Germany prepares for PPWR recycled content requirements – new legislation reshapes the recycled plastics market

On Thursday, 11 June 2026, the German Bundestag approved a reform of packaging legislation. The reform aims to accelerate the use of recycled materials and prepare markets for upcoming requirements under the EU Packaging and Packaging Waste Regulation (PPWR). As a result, Germany intends to introduce recycled material requirements as early as 2027 – three years before PPWR recycled plastic requirements take effect.  

PPWR introduces recycled content requirements for plastic packaging  

The EU Packaging and Packaging Waste Regulation (PPWR) introduces recycled content requirements for plastic packaging from 2030 onwards. These requirements mandate minimum recycled content percentages for plastic packaging.

Recycled content requirements set by PPWR are ambitious and, with current European recycled plastic capacity, are in practice impossible to meet. Plastic packaging used in food contact applications must contain at least 10% recycled plastic, while the minimum requirement for other plastic packaging is 35%.

High recycled content requirements have made it more difficult for markets to prepare for upcoming obligations. As uncertainty remains regarding how future requirements can be met, demand for recycled plastics has remained lower than expected. This has led to a reduction in recycling capacity across Europe: several companies in the sector have gone bankrupt; production has been scaled back, and investments have been put on hold.

Estimates suggest that Europe has lost approximately one million tonnes of plastic recycling capacity over the past two years (including both mechanical and chemical recycling).

Meeting recycled content requirements depends on sufficient demand for recycled plastics and investment in new capacity. For this reason, it would be important for the market to see gradual growth in the use of recycled plastics well before the 2030 deadline.

Germany prepares to introduce recycled material requirements as early as 2027  

The legislative proposal approved in Germany aims to revitalise the recycled plastics market and prepare the sector for upcoming PPWR requirements. This is intended to ensure sufficient production capacity is available when demand increases, particularly from 2030 onwards.

The amendment implements PPWR requirements, which will apply across the EU from August 2026, in German national legislation. The new law is intended to create conditions for a dynamic recycled plastics market and prepare the German packaging industry for operating under the future EU regulatory framework. Recycled material requirements are expected to enter into force in 2027. The Federal Government has now been tasked with preparing these measures without delay, while specific recycled content percentages will be defined later through secondary legislation.

The reform of German packaging legislation aims to reduce packaging volumes, improve packaging recyclability and accelerate the transition to a circular economy. In addition to recycled content requirements, the reform includes requirements related to packaging reusability and compostability, as well as restrictions on difficult-to-recycle materials and certain hazardous substances.

As the first EU Member State to take this approach, Germany is setting an example for preparations during the PPWR transition period between 2027 and 2029. From the perspective of the EU market, the legislative reform also means that packaged products sold in Germany will need to comply with obligations introduced under German legislation.

How are other EU Member States preparing for PPWR requirements?  

Germany’s decision is one of the first examples of how EU Member States are preparing for future PPWR requirements.

The coming years will show what measures other EU countries adopt to promote the use of recycled materials before the 2030 deadlines and how the recycled plastics market develops as recycled content requirements draw closer.