Implementing PPWR: Credible rules can turn recycled-content targets into circular progress
The EU’s new recycled-content targets can strengthen demand for recycled plastics. Through the European Plastics Circularity Coalition, TOMRA is advocating rules that support trustworthy claims, fair competition and strong regional recycling value chains.
Packaging and Packaging Waste Regulation (PPWR) is a comprehensive European Union law designed to curb the environmental impact of packaging, reduce waste, and promote a circular economy across the entire packaging lifecycle. Its core requirements already apply, starting on 12 August 2026.
The PPWR sets the direction, but the practical rules are still being developed. Annexes and subsequent implementing or delegated acts can determine the methodologies, criteria and controls used in practice. Among other things, PPWR will be introducing mandatory minimum recycled-content requirements for plastic packaging. Article 7 also provides for further rules on how recycled content will be calculated, verified and certified.
Increasing demand for high-quality recycled plastics is important to reduce our current overreliance on virgin plastics.
TOMRA continues to follow up its long-term commitment to reduce the adverse impacts from plastics by actively supporting the Alliance to End Plastic Waste (AEPW), the Business Coalition for a Global Plastics Treaty, and the Global Circularity Protocol for Business. The company has also issued own recommendations to the UN’s Global Treaty on Plastic Pollution.
Building robust recycling value chains
To contribute to the implementation of PPWR’s Article 7, TOMRA has co-founded the European Plastics Circularity Coalition with like-minded companies, industry associations and non-governmental organizations. The coalition provides input to the European Commission on the rules supporting PPWR’s Article 7. Despite its name, the coalition’s motivation extends beyond strengthening recycling in Europe.
Its position is that recycled-content targets should encourage investment in robust circular value chains around the world, with materials collected, sorted, recycled and returned to productive use under clear and verifiable requirements. Implemented well, Article 7 could stimulate investments in circular infrastructure globally.
“Article 7 is a major opportunity to accelerate circularity for plastics in Europe. But recycled-content targets must be backed by robust equivalence criteria, traceability and enforcement for imports of recyclates from other parts of the world. Otherwise, Europe risks undermining the investments needed to build a competitive recycling industry,” says Wolfgang Ringel, SVP Public Affairs at TOMRA.
Creating a level playing field
TOMRA’s position is that recycled plastics from outside Europe should not count towards EU targets unless they meet equivalent standards for collection, sorting, recycling, traceability and enforcement. The coalition is calling for:
- System-level equivalence: Equivalence should be assessed at country or system level, rather than demonstrated solely through the certification of an individual recycling facility.
- Clear interim rules: Until system equivalence is operational and enforceable, the coalition proposes that only recycled content produced in the EU, EFTA and the UK should count towards the targets, with safeguards for shortages.
- Effective enforcement: Audits and penalties should prevent non-compliant materials from undercutting responsible investment. These are the coalition’s policy recommendations and are not requirements already established by the PPWR.
Raising standards across regions
The coalition presents a level playing field to promote comparable standards, not to restrict responsible international trade in recycled materials.
“A level playing field is key to sustaining the European recycling industry, but also to encouraging investments in systems and infrastructure in other regions of the world to establish circular material streams and encourage a shift to recycled material targets in other continents,” says Wolfgang Ringel.
For the coalition, recycled materials should compete on a credible and transparent basis wherever they originate. This requires documented standards, reliable traceability and effective enforcement.
From regulatory targets to circular outcomes
The PPWR sets the direction through mandatory recycled-content requirements. Translating these targets into circular outcomes will depend on effective systems for collecting, sorting and recycling packaging waste, alongside credible methods for verifying the recycled material used in new packaging. Through the European Plastics Circularity Coalition, TOMRA is advocating implementation rules that support trustworthy claims, continued investment in European recycling capacity and strong regional circular value chains elsewhere.
With credible and comparable requirements, the coalition believes Article 7 can support Europe’s circular-economy objectives while encouraging wider investment in high-quality recycling systems.
Join the discussion
The PPWR is a landmark piece of legislation for circularity, competitiveness and resilience. With a balanced and fair implementation that ensures a level playing field, the regulation has the potential to make lasting meaningful impact both in Europe and globally. The supporting acts are being drafted now, and you can contribute in several ways:
- Join the coalition: The European Plastics Circularity Coalition remains open to members who share the coalition’s beliefs in building resilient circular systems. Interested parties can contact TOMRA’s Public Affairs team to notify your interest.
- Join the conversation: Key members of the European Plastics Circularity Coalition will participate at the Brussels Climate Week’s Industry Day on Wednesday 14 October. TOMRA’s Wolfgang Ringel and Eastman’s Francisca Melia will be engaging in a fireside chat on the topic.
