European Commission Opens Evidence Call On PPWR Recycled Content Calculation Rules

The European Commission opened a call for evidence on 14 August 2026 for uniform rules to calculate and verify recycled content in plastic packaging under Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation. The future implementing act will shape how recyclers, converters, importers, brands and auditors demonstrate compliance across the European Union.

Feedback remains open until 16 September 2026 at 11:59 pm Brussels time. The Commission gives the fourth quarter of 2026 as indicative timing for the package of acts, but no PPWR-wide calculation method has yet been adopted. Businesses should not present a preferred approach as settled law.

PPWR Recycled Content Evidence Moves Towards One EU Method

The initiative, referenced Ares(2026)7895997, says a common method should reduce divergent national practices, give the recycling sector investment clarity and help businesses implement plastic-packaging recycled-content obligations. It is an implementing decision rather than an amendment to the PPWR itself.

The previous position was incomplete rather than unregulated. The PPWR establishes the legal recycled-content framework and future minimum percentages, while the Commission still needs to specify how economic operators calculate and verify the figures. The new trigger is the formal opening of evidence gathering for that operational method.

The call covers three related acts: calculation and verification for recycled content collected and recycled in the EU, sustainability criteria for plastic recycling technologies, and equivalence conditions for recycled material from third countries. The calculation measure remains a distinct legal instrument within that package.

Manufacturers Need Auditable Material Data

The method could determine how businesses treat data flows, chain of custody, aggregation, evidence retention, independent audits and technical documentation. The Commission also identifies production economics, output quality, energy use and environmental performance as relevant considerations. It has not yet confirmed how each issue will be resolved.

Packaging manufacturers and brands should map where recycled-content claims originate and which records follow material through polymer production, compounding, conversion and filling. Recyclers and waste operators should test whether output certificates reconcile with input, yield and quality records. Importers will need evidence that can withstand EU verification, particularly where records are produced outside the Union.

A single verification method may move commercial value towards recyclers and software providers that can produce traceable, assurance-ready data. It may also expose contractual gaps where buyers receive a percentage claim without rights to underlying evidence or audit access.

What Organisations Should Do Before 16 September

Companies should compare existing mass-balance or physical-content methods, identify packaging formats with weak supplier data and document the cost of independent verification. Trade associations can support submissions with real production examples, but comments should distinguish preferred policy design from current legal duties.

Procurement contracts should define recycled-content terminology, evidence retention, change notification and audit rights. Laboratories and assurance providers should assess whether current sampling, calculation and certification procedures can be applied consistently across multiple packaging formats and jurisdictions.

What Happens Next

After the evidence call, the Commission intends to prepare draft acts and supporting analysis before adoption. Businesses should monitor calculation rules alongside the separate work on recycling technologies and imported recycled materials because the measures may interact without being legally interchangeable.