EU sets binding rules for calculating and verifying recycled content in PET beverage bottles
Economic operators placing PET bottles on EU markets must calculate, document and third-party-verify recycled content using the Decision's mass-balance rules, and Member States must collect, verify and report that data against the recycled-content target
Change
On 30 June 2026 the European Commission adopted Implementing Decision (EU) 2026/1425, setting binding rules for calculating, mass-balance accounting, third-party verifying and annually reporting recycled plastic content in single-use PET beverage bottles under the Single-Use Plastics Directive (2019/904), and repealing Implementing Decision (EU) 2023/2683; it enters into force 20 days after its 3 July 2026 publication.
Why it matters
The Decision introduces mass-balance accounting so recycled content from chemical recycling can count toward the Directive's targets. Economic operators must apply mass-balance accounting at each calculation point, with per-facility attribution, no negative balance at any time and a three-month maximum accounting period, issue batch-level declarations, and retain suppliers' declarations for five years. Operators processing non-polymer material at both input and output stages face annual on-site, facility-level third-party verification (three-yearly for micro/SMEs), with certificates valid one year (three years for micro/SMEs) and recognised across Member States. Recycled material processed in third countries counts toward the mandatory target only from 21 November 2027 (OECD-Decision countries, subject to Commission assessment) or where EU environmental-equivalence agreements exist.
Implications
- — Economic operators placing PET bottles on an EU market must calculate recycled-plastic weight per bottle part using the Decision's formulas, apply mass-balance accounting at each calculation point (no negative balance, three-month maximum period, per-facility), issue Annex V batch declarations to customers and retain suppliers' declarations and certificates for at least five years — without this, Member States cannot count those amounts toward the recycled-content target.
- — Operators processing non-polymer material at both input and output stages (chemical recyclers in particular) must submit to annual on-site, facility-level third-party verification by an accredited verifier — every three years for micro/SMEs — and pass certificates down the supply chain; unverified material cannot be reported as recycled content.
- — Member State authorities must collect operator data, verify it on a risk-based approach, report only data verified under this Decision, and submit annually in the Annex II/III formats — data outside this basis cannot demonstrate attainment of the target.
- — Operators sourcing recycled feedstock from third countries must track origin: material recycled in OECD-Decision countries counts toward the mandatory target only from 21 November 2027 subject to the Commission's assessment, and non-OECD-Decision material counts only under EU environmental-equivalence agreements — sourcing decisions made before checking status risk non-countable content.
Who is affected
- — Economic operators (recyclers, converters, food business operators, importers) placing PET bottles on EU markets
- — Chemical recyclers and operators processing non-polymer material subject to third-party verification
- — Member State authorities responsible for data collection, verification and reporting
- — Accredited verifiers / conformity assessment bodies
What to watch
- — 23 July 2026 (20 days after 3 July publication): the Decision enters into force and the repeal of Implementing Decision (EU) 2023/2683 takes effect.
- — 21 November 2027: recycled plastic processed in OECD-Decision third countries may begin counting toward the mandatory target, subject to the Commission's assessment under Regulation (EU) 2024/1157.
- — 1 January 2030: Commission deadline to review the Decision, including the mass-balance allocation rules.