European Commission has published an implementing act clarifying the methodology for calculating and reporting recycled content in packaging. The document establishes detailed technical criteria for compliance verification and directly impacts producers, converters, and recyclers across the EU.

The European Commission has issued an implementing act detailing how economic operators must calculate and declare recycled content in packaging, in line with the EU’s circular economy objectives.
The document provides essential clarifications regarding:
– methodology for calculating recycled content percentage
– differentiation between mechanical and chemical recycling
– traceability requirements throughout the value chain
– obligations for independent audit and verification
A critical aspect is the definition of the point at which material is considered “recycled” within the industrial process. The act specifies that only material effectively reintroduced into manufacturing can be counted, excluding technological losses or non-validated intermediate materials.
For plastics converters, the implications are significant:
• stricter documentation of recycled material origin
• ERP system adjustments for traceability compliance
• closer cooperation with certified recyclers
• potential increase in administrative and compliance costs
In the case of chemical recycling, the act introduces additional criteria regarding mass balance allocation — a sensitive and ongoing debate within the European plastics industry.