New EU rules for calculating and verifying recycled plastic content in PET beverage bottles entered into force on 23 July 2026.

The 25% recycled-content target itself is not new. It has applied since 2025 under the Single-Use Plastics Directive. The new methodology clarifies which materials count, which parts of the bottle must be included and what evidence is needed across the supply chain.

For companies placing bottled drinks on the EU market, a stated rPET percentage is therefore not always enough. The recycled material must also qualify under the EU calculation rules.

Is the 25% requirement assessed for every bottle?

At EU level, the target is calculated as an average for all PET beverage bottles placed on the market of each Member State during a calendar year.

It does not necessarily mean that every individual bottle must contain exactly 25% recycled plastic.

However, national implementation may require compliance or data collection at a more detailed level, such as per economic operator or product portfolio. Companies should therefore check the rules used in each country where they place bottles on the market.

The target will increase to 30% from 2030 and will then cover all relevant single-use plastic beverage bottles, not only PET bottles.

Which bottles are covered?

The rules apply to single-use plastic beverage bottles with a capacity of up to three litres.

A PET bottle is covered where polyethylene terephthalate is the major component of the bottle.

The scope does not include:

• glass or metal bottles that only have plastic caps or lids;
• bottles intended and used for liquid food for special medical purposes.

The methodology adopted in 2026 specifically addresses PET bottles. It should not automatically be applied to other packaging formats or to the wider recycled-content requirements under the PPWR.

Which parts of the bottle are included?

The calculation covers the plastic used in the complete bottle as it is normally sold.

This includes:

• the bottle body;
• the cap or lid;
• plastic labels;
• plastic sleeves.

The recycled plastic contained in all of these parts can contribute to the numerator. Their total plastic weight also contributes to the denominator.

This can produce a different result from a calculation based only on the bottle body.

For example, a bottle body may contain 25% recycled PET. If the cap and sleeve contain no recycled plastic, the recycled-content percentage for the complete bottle will be lower.

Non-plastic parts are excluded. A paper label, for example, does not form part of the plastic weight used in the calculation.

Only post-consumer plastic waste counts

The new methodology defines recycled plastic as material derived from post-consumer plastic waste.

This generally means plastic from products that have already been placed on a market for distribution, consumption or use.

Production waste generated before a product is placed on the market does not qualify simply because it is reprocessed.

This includes waste or scrap arising during:

• manufacturing;
• secondary processing;
• product testing;
• storage;
• internal transfers before market placement.

Companies should therefore distinguish between post-consumer recycled content and reused production scrap when reviewing supplier data.

A material may reduce the use of virgin plastic without qualifying toward the EU recycled-content target.

Can mechanically recycled PET count?

Yes.

Mechanically recycled PET can count where it meets the applicable requirements and the percentage of recycled plastic in the material is properly documented.

For food-contact bottles, companies will often rely on declarations issued under the EU rules for recycled plastic materials intended to come into contact with food.

The economic operator placing the bottle on the market calculates the recycled content using the percentage stated in the relevant material documentation and the weight of each bottle component.

The calculation must therefore be supported at component level rather than by a general statement that the overall packaging contains recycled plastic.

Can chemically recycled plastic count?

The new decision also allows recycled content from chemical recycling and other recycling methods to be recognised.

Where the actual proportion of post-consumer recycled material remains known throughout the process, the calculation can be based on that physical proportion.

Where recycled and virgin feedstocks are mixed and the recycled share can no longer be physically identified in each output, mass-balance accounting may be used.

This is not an unrestricted book-and-claim system.

The rules require, among other things, that:

• recycled input is linked to realistic outputs;
• material used as fuel or lost during processing is excluded;
• more recycled material is not allocated than entered the process;
• attributed amounts are not transferred between different facilities or companies;
• the mass-balance period does not exceed three months.

Certain stages of chemical-recycling supply chains are also subject to independent facility-level verification.

Can imported recycled plastic count?

Imported recycled plastic may be used in beverage bottles, provided that it complies with the relevant EU requirements.

However, being legally imported does not automatically mean that it can be counted toward the EU target.

Under the new methodology, recycled plastic initially qualifies where the post-consumer waste was recycled, including sorted, within the EU.

From 21 November 2027, material recycled in an OECD country may also count, unless the EU determines that the country does not meet the required standards for environmentally sound plastic-waste management.

Material recycled in a non-OECD country may only count where the EU has concluded an agreement or arrangement that provides equivalent environmental and human-health safeguards.

Companies sourcing recycled material internationally should therefore distinguish between:

• whether the material may be imported and used;
• whether it may be counted toward the mandatory recycled-content target.

These are separate questions.

What documents must follow the material?

The recycled-content information must be traceable through the supply chain.

Economic operators must provide a declaration with each relevant material batch. The declaration contains information such as:

• the material and batch reference;
• total batch weight;
• the amount or percentage derived from post-consumer plastic waste;
• the geographical origin;
• the recycling technologies used;
• relevant mass-balance information, where applicable.

Declarations received from suppliers must generally be kept for at least five years.

An operator that only resells or transfers material without changing its chemical or physical composition does not need to create a new declaration. It must pass the existing declaration to the next customer.

Where material is mixed or its composition changes, a new calculation point and updated documentation may be required.

What should companies placing bottles on the market verify?

The most relevant checks are:

• whether the product is a covered PET beverage bottle;
• whether the calculation includes the body, closures and plastic labels or sleeves;
• whether the recycled content comes from post-consumer plastic waste;
• whether each component is supported by appropriate batch documentation;
• whether imported recycled material is currently eligible to count;
• whether chemically recycled content follows the required mass-balance and verification rules;
• whether the correct data is available for each Member State where bottles are placed on the market.

A supplier statement showing “25% rPET” may be useful, but it does not answer every compliance question.

The percentage must relate to the correct bottle parts, qualifying recycled material and the market data used under the national reporting system.

How does this relate to packaging EPR?

The recycled-content target and packaging EPR are separate obligations.

Packaging EPR generally concerns national registration, packaging-volume declarations, recycling fees and authorised representation.

The recycled-content rules concern the composition of the bottle and how that composition is calculated and verified.

Some of the same product and packaging data may be needed for both areas, but meeting the recycled-content target does not replace EPR registration or reporting.

How Viron can support

Viron helps companies assess packaging obligations across the EU and distinguish between product requirements, recycled-content rules and national EPR compliance.

We can also coordinate packaging registrations, declarations, authorised representation and ongoing reporting across multiple markets.