What the PPWR is
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the European Union's main rulebook for packaging. It entered into force on 11 February 2025 and applies from 12 August 2026. It covers the design, labelling, reuse, recyclability and recycled content of packaging, and it sets out producer obligations for packaging placed on the EU market. Because it replaces the earlier packaging directive with a directly applicable regulation, the same rules apply across member states without national transposition.
For plastic credit buyers, the PPWR matters for two reasons. It creates a binding demand for recycled plastic in packaging, and it tightens how packaging claims can be made. Both affect how a credit can be used.
Recycled content is a physical requirement
The PPWR sets minimum recycled content levels for plastic packaging from 2030, with further increases in later years. The obligation is about the material in the packaging itself. A brand meets it by using recycled plastic in its packs, and it is measured against the packaging it places on the market.
A plastic credit does not change that calculation. A credit records that a quantity of plastic waste was collected or recycled somewhere, usually through a project that the buyer does not own. The buyer does not receive that plastic, and the credit does not add recycled content to a bottle or a film. The distinction is set out in more detail in the article on plastic credits versus recycled content claims.
Any suggestion that a credit counts towards the target should be treated with caution until the regulation text and its implementing acts say so explicitly.
Where credits still have a role
Plastic credits remain useful for goals that sit outside the packaging target. A company may want to fund collection in a region where its packaging ends up, or to show progress on a plastic footprint that includes products it cannot yet redesign. Credits can also support the collection side of extended producer responsibility (EPR) programmes, where the producer's obligations are about financing collection and recycling rather than the content of each pack.
The important point is that a credit should be described as a credit. It funds a documented waste outcome. It is not evidence that a specific pack contains recycled plastic.
Packaging claims under the new rules
The PPWR tightens how packaging is labelled and described, and it sits alongside the EU rules on green claims. A brand that uses a plastic-neutral or plastic-positive message on EU packaging should be able to show three things: what the claim covers, which credits support it, and how those credits were verified and retired. The retirement record matters, because it shows the credit can no longer be claimed by anyone else.
Brands should also avoid wording that implies a pack is made from recycled plastic when it is not. A message such as this bottle is plastic neutral can be read as a material statement by a consumer. A clearer message is we fund the collection of one tonne of plastic waste for every tonne of plastic we place on the market, if that is what the purchased credits support and the claim is reviewed against the current rules.
What to check before the next packaging decision
Packaging teams and sustainability teams usually need to work through the same questions:
- Which packs are in scope. Map the packs placed on the EU market and confirm which fall under the recycled content obligation and which do not.
- Where recycled material comes from. Confirm the supply chain for recycled plastic and the documentation that supports each content claim.
- How credits are described. Keep credit-based statements separate from material statements in packaging copy and in reports.
- What the implementing acts say. The calculation methods for recycled content are set through further EU acts, so check the current text before relying on any method.
- Who signs off. Packaging claims that rely on credits should go through legal or compliance review before publication.
Frequently asked questions
Does the PPWR apply to packaging sold outside the EU?
The regulation applies to packaging placed on the EU market. A brand that sells into the EU needs to check its packaging against the rules whatever its home market, and the answer depends on how the product is placed on the market.
Can a plastic credit help a brand meet the 2030 recycled content level?
Not on the reading that matters for most buyers. The recycled content target is about the material in the packaging. Credits do not add recycled plastic to a pack. Any use of credits in that context should be reviewed against the regulation text by legal advisers.
Do the rules change how I should talk about plastic credits?
Yes, in practice. The safest approach is to describe a credit as a verified waste outcome, state which claim it supports, and keep it separate from any statement about recycled content in a product.
About the author
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The Plastic Units editorial team writes and maintains the Knowledge Bank and news on the plastic credits market, recycling economics and plastic policy.