Recycled-content targets are becoming a material qualification problem

The dates and categories matter

Regulation (EU) 2025/40 was published on 22 January and entered into force twenty days later. Its general application date is 12 August 2026, while recycled-content provisions have their own timetable. Entry into force should therefore not be described as an immediate requirement to meet all the future percentages.

Article 7 sets initial targets of 30% for contact-sensitive PET packaging other than single-use beverage bottles, 10% for other contact-sensitive plastic packaging, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. These apply from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later, with specified exceptions.

The calculation concerns post-consumer recycled content, by packaging type and format, averaged per manufacturing plant and year. A buyer should establish the applicable category and method before treating a percentage printed on a supplier’s brochure as sufficient evidence.

The Council’s December adoption announcement also places recycled content alongside reuse, packaging minimisation and restrictions on substances of concern. Increasing the recycled fraction is consequently one part of a wider packaging decision, rather than a complete measure of environmental or regulatory performance.

Start with the intended application

A clear bottle, a protective transport component and a food-contact tray do not ask the same things of a polymer. Their appearance, processing behaviour and service conditions can differ. A qualification plan should begin with what the finished package must do, then assess whether the proposed recycled material can support it.

An illustrative converter may find a resin that performs well in a simple moulding trial but behaves differently at the intended production rate. Another material may meet the mechanical requirement while failing an appearance specification. Neither outcome can be predicted from recycled percentage alone.

The trial should therefore use an agreed acceptance specification and representative operating conditions. The supplier and converter should decide which properties are essential, how they will be measured and how variation between deliveries will be handled. This creates a basis for interpreting the results instead of declaring success from one attractive sample.

The approach also prevents a common commercial misunderstanding: a material described as suitable for one application has not necessarily been qualified for every packaging format made from the same polymer family.

Food-contact safety requires process evidence

EFSA’s July 2024 scientific guidance addresses the safety assessment of post-consumer mechanical PET recycling processes for food-contact materials. It explains how applicants should describe inputs, the recycling process and the evidence supporting decontamination.

Its challenge-test guidance asks for representative materials and operating conditions, with an explanation of how smaller-scale testing relates to the industrial process. The assessment concerns the process and its stated conditions, not merely the visual cleanliness of a batch of flakes or pellets.

This is a technical guidance document for a defined recycling technology and use. It should not be generalised into a claim that all recycled polymers are safe, or that all are unsafe. A buyer needs to understand the relevant process, evidence and authorised conditions for the material it intends to use.

The operational implication is to ask whether the proposed supply corresponds to the process and conditions covered by the supporting documentation. A change in feedstock or processing arrangement should have an established review route, rather than be treated as an ordinary purchasing substitution with no technical consequence.

A US reference highlights the same distinction

The US Food and Drug Administration’s 2021 chemistry guidance identifies residual contaminants and their potential migration into food as central considerations for recycled plastic used in food packaging. It separately notes that microbial contamination and structural integrity are important but outside that document’s scope.

This is US guidance, not a substitute for EU requirements. Its relevance to a materials buyer is the separation of evidence: a chemistry assessment does not automatically establish the mechanical performance of the package, and a successful mechanical trial does not settle the chemistry question.

An international supplier should therefore avoid presenting a single document as universal market approval. The customer needs to know which jurisdiction, process and intended use the evidence addresses. That precision can reduce repeated questions later in qualification and prevent an unsupported claim from entering the product specification.

The same discipline applies to the finished article. A resin supplier’s evidence is an input to the converter’s assessment, not a reason to ignore the effects of the actual formulation and manufacturing process used for the package.

Verify what the percentage represents

ISO 22095:2020 provides general terminology and models for chain of custody. Its public scope cautions that a chain-of-custody framework alone does not prove a material’s characteristics. For recycled-content claims, the buyer should identify the applicable claim and evidence rather than rely on the mere existence of a tracking system.

The receiving process should connect the supplier’s declaration to the delivered material and the relevant production records. It should also establish how a correction is communicated. If a declaration is revised after dispatch, the converter needs to determine which stock and finished products may be affected.

An illustrative business might maintain excellent purchase invoices but lose the link when two deliveries are combined in a silo. Whether that arrangement supports the intended claim depends on the applicable accounting and control method. The point is to resolve the method before production, rather than reconstruct it only when a customer requests evidence.

A clear data agreement can identify the reporting period, unit, material category and supporting records expected from the supplier. Consistent definitions make commercial comparisons more meaningful and reduce the risk of confusing different kinds of recycled-content statements.

Qualify a supply relationship, not one sample

A one-off trial can show that a material worked under the conditions tested. It does not establish how the supplier will control variation over a year of deliveries. The qualification discussion should therefore include routine controls, notification of changes and a process for handling an out-of-specification batch.

The converter can examine whether incoming checks are matched to the failure modes that matter for its product. A property that is easy to measure is not necessarily the property that determines performance. The test plan should be designed with the relevant technical specialists and linked to the actual acceptance criteria.

Commercial terms can support that arrangement by distinguishing a quality issue from an ordinary price negotiation. The parties should know who investigates a problem, what information is available and how production is protected while the cause is assessed. Those responsibilities become more valuable as dependence on a qualified recycled feedstock increases.

A second source may improve resilience, but it needs its own qualification. Two suppliers offering the same nominal recycled percentage should not be assumed interchangeable without evidence about the properties and process relevant to the application.

Buy against the future requirement carefully

The new regulation gives suppliers a reason to prepare, but it does not justify treating every future implementation detail as settled today. Buyers should keep their assumptions dated and review them as the required methods and guidance develop.

The strongest preparation combines three records: evidence supporting the recycled-content claim, evidence of suitability for the intended use and evidence that production can hold the required performance. Each answers a different question. Together they provide a more credible purchasing basis than a percentage alone, and a clearer route from regulatory ambition to a package that can be made and used reliably.