Article 7 is the part of PPWR that compels real change in how plastic packaging is sourced. Recyclability (Article 6) measures whether packaging can be recycled; Article 7 closes the loop by requiring that a measured fraction of every plastic packaging item placed on the market has already been recycled. The thresholds are binding, escalator-style, and verified through chain-of-custody mass balance — not nominal marketing claims.
The thresholds, by category
Article 7(1) sets the headline percentages. They apply at the level of the obliged operator, averaged across each packaging category and plastic type placed on the EU market in a calendar year:
Category
1 Jan 2030
1 Jan 2040
Contact-sensitive plastic packaging made of PET
30%
50%
Contact-sensitive plastic packaging other than PET
10%
25%
Single-use plastic beverage bottles
30%
65%
Plastic packaging other than the above
35%
65%
Compostable exemptions
Article 7(3) exempts plastic packaging that consists entirely of compostable plastic (conforming to Article 8 and EN 13432) from the recycled-content thresholds. Tea bags, fruit stickers, and certain coffee pods qualify. Most consumer plastic packaging does not.
Per-unit vs averaged
The thresholds apply to average performance per category, not per unit. A manufacturer placing 100 PET water bottles on the German market in 2030 can have 70 bottles at 0% PCR and 30 bottles at 100% PCR — average 30% — and still comply. The averaging is calculated per plastic type within each category, per year, per obliged operator.
What counts as recycled content
Article 7(8) defines “recycled content” tightly. To count toward the threshold, the material must meet three criteria:
Post-consumer origin. The recyclate must come from packaging or other products that have completed their first use by an end consumer. Pre-consumer (factory off-cuts, scrap) does not count toward Article 7.
EU-collected or qualifying third-country origin. Recyclate from third countries counts only if the source country’s collection and recycling system has been recognised as equivalent under a delegated act.
Documented chain of custody. The recyclate must be traceable from collection through to inclusion in the final packaging, with sufficient documentation to substantiate the claim.
Chain of custody and mass balance
Most plastic recycling processes mix recycled and virgin feedstock in a single line — segregation is technically impossible above a certain throughput. Article 7(11) authorises a mass-balance chain-of-custody approach to allocate the recycled attribute to specific output units.
The mass-balance principle: if 30% of inputs to a polymer plant in a given period are post-consumer recyclate, the operator can allocate the recycled attribute to 30% of outputs by mass. Allocated outputs can then be sold to packaging manufacturers as “30% PCR” material, even though no individual molecule is provably recycled.
Approved schemes
The Commission’s delegated act under Article 7(11) specifies recognised chain-of-custody schemes. As of 2026, the leading schemes used in practice:
Scheme
Operator
Use case
ISCC PLUS
International Sustainability and Carbon Certification
Polymer producers using mixed feedstock incl. chemical recycling.
Both routes count toward Article 7, with conditions. The distinction matters because food-contact applications historically required mechanical recycling under EFSA opinions; the Commission has increasingly accepted chemically recycled feedstock under specific opinions.
Mechanical recycling — washing, sorting, shredding, extrusion of post-consumer plastic. Outputs a recyclate with measurable physical PCR content. Established food-grade approval pathway under EFSA for PET (bottle-to-bottle since 2008).
Chemical recycling (pyrolysis, depolymerisation, dissolution) — recovers monomers or hydrocarbon feedstock that re-enters polymer production. Allocated via mass balance. Increasingly accepted by EFSA for food contact; the basis on which much of the post-2030 supply will scale.
→ Carbonorm tracks PCR % per SKU, validates the supplier’s chain-of-custody certificate, flags pre-consumer claims as ineligible for Article 7, and computes your portfolio average against the 2030 and 2040 thresholds.
How to substantiate a claim
For every SKU where you assert recycled content under Article 7, the technical documentation file (Article 12) must contain:
A supplier declaration stating the post-consumer recyclate percentage in the supplied material, the scheme under which it is certified, and the certificate number.
The scheme certificate itself (e.g. ISCC PLUS), valid as of the production date of the packaging.
Mass-balance audit records showing the allocation period and the volume of certified PCR allocated to the specific batch.
A portfolio averaging worksheet at the obliged-operator level demonstrating that the category-level threshold is met.
Five common Article 7 mistakes
Counting pre-consumer scrap. Factory off-cuts, regrind from your own production, and post-industrial film are not post-consumer. They do not count.
No chain-of-custody scheme. A supplier’s self-declared 30% PCR claim is unsubstantiated. The mass-balance certification (ISCC PLUS, EuCertPlast) is what auditors look for.
Per-SKU compliance assumed. Thresholds apply to category averages, not individual SKUs. Allocating high-PCR material to a few SKUs while keeping the majority at 0% can still comply if averaged correctly.
Confusing recyclability with recycled content. A grade-A PET bottle (Article 6) can have 0% recycled content. Article 7 is a separate, additional obligation.
Threshold creep underestimated. The 2040 thresholds are 50–65%, more than double the 2030 levels. Plan supply-chain transitions on a 2030 → 2035 → 2040 trajectory, not a one-step 2030 push.