16/09/2026.- Three implementing and delegated acts under Article 7 of the Packaging and Packaging Waste Regulation (PPWR) will shape how recycled-content requirements for plastic packaging are calculated, verified and implemented in practice.
Natural Mineral Waters Europe (NMWE) welcomes the objective of increasing the use of high-quality recycled plastic in packaging and developing a strong EU market for secondary raw materials. To achieve these objectives, the secondary legislation needs to provide clarity, legal certainty and harmonised implementation.
In its response to the European Commission’s Call for Evidence, NMWE sets out its priorities for the three acts covering:
Calculation and verification of recycled content
The rules should be clear and workable, with clear definitions and responsibilities across the supply chain. They should take into account the availability of recycled materials, technical feasibility and food-contact requirements, while ensuring a harmonised EU approach.
Sustainability criteria for recycling installations
The criteria should be proportionate and practical, support a level playing field between EU and non-EU recycling installations, and avoid artificial barriers to trade or recycling technologies. Different recycling solutions should be recognised based on their environmental performance compared with the fossil-based materials they replace.
Equivalence for recycled content originating outside the EU
The rules should focus on calculation and verification and build on existing EU and international frameworks, including Regulation (EU) 2022/1616 for food-contact applications and relevant ISO standards for non-food applications, rather than creating unnecessary additional requirements.
Across all three acts, NMWE calls for a clear, practical and harmonised framework that enables companies to make the necessary investment and compliance decisions.
Read NMWE’s full position paper here: NMWE_Call for Evidence_Art.7