New recycled plastic calculation in bottles: what manufacturers and packagers must do in 2026

Key data

If you manufacture single-use plastic bottles or package beverages in them, your company has a new technical obligation in force since 30 June 2026. The Commission Implementing Decision (EU) 2026/1425 establishes how you must calculate, verify and communicate the recycled plastic content in your packaging, and completely replaces the previous technical framework set by Decision 2023/2683.

It is not a newly created regulation: it is the technical update of the requirements already required by the SUP Directive 2019/904 on single-use plastics. What changes now are the specific methods you must use to demonstrate compliance with minimum recycled content targets to the competent authorities.

What does this regulation establish?

Decision 2026/1425 develops the article of SUP Directive 2019/904 that requires a minimum percentage of recycled plastic in single-use beverage bottles. To be able to demonstrate compliance, the regulation establishes three mandatory technical pillars:

• Standardized calculation methodology: manufacturers and packagers must apply the method defined in this Decision to determine what percentage of the plastic incorporated in the bottle comes from recycled material. Any proprietary method is not acceptable.
• Verification: the calculation must be verifiable by the competent authorities. This implies having technical documentation and traceability that supports the declared data.
• Communication and reporting: data on recycled content must be communicated to the authorities in the format and with the requirements established by the Decision.

The objective is to ensure that data on recycled plastic circulating in the European single market is comparable, verifiable and reliable, preventing each company from using its own criteria to calculate the percentage.

Economic and operational impact

The direct impact is not a fee or fixed amount: it is the cost of internal adaptation and the risk of not being able to sell in Europe if compliance is not met. The main operational consequences are:

• Review of traceability systems: companies must ensure they can trace the origin of recycled plastic incorporated in each production batch, from supplier to final product.
• Update of technical documentation: internal records and reports sent to authorities must be adapted to the new format and methodology of Decision 2026/1425.
• Supplier audit: if recycled plastic is supplied by a third party, the company needs documentary guarantees that such material meets the criteria of the new methodology.
• Risk of sanctions: non-compliance may imply administrative sanctions and, most relevant economically, restrictions on marketing in the European single market.

The cost of adaptation will depend on the size of the company and the maturity of its current traceability systems. Companies that already had robust processes under Decision 2023/2683 must review whether their methodology remains valid under the new framework. Those that did not have formalized systems face a larger investment.

Who does it affect?

• Manufacturers of single-use plastic bottles for beverages with activity in the EU, regardless of size.
• Beverage packagers that use single-use plastic bottles in their production process.
• Importers of bottles or beverages packaged in single-use plastic that market their products in the European single market.
• National control authorities responsible for verifying compliance with recycled content targets.
• Recycled plastic suppliers that must certify the characteristics of their material to their manufacturing clients.

Practical example

A Spanish company that manufactures PET bottles for mineral water and soft drinks used its own system to calculate the percentage of rPET (recycled PET) incorporated, validated under Decision 2023/2683. As of 30 June 2026, that system is no longer sufficient: it must apply the new standardized methodology of Decision 2026/1425.

In practice, this means the company must:

1. Review whether its current calculation method matches the new standard or requires adjustments.
2. Update traceability records to reflect the origin of rPET according to the new criteria.
3. Adapt the reports it sends to the Spanish competent authority to the new communication format.
4. Request from its rPET suppliers the documentation that certifies compliance under the new methodology.

If the company does not adapt its system and an inspection detects that the declared percentage of recycled plastic cannot be verified with the required methodology, it is exposed to sanctions and, in the worst scenario, to restrictions on marketing its products in the EU.

What should companies do now?

1. Review the current calculation methodology and compare it with the technical requirements of Decision 2026/1425 to identify deviations from the new standard.
2. Audit internal traceability systems to ensure they allow documenting the origin and percentage of recycled plastic in each production batch according to the new criteria.
3. Update technical documentation and reports for reporting to competent authorities in the format required by the new Decision.
4. Communicate the changes to recycled plastic suppliers and require them to provide documentation compatible with the new methodology.
5. Verify that contracts with customers and distributors correctly reflect the percentages of recycled content calculated under the new framework, to avoid claims or commercial conflicts.
6. Consult with specialized advisors if there are doubts about the technical application of the new methodology, especially in cases of mixed production or complex supply chains.

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_202601425