First establish whether Article 7 applies to the packaging. Then determine whether it is contact-sensitive packaging, a single-use plastic beverage bottle or other plastic packaging.
The four main thresholds in Article 7
Regulation (EU) 2025/40 sets minimum recycled content recovered from post-consumer plastic waste. Four main levels are specified for the first stage of Article 7:
- 30% – for contact-sensitive packaging made from PET as the major component, excluding single-use plastic beverage bottles;
- 10% – for contact-sensitive packaging made from plastics other than PET, excluding single-use beverage bottles;
- 30% – for single-use plastic beverage bottles;
- 35% – for other plastic packaging covered by Article 7.
First check whether Article 7 applies
A common mistake is assigning a threshold solely by material, such as “PET = 30%”. This is an oversimplification. Before determining the level, check the full scope of Article 7, including exemptions and specific rules for particular packaging categories.
A useful classification sequence is: packaging type → application → contact-sensitive status → main material → any beverage bottle status → exemptions.
PCR and PreCR are different
Article 7 links the required levels to recycled material recovered from post-consumer waste. Pre-consumer material may qualify as recycled material, but it does not automatically replace the PCR share required by this provision.
For example, 20% PCR plus 20% PreCR gives 40% total recycled content, not 40% PCR.
How is the level calculated?
The PPWR provides for minimum content to be calculated as an average per manufacturing plant and year, by the packaging types and formats listed in Annex II. The detailed calculation and verification methodology is linked to Commission implementing acts.
The 2030 deadline uses a later-date rule
The first-stage requirements apply from 1 January 2030 or three years after the implementing act referred to in Article 7(8) enters into force, whichever date is later. Compliance planning must therefore monitor both the PPWR itself and the implementing acts being published.
What can you prepare now?
- clear classification of the packaging and its plastic parts;
- component weights and data on the materials used;
- a distinction between PCR and PreCR;
- supplier data and the origin of recycled material;
- a system for compiling data by plant and reporting period;
- control of changes to materials and design.
Key point
The correct threshold cannot be determined from the polymer alone. Classify the packaging correctly first, then assign the relevant PCR requirement.