The European Commission has published a call for evidence on minimum recycled content quotas under the Packaging and Packaging Waste Regulation, covering calculation and verification methods and the use of imported recyclate. The call is divided into three acts: the calculation and verification of plastic recycled content in packaging; sustainability criteria for plastic recycling technologies; and conditions for importing plastic recyclates or articles with incorporated plastic recycled content from non-EU countries.

The call seeks to establish the estimated annual volume of recycled content imported into the EU from third countries, broken down by polymer type where available, along with the proportion of plastic packaging placed on the EU market that originates from third countries and which of those countries are the main sources of recycled plastic or recycled content imported into the EU. It also asks what verification, certification or chain-of-custody schemes are currently used to verify the origin, traceability and recycled content of plastics recovered from collected or recycled post-consumer plastic waste.

Stakeholders from the European Union and beyond are invited to provide feedback via the Have Your Say portal, including relevant published and pre-print scientific research, analyses and data. The feedback period will last until 16 September 2026 (00:00 Brussels time).

While an impact assessment will not be carried out, the Commission plans to collect and analyze evidence around expected costs, benefits, feasibility, proportionality, enforceability, impacts on SMEs, market surveillance needs, international supply chains, and implications for third countries. This is set to inform the preparation of the new legal measures and will be set out in a Commission staff working document.

The Commission cites the supporting study for the revision of the previous Packaging and Packaging Waste Directive, which identified a low uptake of recycled content and the necessity of a harmonized definition and method of measurement, including reporting and verification. It fears that market operators and authorities would rely on different calculation methods, evidence requirements and verification practices if harmonized rules are not put in place – creating uncertainty for businesses, making enforcement more difficult, and potentially undermining the Single Market’s level playing field. The supporting study also highlights concerns around the availability and quality of recycled plastics, supply-chain cooperation, administrative burdens and data flows.

Conversely, the three acts of the call for evidence are expected to secure legal certainty, consistent enforcement, demand for high-quality recycled plastics and a level playing field for packaging on the Single Market. It is set to ensure that any claims made about recycled content are reliable, and that the recyclate used to achieve the Packaging and Packaging Waste Regulation’s recycled content quotas is sourced under ‛credible environmental and health-protection conditions.’

The initiative is set to align with the Commission’s effort to streamline various methods of carbon accounting under the Deep Cleaning Action Plan.

The Commission aims to ensure that the relevant implementing and delegated acts are ‛verifiable and enforceable’ by the time they are adopted on 31 December 2026. Yet industry professionals such as Martin Engelmann, director general at the German Plastic Packaging Association, expect the call for evidence to delay recycled content requirements by at least several months.

“Even though the Commission appears to be sticking to this timeline so far, it is highly unlikely that they will be finalized in time,” Engelmann said in a LinkedIn post. “In the parallel procedure to establish methods for calculating the recycled content of batteries, the Commission did not submit a first concrete proposal for consultation until shortly before the legal deadline.”

Engelmann also states that paragraphs 8-10 under Article 7 of the Packaging and Packaging Waste Regulation, which were fully amended during the trialogue, are incomplete and, in some cases, contradictory – arguing that the challenge of developing a workable and non-discriminatory legal framework from these provisions is therefore significant.

The news comes after the first legal measures set out under the Packaging and Packaging Waste Regulation, including PFAS restrictions and Declaration of Conformity requirements, were officially enforced last week.

The Commission recently set out a methodology to calculate, verify and report chemically recycled content in single-use PET beverage bottles. The move was expected to level the playing field and ensure investment security for the plastics recycling sector.

The Have Your Say portal was previously used to carry out a public consultation for calculation, verifying and reporting rules, which were hoped to standardize chemical recycling across the EU and bring the bloc closer to the recycled content targets set out in the Single-Use Plastics Directive.