Preparing for Article 7 means knowing which packaging parts are included in the calculation, how much is PCR, where the material originates and how the data will be aggregated and verified.
Article 7 focuses on PCR
The minimum levels concern plastic recovered from post-consumer plastic waste. Pre-consumer material can increase total recycled content, but it does not automatically replace the required PCR share.
Step 1. Establish whether the requirement applies
First check the scope of Article 7 and any exemptions. Not every plastic application should be classified solely by its polymer.
Step 2. Assign the correct category
In the first stage, the PPWR specifies different thresholds for contact-sensitive packaging, single-use plastic beverage bottles and other plastic packaging.
Step 3. Define the material data
For every part included in the calculation, record the material, weight, source of recycled material, PCR share, supplier and manufacturing plant. Control these data against the same product version.
Step 4. Establish traceability
The supplier certificate, purchasing document and inventory data should lead to the material actually used in production. A percentage stated in a supplier specification is not sufficient on its own to establish a complete evidence system.
Step 5. Prepare an aggregation system
The PPWR provides for levels to be determined by manufacturing plant, year and the relevant packaging type and format. The ERP system or another data source should allow this information to be compiled.
Step 6. Monitor the implementing methodology
The detailed calculation, verification and documentation methods are linked to implementing acts. A company's internal method should not be presented as the final PPWR methodology unless it meets the applicable implementing provisions.
Step 7. Separate certification from legal responsibility
Recycling Process or Recycled Plastics Traceability can provide valuable evidence about material origin and content. Responsibility for meeting Article 7 nevertheless remains with the relevant economic operator.
Key point
Preparing for Article 7 requires a data system, not just purchasing PCR. A company should be able to demonstrate the material source, physical flow, calculation method and consistency of the values with actual production.