A genuine target, but with the conditions missing
The PPWR sets a target of 10% recycled content for food plastics other than PET by 2030. This directly affects a large share of food packaging: PP trays, PE films, PS pots, multilayer lidding.
No one disputes the environmental intent. Incorporating recycled material into plastic packaging is a priority of the transition to a circular economy. The problem is not the target. It is the path between the target and operational reality. That path involves three distinct barriers, and none of them is close to being lifted.
The three barriers no one frames together
Barrier 1: the EFSA regulatory framework
To incorporate recycled plastic into food-contact packaging, the material must be approved by EFSA under Regulation (EC) 1935/2004. This is no formality: it is a full toxicological assessment that takes between three and five years, with a detailed dossier on the recycling process, the quality of the incoming stream and the risks of unwanted substances migrating.
The only genuinely approved processes today concern recycled PET from transparent bottles, essentially water bottles. The logic is straightforward: the stream is controlled and homogeneous, water as a product carries no cross-contamination risk, and the dossier was achievable. The moment you step outside that specific case, the complexity explodes.
Barrier 2: the supply of material
Even if EFSA were to approve new processes for PP, PE or PS tomorrow, the question of supply would remain unresolved. The recycling chains for these flexible and rigid plastic resins are very recent in France and across Europe. The volumes collected, sorted and recovered are still very low. And the quality of the incoming streams is uneven, which further complicates the EFSA dossiers.
Holding the regulatory authorisation without the material available solves nothing. Both conditions are needed at the same time.
Barrier 3: mass balance
Some put forward mass balance with an ISCC+ certificate as the answer to these first two barriers. It is worth understanding what it really is: a supply-chain accounting system. It certifies that a given quantity of recycled material has entered the production system somewhere and that a corresponding “credit” is allocated to a product.
This does not mean that the recycled molecules are physically in that packaging. It is not an EFSA health approval. The two systems have nothing in common and do not substitute for one another. ISCC+ does not lift the EFSA regulatory barrier.
What this means in practice: material suppliers are receiving 2030 specifications today with recycled-content requirements for PP, PE or PS food packaging. These suppliers have literally no EFSA-approved process to offer in response. It is not that they lack willingness. It is that the regulatory and industrial preconditions are not met, and probably will not be by 2030 for all the resins concerned.
What the PPWR acknowledges itself
This is the point that deserves close reading: the PPWR itself provides for an exemption from the recycled-content obligation where that content would conflict with food-contact materials legislation.
This exemption is in the text. It is intentional. And it means that those who drafted the regulation were aware of the conflict between the recycled-content target and the existing EFSA framework.
In practice, the drafters provided for an exemption where regulatory coordination would have been needed. The environmental intent is certainly present in the text. The consistency between regulations is not.
This is not a minor footnote. It is the implicit acknowledgement that the 10% target for food plastics other than PET in 2030 may not be achievable under current regulatory conditions. The exemption is there to prevent the target from creating automatic non-compliance in cases where the technical solution does not yet exist.
What this changes for your material strategy
PET food-contact packaging
The situation is better, but not without risk. EFSA-approved processes exist (essentially the SuperClean processes on transparent PET bottles). The supply is real but under strain. The 30% target for 2030 is ambitious but technically achievable, provided sourcing is secured early. Competition for this supply will intensify considerably by 2028-2029.
PP, PE, PS food-contact packaging
The 10% target for 2030 sits in a zone of genuine uncertainty. Without the EFSA barrier being lifted for suitable processes, and without the development of recycling chains at sufficient volume, strict compliance will be hard to reach for certain resins. Documenting the regulatory obstacles and the steps taken from now on is essential to justify recourse to the exemption if needed.
Non-food-contact plastic packaging
A more favourable situation. The 35% targets for 2030 are more attainable because there is no EFSA barrier. The recycling chains for rigid non-food plastic are more mature. Sourcing certified recycled material must be set up as early as 2026-2027 to secure the volumes needed before the pressure of 2029-2030.
What this case reveals about the PPWR
The recycled-content target for plastic food packaging illustrates a structural problem in the regulation: ambitions set without any systematic check of their feasibility against the other sector-specific European regulations in force.
This is not a problem unique to the PPWR. It is a problem of coordination between regulations produced by different teams, at different times, without a cross-cutting view. The food-contact materials regulation and the packaging regulation were plainly not built together.
For industry, the practical conclusion is clear: do not wait until 2029 to find that the target is unachievable. Document the regulatory barriers encountered now, open discussions with suppliers about their development plans, and follow closely the changes to the EFSA list of approved processes. These are the elements that will make it possible to demonstrate the company’s good faith and to rely on the exemption if strict compliance is impossible within the deadlines.
Sources: Regulation (EU) 2025/40, Article 7. Regulation (EC) 1935/2004 on food-contact materials. EFSA register of approved plastic recycling processes. European Commission guidance of 30 March 2026. Content provided for information only; it does not constitute legal advice.
Cover photo: Nareeta Martin on Unsplash