the EU market; a downstream user of packaging, not a converter or recycler. Allocate verification to the point where recyclate is incorporated. Recycled content is determined at the converter.

PHOENIX remains supportive of the overall objectives of PPWR and welcomes further dialogue on practical implementation requirements. Against this background, we call for: 1. Clear Allocation of Responsibilities Responsibilities should be clearly defined across recyclers, converters, packaging suppliers, producers, importers, and private label owners.

CONAI welcomes the contribution to the consultation of the European Commission launched from 14 August to 16 September 2026 on the implementing act provided for in Article 7(8) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) to establish the methodology for the calculation and verification of recycled content in plastic packaging, recovered from post-consumer plastic waste, as well as the format…

Filed in Italian · English published by the European Commission

We support the development of a clear, practical and verifiable methodology for calculating and verifying recycled content that can be applied consistently throughout the EU. The methodology should be consistent with the basic calculation framework under Article 7(1) and (2) of the PPWR, including calculation per packaging type and format as an average per manufacturing plant and year.

The Food and Beverage Carton Alliance welcomes the opportunity to contribute to the development of the recycled content calculation methodology under Article 7 PPWR and ensures that the implementing act supports both circularity and competitiveness.

The Malta Business Bureau (MBB) welcomes the opportunity to provide feedback on the upcoming implementing and delegated acts under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). A central challenge highlighted by our business community is that the PPWR framework remains largely tailored to generic, high-volume packaging formats (e.g., standard carton boxes, beverage cans, PET water bottles).

Clean Planet Energy (CPE) is a UK developer converting hard-to-recycle post-consumer plastic waste into purified pyrolysis oil (PPO) and circular hydrocarbon feedstocks. These intermediates can be physically supplied to petrochemical assets and attributed, through an independently audited chain of custody, to new plastic for demanding packaging applications.

The Finnish Meat Industry (Atria Suomi Oyj, HKFoods Oyj and Snellmanin Lihanjalostus Oy) welcomes the opportunity to provide feedback on the implementing act regarding PPWRs article 7 point 8, laying out uniform rules for implementing the requirements for recycled content in plastic packaging. The companies account for the great majority of meat production in Finland. 1.

The draft implementing act will play a critical role in determining how recycled content targets under the Packaging and Packaging Waste Regulation (PPWR) are achieved in practice. It should create a framework that both ensures environmental integrity and supports investments in advanced recycling technologies capable of delivering high-quality recycled materials suitable for demanding packaging applications…

Opinion provided by ADEME – IPC – IFPEN The project financed by ADEME is carried out by IPC and IFPEN until the end of 2026 with a duration of one year. It aims to develop a robust scientific protocol to distinguish virgin PET materials from recycled PET materials.

Filed in French · English published by the European Commission

The act will ensure uniform rules for the implementation of the requirements for recycled content in plastic packaging. This will: reduce the administrative burden for compliance across the EU by providing the recycling industry with the legal clarity it needs to make the necessary investments to help businesses properly implement the obligations on recycled content in plastic packaging by banning non-recyclable…

Filed in Italian · English published by the European Commission

The PPWR mass-balance methodology must reflect integrated chemical recycling operations. Pyrolysis oil requires upgrading and refining to meet petrochemical specifications, and these stages should be recognized as integral parts of the process. The framework should reflect industrial reality and maximize the recycled carbon attributed to new plastics. We recommend that the Commission: 1.

Methodology for the calculation and verification of the PCR share (Article 7(8)) Post-consumer material definition (PCR): The actual terms of reference for the transposing legislation specify that they are to cover the requirements for the content of post-consumer waste materials. This means that post-industrial/pre-consumer technological waste should not be eligible.

Filed in Czech · English published by the European Commission

The Renewable Carbon Initiative (RCI) would like to emphasise that the calculation rules for recycled content in packaging should include clear and workable provisions for mass balance approaches. This is essential to enable the contribution of recycling technologies beyond mechanical recycling, in a manner comparable to the approach established under CID 2026/1425 for single-use PET bottles.

Key messages The implementing measures must be proportionate, auditable and workable for complex industrial supply chains if they are to deliver genuine environmental benefit. A pragmatic mass-balance approach is essential to minimise avoidable compliance costs while maintaining credible verification and environmental integrity.

Brussels, September 2026 EUROPEN’s response to calls for evidence on Article 7 of the Packaging and Packaging Waste Regulation (PPWR) Introduction In August 2026, the EU Commission launched three calls for evidence in relation to Article 7 of the PPWR, which establishes recycled content targets in plastic packaging.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BASF welcomes the opportunity to provide feedback on the recycled content calculation rules for packaging. Achieving PPWR recycled-content targets will require large-scale deployment of chemical recycling alongside mechanical recycling.

Vantaan Energia is Finland's largest Waste-to-Energy company. We are preparing a EUR 1 billion CC(U)S project that will capture the 600 ktpa CO from our plants as well as a residual waste sorting facility that will reduce the fossil share of our feedstock. Europe still faces a significant gap between its ambitions for higher plastic recycling rates and the waste streams that can realistically be recycled today.

JEITA welcomes the opportunity to provide comments on the methodology for calculating and verifying recycled content in plastic packaging under Article 7(8) of the PPWR. JEITA supports the environmental objectives of Article 7 and the establishment of a harmonized, transparent and verifiable methodology.

As an operator of plastic pyrolysis technology based in Poland, we strongly welcome the European Commissions initiative to establish harmonized rules for calculating and verifying recycled content under the PPWR. To unlock vital circular investments across Europe, the final framework must adopt a mass balance methodology that fully reflects the complete industrial value chain.

MGR Packaging welcomes the opportunity to participate in the Call for Evidence on the Implementing Act under Article 7(8) of Regulation (EU) 2025/40 (PPWR). For this purpose, we are pleased to submit the attached document, which we hope will provide regulators with valuable insights from an industrial operator that already manufactures packaging incorporating more than 90% post-consumer recycled (PCR) content.

Japan Cosmetic Industry Association (JCIA) recommends clear, practical and verifiable rules for calculating and verifying recycled content, taking into account the complexity of cosmetic packaging and global supply chains.

We welcome the legal certainty provided by the harmonisation of rules for the calculation and verification of recycled content in plastic packaging. This is essential for the Single Market in packaged goods. Divergent national approaches would create additional administrative burdens that distort competition and result in uncertainty throughout the value chain.

Confcommercio welcomes the possibility to provide input to the public consultation on the rules for the calculation and verification of recycled content in plastic packaging under the Packaging and Packaging Waste Regulation. Please refer to the attached document.

Filed in Italian · English published by the European Commission

Pöppelmann expressly welcomes the objectives of the PPWR. For a successful implementation, the legal acts under Article 7 must be made ecologically sensible, economically efficient and less bureaucratic. In our view, the following points should be taken into account: 1.

Filed in German · English published by the European Commission

bobine is a French chemtech start-up dedicated to the electrification and decarbonization of industrial processes. Its proprietary technology, combining heterogeneous catalysis and electromagnetic induction, runs entirely on electricity and converts the pyrolysis gas or oil derived from post-consumer polyolefin waste (PE/PP), which cannot be recycled today, into virgin-quality monomers suitable for food-contact…

Chemical Recycling Europe (CRE) welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(8) of Regulation (EU) 2025/40 (PPWR), which will establish the calculation and verification methodology for recycled content attributed to plastic packaging through mass balance accounting.

DR. JOHANNES HEIDENHAIN GmbH supports harmonised and practicable rules for recycled content in plastic packaging. The attached position paper highlights the need to recognise industrial closed material loops and to avoid rigid PCR-only requirements that create shortages or displace suitable PIR.

Helix Projects BV welcomes the opportunity to respond to the Call for Evidence on the Implementing Act on Article 7(8) of Regulation (EU) 2025/40 (PPWR), which will establish the calculation and verification methodology for recycled content attributed to plastic packaging through mass balance accounting.

Opinion of the Czech Traditional Trade Association: In our view, the Commission should not create a completely new “greenfield” certification apparatus, but should link existing established standards (EN 15343, RecyClass, EuCertPlast) to the forthcoming Digital Product Passport (DPP).

Filed in Czech · English published by the European Commission

GS1 is a neutral, not-for-profit standards organisation that develops and maintains global standards for identification, data capture and data sharing. GS1 standards are used across sectors and jurisdictions to support supply-chain efficiency, traceability, regulatory compliance and interoperability.

FEDIMA represents European manufacturers and suppliers of ingredients to the bakery, confectionery and patisserie industries. FEDIMA welcomes the opportunity to provide feedback on this initiative and supports the establishment of harmonised EU-wide rules for the calculation and verification of recycled content in plastic packaging.

Fecc welcomes the European Commissions initiative to harmonise the rules for calculating and verifying recycled content in plastic packaging. As representatives of the European chemical distribution sector, we support a clear, reliable and proportionate framework that can work across complex chemical value chains and facilitate the uptake of recycled materials.

The Commission is currently assessing under Regulation (EU) 2025/40 the establishment of methodologies for the verification of recycled content. The strategic premise here must be to rely on certification schemes that are already established and functioning in the market, rather than building inefficient parallel regulatory structures.

Filed in German · English published by the European Commission

Introduction ECP4 (the European Composites, Plastics and Polymer Processing Platform) welcomes the opportunity to contribute to the Call for Evidence on the implementing and delegated acts to be adopted under Article 7 of Regulation (EU) 2025/40. Established in 2012, ECP4 brings together research and technology organisations and industrial actors across the composites, plastics, and polymer processing value chain.

Data on imports of plastic recyclates: - What is the estimated annual volume of recycled content imported into the EU from third countries? (estimates by polymer type where available). The attached Swedish report, Plastkartläggning 2023, provides the most recent in-depth description available.

VCI - Position PPWR Article 7 (8) Shared Objectives Amid Different Technical Approaches The implementation of Article 7(8) PPWR involves a number of complex technical questions, including chain-of-custody approaches, attribution methodologies, aggregation levels and verification requirements.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The introduction of harmonised rules for the calculation and verification of recycled content in plastic packaging is strongly welcomed. An EU-wide uniform approach is essential for legal certainty, transparency and a level playing field in the Single Market.

Filed in German · English published by the European Commission

The RecyClass - https://recyclass.eu/ - certification provides a solid baseline for the verification of the michanically recycled content. This certification is now used worldwide by both machine recyclers (Recycling Process) and processors and producers who use machine recyclates for packaging production (Recycled Plastics Traceability).

Filed in Dutch · English published by the European Commission

You are killing small businesses with these new rules. Micro businesses that sells in and out of the EU cannot afford the same as the huge corporations, they shouldn't be in the same bracket. Every time you put new rules in it's another nail in the coffin for small businesses. It's not fair to bring in these new rules without exemptions for those of us who are trying our best to make a living on our own.

The calculation of the recycled content should be based on the EN 15343 standard which clearly states the way to calculate the recycled content with a distinction between PCR and PIR and the ISO 22095 standard ensures the complete chain of custody. These certification systems also take REACH compliancy into consideration.