New European legislation requires that, from 2030 onwards, all plastic packaging must contain recycled content derived from post-consumer packages. At present, this is only feasible for PET packaging. To meet these new requirements, significant changes are necessary.
In an effort to create a more circular economy, the EU has introduced new packaging regulations. Many packaging companies still opt for the cheaper and more convenient choice of virgin plastic. This contributes to climate change and planetary pollution. The European Packaging and Packaging Waste Regulation (PPWR) was published on January 22, 2025, and will come into effect mid-2026. The big picture is clear: encourage reusable packaging, minimize packaging material use, produce packaging that is more recyclable and contains more recycled content, and eliminate hazardous substances. While the PPWR’s intent is commendable, its practical implementation on some topics presents significant challenges, to say the least. This article takes a closer look at the requirement to use recycled content in all plastic packaging by 2030 (!). Given current technologies, existing legislation, and production systems, this is difficult to achieve. Achieving these targets will require urgent and multiple transitions in technology development and systemic change. The fact that these recycled content targets must be met within just five years, while technology development takes decades, approval processes for novel decontamination technologies take seven years, and everything must also be practically implemented, makes this aspect of the PPWR seem almost impossible from the outset.
The previous European Commission rightly concluded that earlier Packaging and Packaging Waste Directives (PPWDs) failed to reduce packaging use or packaging waste. Furthermore, waste management was not optimal in many member states. In response, the EU decided to intervene. The result is the PPWR – now a regulation (a binding law), rather than a directive (a guideline). The PPWR consists of 71 articles, 124 pages, and 8 annexes. Covering all would be excessive. In this article we therefore focus on Article 7: ‘minimum recycled content in plastic packaging.’
The regulation distinguishes between contact-sensitive packaging (for food, animal feed, pharmaceutic applications, and cosmetics) and non-contact-sensitive packaging (everything else). Contact-sensitive packaging is further divided into categories, each with its own targets for recycled content in 2030 and 2040. These targets apply to post-consumer recycled material, hence sourced from households. The targets apply to all plastic packaging (with only a few exceptions).
Table: Targets for minimum recycled content in all plastic packaging
Contact-sensitive
Non-contact-sensitive; Detergent bottle, screw box…
For contact-sensitive packaging, only the requirement for recycled content in PET beverage bottles and trays is feasible using existing mechanical recycling technology. For all other packaging types, the required technology does not yet exist, or the target percentages are unattainable with the current packaging designs, recycling systems, and food safety legislation. Even for non-contact-sensitive packaging, which does not need to comply with food-contact material legislation, the targets are highly ambitious: the current recycling system cannot always produce recycled plastics with the required properties (such as transparency, odor neutrality, or specific melt strength). In short, there’s a lot of work to be done.
Mechanical recycling processes for plastic packaging waste currently dominate in Europe. These processes keep the plastic intact and consist of, sorting, shredding, and washing it before reprocessing it into new plastic. Mechanical recycling offers a relatively high material yield (55-80%), enabling Extended Producer Responsibility (EPR) organizations such as Verpact to meet EU recycling targets (50% by 2025 and 55% by 2030). However, most plastic packaging has components (labels, caps, adhesives, inks, coatings, etc.) that are very difficult to separate. This often results in lower-quality recycled plastic (with odor, discoloration, reduced strength, etc.), and in some cases, certain packaging components can even generate toxic substances during recycling. Nevertheless, through strict input control with an extensive AI (artificial intelligence) sorting process, some mechanical recycling companies manage to select only the containers from the lightweight packaging (LWP) waste that are well recyclable and then clean these to the maximum extent to produce a nearly transparent HDPE or PP product. Plastics recycled as such are used in personal care packaging (which is also contact-sensitive, but has less stringent approval requirements than food packaging).
PET trays from separately collected LWP waste are currently mechanically recycled into two different grades of recycled PET (rPET), one type that is nearly transparent and another grade that is light-colored and hazy. Both grades have a positive assessment from EFSA (European Food Safety Authority) and thus may be used as food-safe recycled plastics in food packaging.
Mass yields are currently limited due to the limited share of PET trays that are well-recyclable. Higher yields and fully transparent grades of rPET are potentially achievable with depolymerization; this involves converting polymers back into monomers. However, this is also a relatively expensive technology and therefore hardly used. Depolymerization processes (such as Ioniqa's process) do not require EFSA assessment, so the resulting rPET may be applied directly as a food-safe material. The future process of CuRe Technology produces oligomers as intermediates and thus does need to go through the approval process for a new (novel) recycling technology.
The vast majority of plastic packaging is made from PE or PP. For these plastics, in addition to mechanical recycling, various thermochemical recycling technologies have been developed, including pyrolysis. Pyrolysis oil can be purified and co-processed with crude oil to obtain a multitude of products (including ethylene and propylene), from which new packaging plastics can be made. This pyrolysis technology, along with sorting and purification processes, is well-developed, with several test facilities already in place. This could be expanded on a larger scale. The resulting plastic is made from monomers and is considered food-safe. However, pyrolysis is an energy-intensive process, where part of the produced gases is used to fuel the system, resulting in a mass yield of around 60%. The process consists of pre-sorting, pyrolysis, post-processing and cracking; losses occur in each step and therefor the plastic yield is low. Additionally, EPR organizations are hesitant to supply pyrolysis plants with sorted plastics since the European Commission has yet to define whether pyrolysis-derived material counts towards official recycling rates.
Packaging companies, with support from research institutions such as Wageningen University & Research, must now develop strategies to meet the recycled content demands. Multiple strategies will be needed simultaneously. The simplest approach is switching from PE or PP to PET, provided the PET packaging is well-designed for recycling and does not contain problematic components like direct printing, in-mould labels, or pigments. However, most PE and PP packaging cannot be replaced with PET due to functional requirements. For instance, microwaveable packaging is possible with PP but not with PET. However, these PE and PP packages can be made more suitable for high-quality mechanical recycling and thermochemical recycling. Several recycling checks and design-for-recycling guidelines are already available. Knowledge about this is constantly developing to make these checks and guidelines more comprehensive. For example, it was recently discovered that nitrocellulose binder in inks, azo colorants (synthetic colorants) and aromatic polyurethane adhesives can form toxins during thermal reprocessing (extrusion). Tackling this, RecyClass updated its design-for-recycling guidelines.
The formal methodology that packaging companies must use to determine whether their packaging is recyclable under the PPWR is still being developed and will be published in a forthcoming delegated act. This will undoubtedly incorporate ongoing research and insights. As a result, packaging companies will need detailed knowledge of the substances present in all components of their packaging. This requirement is reinforced by the PPWR’s ban on hazardous substances in packaging (Article 5) and, specifically, the ban on PFAS in food packaging. This is also part of the declaration of conformity that packaging companies must prepare (Article 39 of the PPWR). It sounds logical, but this requires suppliers to disclose exactly what is in their inks, coatings, adhesives, labels, and additives—an unprecedented level of transparency in an industry where trade secrets and complex supply chains have long obscured such details. A system change is needed here.
Rigid PE and PP packaging faces a specific challenge: a lack of standardization. In our free market economy, packaging freedom is a great asset for marketeers to sell products. It also results in a vast array of non-uniform packaging materials with not only different shapes, colors, and printing but as a basis different grades of PE and PP. This hinders high-quality mechanical recycling but is less problematic for thermochemical recycling. Packaging companies could boost high-grade mechanical recycling of PE and PP by marketing more standardized packaging. Packaging designs could also be improved for thermochemical recycling by using other pigments, labels, printing and adhesive layers that contain fewer undesirable elements (oxygen, nitrogen, sulfur, halogens, metals, etc.). The ban on the use of PFAS in food packaging certainly helps in this regard.
Recycling companies can only survive if they can sell high-quality recycled plastic at a good price or market products themselves from lower-value recycled plastics. The announced mandatory use of recycled content is extremely important to them. Mechanical recycling companies want to make more high-quality PE and PP recycled plastic, but are now constrained by the designs of current packaging. Although these recycled plastics contain very few (semi)-volatile substances, it cannot be guaranteed that no toxic substances could be present in concentrations less than 0.05 µg/kg. No conclusive analytical methods are available for this. Since this is the expected requirement for food-safe recycled plastic from PE and PP, recycling companies are hesitant to invest in recycled PE and PP products for food packaging. This is understandable given the high costs (many millions of euros in analysis costs), long duration (7 years) and the uncertain outcome of a novel technology application to EFSA under EU/1616/2022. The chance of approval for food-safe use of PE and PP packaging from a LWP collection system now seems slim, but there may be an opportunity for packaging coming from mono-collection systems such as deposit refund. This makes recyclers keen to see more packaging returned through mono-collection systems. However, this clashes with the interests of supermarkets who would then have to facilitate this. Thermochemical recycling companies have been pressing the European Commission for several years in vain for clarity around the calculation rules - what counts as recycled material? If such clarification is provided and these calculation rules support the business, a lot of capacity will have to be added in the short term. In the meantime, testing facilities can use the difficult-to-recycle sorting products and the various wastes from sorting and recycling to conduct tests and improve their processes.
For EPR organizations, meeting all legal requirements will be even more challenging. Eco-modulation (lower fees for well-recyclable packaging) is one of the few incentives available to encourage companies to improve packaging design. On the supply side, EPR organizations will start directing sorted packaging waste towards recycling facilities that produce high-quality recycled plastics. By 2030, packaging companies will be pushing EPR organizations to provide access to food-safe or high-quality recycled plastic. This will create a new dynamic in which EPR organizations can put pressure on packaging companies to improve and standardize their designs.
Meeting the PPWR’s requirements for minimum recycled content in plastic packaging by 2030 will be extraordinarily difficult. A complex mix of existing guidelines, upcoming delegated acts, and calculation methodologies; all affect the feasibility of ultimately achieving these PPWR targets – and more generally – a more circular economy for plastic packaging. One thing is clear: the PPWR will fundamentally reshape the packaging industry. It will become increasingly dependent on recyclers and petrochemical companies. Simultaneously, packaging companies will increasingly demand transparency from suppliers about the substances present in all packaging components . Moreover, the relationship between EPR organizations and packaging companies is expected to become increasingly close as mutual dependencies are going to increase significantly.
Finally, the authors note that the PPWR regulation primarily focuses on current (fossil-based) packaging materials. While these offer excellent product protection, they also contribute to irreversible plastic pollution of the planet. This problem cannot be solved solely by increasing recycling and reuse. Article 8 of the PPWR mentions only one study on bio-based packaging materials, but there is no further stimulus for their development. The Netherlands appears to be taking the lead in this area, as the proposed National Circular Plastics Standard will require a minimum share of recycled and/or bio-based plastic in packaging.
Source: Vakblad Voedingsindustrie 2025
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