Correction of recycled plastic calculation in bottles: what changes for manufacturers and bottlers in 2026

Key data

Plastic bottle manufacturers and beverage bottlers operating in the European Union have an immediate obligation: to review the recycled plastic calculation methodology they apply to their single-use bottles. The European Commission has published a correction of errors to the Implementing Decision (EU) 2026/1425, the standard that sets how the percentage of recycled plastic in these containers is calculated, verified and reported, in application of the Directive (EU) 2019/904 on single-use plastics (SUP).

This correction is not a minor wording change: it can affect calculation formulas, technical definitions or verification procedures that companies were already applying from the entry into force of the original standard. Ignoring it could constitute a breach of the minimum recycled content objectives required by European regulations, with the consequent risk of sanctions.

What does this regulation establish?

The Implementing Decision (EU) 2026/1425 establishes the methodology that economic operators must follow to:

• Calculate the percentage of recycled plastic incorporated in single-use plastic beverage bottles.
• Verify that this percentage complies with the minimum objectives set by the SUP Directive.
• Report recycled content data to the competent authorities of each Member State.

This Decision repeals and replaces the previous Implementing Decision (EU) 2023/2683, which was the methodological framework in force until now. The correction of errors published on 20 July 2026 affects the text of Decision 2026/1425 and may modify specific elements such as calculation formulas, definitions of technical terms or steps in the verification procedure.

Economic and operational impact

The impact of this correction is primarily operational and regulatory compliance. Companies that had already adapted their measurement systems, internal audits or data reporting to Decision 2026/1425 must now verify whether the corrected errors affect their processes.

The specific risks of not acting are:

• Applying incorrect calculation formulas and declaring recycled percentages that do not conform to the corrected official methodology.
• Failing to meet the minimum recycled content objectives required by the SUP Directive, which may result in sanctions by national authorities.
• Invalidating sustainability audits already performed with the erroneous version of the standard, requiring them to be repeated.
• Compromising documentary traceability vis-à-vis customers, distributors or investors who require verified ESG compliance.

The cost of review and adaptation will depend on the production volume and complexity of each company's measurement systems, but in any case it is significantly lower than the cost of non-compliance detected in an inspection.

Who does it affect?

• Manufacturers of single-use plastic beverage bottles, especially PET bottles and other plastics commonly used in the beverage sector.
• Beverage bottling companies that use single-use plastic bottles in their production process and must demonstrate the minimum recycled plastic content.
• Sustainability auditors who verify compliance with recycled content objectives for their clients in the packaging and beverage sector.
• Compliance officers and operations directors in companies in the packaging, beverage and food sector.
• Consultants and advisors specializing in packaging regulations who advise companies on the SUP Directive.

Practical example

A mineral water bottler that produces single-use PET bottles had adapted in July 2026 its internal system for calculating the percentage of recycled plastic incorporated, following the methodology of Implementing Decision (EU) 2026/1425. Its internal reports and data reported to the competent authority were based on that version.

With the publication of the correction of errors on 20 July 2026, the company must review whether any of the formulas or definitions it applied has been corrected. If, for example, the correction affects the formula for calculating the recycled percentage, the data already reported may not be in conformity with the corrected official methodology. In that case, the company should recalculate, correct its records and, if appropriate, notify the correction to the competent authority, before an inspection detects the discrepancy.

What should companies do now?

1. Download and read the corrected text of Implementing Decision (EU) 2026/1425, published in the EU Official Journal on 20 July 2026, to identify exactly which elements have been corrected (formulas, definitions, verification procedures).
2. Compare the corrected version with the one being applied internally: review whether the calculations performed since 3 July 2026 are based on the erroneous version or the corrected one.
3. Recalculate and correct the data on recycled plastic content if the corrected errors affect the formulas or procedures being used.
4. Update internal systems for measurement, recording and data reporting to reflect the corrected methodology.
5. Inform the sustainability auditors working with the company so they also update their verification procedures.
6. Review data already reported to the competent authorities and, if appropriate, notify corrections to avoid discrepancies in future inspections.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690601