European Regulations

EU Correction of Recycled Plastic Rules in Bottles: What Manufacturers Must Review in 2026

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Equipo Editorial CambiosLegales
31 Jul 2026 7 min 0 views

Key data

RegulationCorrection of errors of Commission Implementing Decision (EU) 2026/1425, of 30 June 2026
Publication31 July 2026 (OJ L, 2026/1425)
Entry into force3 July 2026 (date of the original corrected standard)
Affected partiesManufacturers and packagers of single-use plastic bottles for beverages
CategoryEuropean Regulation
Repealed standardCommission Implementing Decision (EU) 2023/2683
Reference DirectiveDirective (EU) 2019/904 of the European Parliament and of the Council (SUP Directive)
OJEU ReferenceOJ:L_202690635
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Manufacturers and packagers of single-use plastic bottles for beverages have an immediate obligation: to review their systems for calculating and verifying recycled plastic content. The European Commission has published a correction of errors to the Implementing Decision (EU) 2026/1425, the standard that develops the Single Use Plastics Directive (SUP, Directive (EU) 2019/904) regarding the calculation, verification and reporting of data on recycled plastic in beverage bottles.

This correction, published on 31 July 2026 in the EU Official Journal (reference OJ:L_202690635), may affect calculation formulas, definitions or verification procedures that companies are already applying. The corrected standard entered into force on 3 July 2026 and repeals the previous Implementing Decision (EU) 2023/2683.

What does this regulation establish?

Implementing Decision (EU) 2026/1425 —now corrected— develops the technical obligations of the SUP Directive with respect to single-use plastic bottles for beverages. Specifically, it regulates three areas:

Regulated areaWhat it means for companies
Calculation of recycled plastic contentMethodology and formulas that must be applied to determine the percentage of recycled plastic incorporated in each bottle
VerificationProcedures and criteria that must be followed to demonstrate to authorities that recycling targets are being met
Data reportingFormat and reporting requirements that companies must submit to demonstrate regulatory compliance

The correction of errors may modify any of these three areas: calculation formulas, technical definitions or verification procedures. Given that the original standard was published on 3 July 2026 and the correction arrives on 31 July, companies that have already begun to apply Decision 2026/1425 must verify that the criteria they are using match the corrected version.

The standard entirely replaces the Implementing Decision (EU) 2023/2683, which was the previous technical framework for the same area. Any measurement or reporting system based on the 2023 standard should be considered obsolete.

Economic and operational impact

The impact is not just formal compliance: it directly affects the ability to market products in the European market. The specific operational consequences are:

  • Review of measurement systems: If the calculation formulas have been corrected, internal systems for measuring recycled content may be generating incorrect data since 3 July 2026.
  • Update of verification procedures: The corrected verification criteria may require changes to internal audits, certifications or technical documentation already prepared.
  • Review of reporting: Data reporting reports prepared under the original version of Decision 2026/1425 may need to be recalculated or reformatted.
  • Commercialization risk: Non-compliance with recycled content requirements may result in the inability to market products in the European market.
  • Sanction risk: Non-compliance may also result in sanctions, the amount of which depends on the national implementation of the SUP Directive in each Member State.

Who does it affect?

  • PET bottle manufacturers for beverages (water, soft drinks, juices, etc.)
  • Manufacturers of other single-use plastic bottles for beverages
  • Packagers that use single-use plastic bottles for their products
  • Regulatory compliance managers in packaging and beverage companies
  • Auditors and verifiers that certify recycled plastic content for these companies
  • Operations and quality directors that manage recycled plastic measurement and reporting systems

Practical example

A PET bottle manufacturer for mineral water that, since 3 July 2026, has been applying the calculation formulas of Implementing Decision (EU) 2026/1425 in its original version to demonstrate the percentage of recycled plastic incorporated in its bottles, must now:

  1. Download and compare the corrected version (published on 31 July 2026, reference OJ:L_202690635) with the original version of 3 July 2026.
  2. Identify whether the corrections affect the calculation formulas, technical definitions or verification procedures that it is already applying.
  3. If there are differences, recalculate the recycled content data using the corrected criteria and update the verification and reporting documentation already prepared since 3 July.
  4. If the corrected data does not meet the thresholds required by the SUP Directive, review the material composition or the recycled plastic supply chain before competent authorities conduct inspections.

This process is especially critical for companies that have already submitted reporting data or that have verification audits scheduled in the coming months.

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What should companies do now?

  1. Download the corrected version of Decision 2026/1425 from the EU Official Journal (reference OJ:L_202690635) and compare point by point with the original version of 3 July 2026.
  2. Identify what elements have been corrected: calculation formulas, technical definitions or verification procedures, and assess whether they affect the internal systems already implemented.
  3. Review and, if necessary, recalculate the recycled plastic content data generated since 3 July 2026 applying the corrected criteria.
  4. Update the verification and reporting documentation that has been prepared under the original version of the standard, especially if there are audits or data submissions planned.
  5. Verify that the recycled plastic supply chain remains compatible with the corrected criteria and that recycled material suppliers are also aware of the changes.
  6. Consult with the legal or compliance team to assess the sanction risk in case the data reported under the original version is not compliant with the corrected version.

Frequently asked questions

What exactly changes with this correction of errors to Decision 2026/1425?

The correction may affect the calculation formulas for recycled plastic content, the applicable technical definitions or the verification procedures that companies must follow. The corrected text was published on 31 July 2026 in the EU Official Journal (OJ:L_202690635). To know the exact changes, it is necessary to compare the corrected version with the original version of Decision 2026/1425, published on 3 July 2026.

When does this correction enter into force and from when must I apply it?

Implementing Decision (EU) 2026/1425, whose correction is published on 31 July 2026, entered into force on 3 July 2026. This means that the corrected criteria are applicable from that date. Companies that have been applying the original version since 3 July must review whether their data and procedures are compliant with the corrected version.

What happens if my company does not update its calculation and reporting systems with the corrected criteria?

Non-compliance with the requirements of the SUP Directive (Directive (EU) 2019/904) and its implementing standards may result in two main consequences: economic sanctions (the amount of which depends on the national implementation in each Member State) and the inability to market the affected products in the European market.

What standard does Implementing Decision (EU) 2026/1425 replace?

Implementing Decision (EU) 2026/1425 repeals and entirely replaces Commission Implementing Decision (EU) 2023/2683. Any calculation, verification or reporting system based on the 2023 standard should be considered obsolete and must be updated in accordance with the new standard (in its corrected version).

What types of bottles does this regulation apply to?

The regulation applies to single-use plastic bottles for beverages, including those made of PET and other plastic materials. Reusable bottles and non-plastic containers are outside the scope. The reference Directive is Directive (EU) 2019/904 of the European Parliament and of the Council, known as the SUP Directive (Single Use Plastics).

Official source

View 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_202690635



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