A few years ago, recycled content in packaging was a voluntary sustainability claim — something brand marketing teams cared about, not something compliance teams required. That has changed.
France already adjusts EPR fees based on recycled content through CITEO's eco-modulation system. Germany is implementing similar incentives. The PPWR introduces mandatory minimum recycled content targets for plastic packaging across all 27 EU member states from 2030. And in the meantime, brand sustainability commitments are increasingly tied to verified recycled content data.
As a packaging manufacturer or supplier, the question you will face more and more often is: "What is the recycled content of this component?" This article explains how to answer it correctly.
What recycled content means under EU definitions
Recycled content refers to the proportion of a packaging component's total weight that is derived from recycled material. The PPWR and most EU EPR systems follow the ISO 14021 definition, which distinguishes between two types:
Post-consumer recycled content (PCR)
Material recovered from end-consumer waste streams — households, commercial premises, post-retail — that has been processed and reincorporated into new packaging material. Examples:
- Recycled PET (rPET) from collected PET bottles, used in new bottles or trays
- Recycled corrugated board from collected household or commercial packaging
- Recycled HDPE from collected household containers
- Cullet (crushed recycled glass) from collected glass bottles and jars
- Recycled aluminium from collected food and beverage cans
Post-consumer recycled content is the more valuable category — it represents material that would otherwise have ended up in landfill or incineration. The PPWR's mandatory recycled content targets specify post-consumer recycled content.
Pre-consumer recycled content (also called post-industrial)
Material recovered from manufacturing waste and reprocessed — trim offcuts, production rejects, and other by-products of the manufacturing process that never reached a consumer.
Pre-consumer recycled content is real recycled material, but it does not count toward the PPWR's mandatory minimums. Brand eco-modulation credits in France similarly give preference to post-consumer content.
In practice: if your corrugated cardboard manufacturer uses trim waste from their own production lines, that is pre-consumer. If they use cardboard collected from households and businesses, that is post-consumer. The distinction matters for your clients.
The PPWR recycled content targets
From 2030, the PPWR introduces mandatory minimum recycled content for plastic packaging placed on the EU market:
| Packaging category | 2030 target | 2035 target |
|---|---|---|
| PET bottles (beverage) | 30% PCR | 65% PCR |
| Other plastic bottles | 30% PCR | 50% PCR |
| Contact-sensitive plastic trays and pots | 10% PCR | 25% PCR |
| Other plastic packaging (non-contact) | 35% PCR | 65% PCR |
The obligation to demonstrate compliance with these targets falls on the producer (the brand). But the producer's ability to demonstrate compliance depends on documentation from the packaging manufacturer.
How eco-modulation works in France (the current model)
France gives brands a preview of what recycled content declarations will look like everywhere from 2026 onward. CITEO's eco-modulation system adjusts EPR fees up or down based on packaging sustainability characteristics — and recycled content is one of the main criteria.
Under CITEO's current system, brands receive a bonus (fee reduction) for using packaging with verified recycled content above specified thresholds:
- Plastic packaging with 30%+ post-consumer recycled content: meaningful fee reduction
- Paper and board with 50%+ post-consumer recycled content: similar reduction
To claim these bonuses, your French clients need documented, verifiable recycled content percentages for each component. A claim without documentation is rejected by CITEO. This is why French clients ask for recycled content data specifically — and why "we use recycled materials" without a percentage is not a useful answer.
How to document recycled content correctly
The documentation chain starts with whoever produces the raw packaging material — the resin producer, the paper mill, the glass manufacturer — and flows through the supply chain to the packaging manufacturer to the brand.
Option 1: Mass balance certification
The most common approach for plastics. A mass balance system tracks the quantity of recycled material input into a production facility and allocates it across outputs. You may receive plastic resin that is a physical blend of virgin and recycled material, certified to a specific recycled content percentage.
Standard certifications that carry mass balance verification:
- RecyClass — European standard specifically for plastic packaging recyclability and recycled content
- ISCC Plus — mass balance certification used for chemically recycled plastics and biobased materials
- REDcert2 — used for chemically recycled materials
If your plastic resin supplier provides a mass balance certificate, the recycled content percentage stated on that certificate is what you document in your BOM.
Option 2: Supplier declaration
For paper, cardboard, and glass, recycled content is typically straightforward: the paper mill or glass manufacturer states the percentage of recycled feedstock used, and you can request this as a standard product specification.
A supplier declaration (a signed document from your material supplier stating the recycled content percentage for a specific product) is generally sufficient for most national EPR systems. It should include:
- Supplier name and contact
- Material description and product code
- Recycled content percentage (distinguishing PCR vs pre-consumer)
- Applicable date range
- Signature / responsible party
Option 3: No recycled content
If your packaging component contains no recycled material, document 0%. Do not leave the field blank — blank is ambiguous and your clients will assume the worst or ask for clarification. A documented 0% is a complete and honest answer.
What to tell clients when you do not have certified data
For some components, you genuinely do not know the recycled content — particularly if your packaging was sourced before recycled content documentation was standard practice.
The honest approach:
- Cardboard and paper: contact your board supplier and request the recycled content specification for the grade you use. Most major corrugated board suppliers can provide this as a standard document. Standard brown corrugated often has 60–80% post-consumer recycled content by default.
- Plastics without documentation: If you have no certification from your resin supplier, do not claim recycled content. Report 0% and note that recycled content certification is "pending supplier documentation." This is more defensible than an unverified estimate.
- Glass: cullet content in glass manufacturing is typically documented at the plant level. Contact your glass supplier — they likely have this data.
Keeping recycled content data current
Recycled content is not a static property of a packaging component — it can change between production batches, especially for plastics where rPET and rHDPE availability fluctuates with market conditions.
Two implications:
- Version your BOMs. If the recycled content of a component changes (e.g., your corrugated board supplier increases their PCR percentage from 60% to 75%), this is a packaging change that requires a new BOM version with an effective date. Your clients need to know which version applies to which reporting period.
- Specify whether the data is lot-specific or a product average. Mass balance certifications often specify a percentage across an annual production volume. If your actual recycled content varies batch-to-batch, document the certified annual average.
Recycled content and recyclability are not the same thing
A common confusion: recycled content describes what a material is made from (looking backward — where did the material come from?). Recyclability describes what can happen to it at end of life (looking forward — can it be recycled?).
A packaging component can have high recycled content but poor recyclability (e.g., a multi-layer laminate made with rPET that cannot be recycled in practice because of the lamination). Conversely, virgin PET bottles are 100% recyclable in most EU collection systems but may contain 0% recycled content.
The PPWR requires both to be tracked — separately. Your BOM documents recycled content. Recyclability is assessed separately by your clients against PPWR recyclability grade criteria.
The practical outcome
Building recycled content documentation into your supplier data system now — even if your current clients are only in Germany or France — sets you up for the point when all 27 EU markets require it. The work of collecting supplier declarations and mass balance certificates is done once per material per product, not once per client per quarter.
For the full picture of what fields belong in a BOM, see exactly what packaging BOM data your clients need. For material classification beyond recycled content, see how to classify packaging materials for EU EPR.