Regulation (EU) 2025/40Applies from 12 Aug 2026Independent publication - not legal advice
PackagingCompliance.help
The Packing Line - a working desk for the EU packaging regulation
Home / Station 06 - Recycled content / Guide

Recycled Content Beyond Plastic: Glass, Metal, Paper and Wood

Article 7 mandates percentages only for plastic - because the other materials' content markets already work. How cullet, scrap and recovered fibre actually run, and why 'no mandate' does not mean 'no duties'.

Published 24 October 2026Checked against the regulation text on 24 October 2026European Union

The short answer

The recycled-content mandate stops at plastic, deliberately. Container glass is routinely produced with high cullet shares because furnaces want cullet - it melts at lower energy and the collection system supplies it in quality. Steel and aluminium run on scrap markets older than the packaging industry itself, with recycled content a standard property of the melt rather than a claim. Paper and board draw on recovered fibre as a primary feedstock, graded and traded globally. In each case the legislator's judgement was that mandated percentages would regulate a functioning market and invite gaming of definitions, while the real risks sat elsewhere - in grading, in collection quality, in honest claims.

No mandate, however, means no holiday. These materials carry the full weight of the other stations: grading, substances, minimisation, fees, and claims discipline for the content figures they advertise voluntarily.

Glass: cullet economics and colour discipline

A glass furnace's cullet share is set by availability and quality: colour-sorted, ceramics-free cullet is the constraint, which is why collection quality (colour separation at bank or kerbside, deposit streams for beverage glass) determines content more directly than any producer decision. Producers support content by specifying cullet-tolerant furnace practice and by defending the stream's quality at the design end - the colours and decorations the recyclability station flags as grade risks are equally content risks, because contaminated cullet is content refused. Where a brand claims a cullet percentage, the evidence is the glassmaker's production data for the relevant period and furnaces; content varies by plant and campaign, and honest claims say so in their basis.

Metal: the scrap market's quiet efficiency

Steel packaging is produced from a melt in which scrap is a standard input, and aluminium's recycling economics - energy savings on the order of 95 percent against primary production - make scrap the most contested feedstock in the metals world. Content claims in metal run into a definitional subtlety the market handles by convention: in a fully pooled melt, the recycled share of a specific can is an allocation, and industry reporting works on market-average and mass-balance-style bases, which claims should name when they borrow them. The regulatory consequence for this station is light-touch with a sharp edge: no mandate, but the claims discipline of the previous guide applies in full to any figure printed on a can.

Paper and fibre: recovered grades and the food-contact line

Recovered paper trades in defined grades, and board and paper packaging span the range from high-recovered-content corrugated (near-total recovered fibre is normal) to virgin-fibre food boards where contact rules and strength specifications limit recovered input. The content questions in fibre are quality questions: which recovered grades may feed which products, with food-contact fibre governed by its own safety logic and national rules in the absence of a single Union measure. Producers should note the direction of the at-scale framework: fibre's high collection performance is the benchmark other materials are measured against, and defending it - contamination discipline, design for repulping from the grading station - is the fibre industry's regulatory interest stated plainly.

Wood: content as cascade

Wood's content story is the cascade: solid reuse first (pallets repaired and recirculated), then material recycling into panel products, then energy. 'Recycled content' in wood packaging appears at the panel layer - particleboard from recovered wood - rather than in the pallet itself, whose circularity is measured in rotations. The honest reporting of wood content therefore names the cascade level it describes. Businesses tempted to present repaired-pallet fleets as recycled content would be double-counting two different virtues; the wood fleet's claim is reuse, evidenced by rotations, and it is the stronger claim of the two.

Why a plastic station spends a guide on the others

Three practical reasons justify this guide's place. Mixed-material businesses plan content once, and need to know where the legal percentages stop so their programmes are scoped honestly. Claims discipline is portfolio-wide: a brand cannot run certified rigour on its plastic lines and folklore on its glass lines without the folklore eventually pricing the rigour. And material substitution decisions - the format strategy of the next decade - compare a mandated material against unmandated ones, a comparison that flatters the unmandated until their full duty set is laid beside the plastic one. Read whole, the six material stories are one story: the regulation mandates where markets failed, and disciplines claims everywhere.

Primary sources on the record

Legal status: No content percentages outside plastic in Article 7 of Regulation (EU) 2025/40; material duties arise under grading, EPR and claims law. Application position for this topic: Ongoing.

Follow the line

Station 06 - Recycled content PPWR Recycled Content Targets: The Percentages and What They Attach To Plastic packaging must contain minimum post-consumer recycled content from 2030: 30, 10, 30 and 35 percent by category, rising in 2040. The pillar guide to Article 7 - categories, calculation shape, exemptions and evidence. Station 06 - Recycled content PPWR Recycled Content Targets: The Percentages and What They Attach To Plastic packaging must contain minimum post-consumer recycled content from 2030: 30, 10, 30 and 35 percent by category, rising in 2040. The pillar guide to Article 7 - categories, calculation shape, exemptions and evidence. Station 06 - Recycled content Recycled Content Claims: What You May Say, and What Must Stand Behind It The voluntary recycled-content label, percentage claims on pack, and the substantiation discipline of green-claims law. Say exactly what the file supports, in the units the consumer understands.