PPWR — Recycled plastic content: 2030 targets

The 10% target for non-PET food-contact plastics is the one that raises the most questions on the ground. To incorporate recycled plastic into food-contact packaging, the recycling process used must be approved by EFSA under Regulation (EC) 1935/2004. That is no formality: it is a toxicological assessment that takes between three and five years. Today the only genuinely approved processes concern recycled PET from clear bottles — essentially water bottles. For PP, PE and PS, the dossiers are not complete.

Some put forward mass balance with an ISCC PLUS certificate as the answer to this problem. To be precise: a supply-chain accounting system, not an EFSA food-safety approval. The two systems have nothing to do with one another and are not interchangeable. Under the mass balance approach, the recycled molecules are not necessarily physically present in the packaging concerned. It is a credit allocated somewhere within the production system.

And even if EFSA were to approve new processes by 2030, the available feedstock would remain insufficient. The recycling streams for flexible and rigid PP, PE and PS are very recent in France and across Europe. The volumes collected and recovered are still very small. What is telling is that the PPWR itself acknowledges this problem by providing an exemption where recycled content conflicts with food-contact regulation. The drafters knew. They put in an exemption rather than solving the problem.