Navigating Recycled Plastics Regulations in 2026

First published: March 2026

 

From the EU’s Packaging and Packaging Waste Regulation (PPWR) to new Chinese national recycling standards, global regulation of recycled plastics is tightening rapidly, particularly across packaging and consumer products.

Below is a regulation-focused overview across the EU, United States, United Kingdom, and China for 2026, with specific implications for recycled plastics testing and compliance.

If you are looking for recycled plastic testing, please contact us here directly.

 

Key applications of rPET, rPP, and rHDPE in consumer products

Regulatory obligations often differ by polymer type and end-use, making it essential to understand where these materials sit in your product portfolio. Recycled polyethylene terephthalate (rPET), recycled polypropylene (rPP), and recycled high-density polyethylene (rHDPE) are three of the most commonly recycled plastics and are used in a range of consumer products:

• rPET is predominantly used in beverage bottles, food packaging trays and clamshells, personal care bottles, and textile fibres (polyester) for apparel and footwear.
• rPP is found in food packaging such as yoghurt pots, caps, closures and ready-meal trays, as well as cosmetic jars, homeware, and textile components.
• rHDPE is widely used in milk and juice bottles, household and industrial chemical containers, personal care bottles, and rigid secondary packaging.

For all of these, regulators are increasingly linking recycled content targets, safety requirements, and claims controls to the specific polymer and end-use. For any brand operating across international markets, ensuring compliance with the specific requirements of each jurisdiction you trade in is key to market access.

 

Regulations on recycled plastics in the EU

Packaging and Packaging Waste Regulation (PPWR)

Regulation (EU) 2025/40, also known as the EU’s Packaging and Packaging Waste Regulation (PPWR), fundamentally reshapes how PET, PP, HDPE, and other recycled-plastic packaging is designed and placed on the market. It applies from 12 August 2026 across all EU member states, including imported packaging.

Under Article 7, mandatory minimum recycled content targets take effect from 1 January 2030: 

• 30% for contact-sensitive PET packaging (excluding single-use beverage bottles)
• 10% for contact-sensitive non-PET packaging, including PP and HDPE
• 30% for single-use plastic beverage bottles
• and 35% for non-contact-sensitive plastic packaging. 

These escalate significantly by 1 January 2040, rising to 50%, 25%, 65%, and 65% respectively. All recycled content must be derived from post-consumer plastic waste.

Beyond recycled content, the PPWR requires all packaging to be designed for recyclability from 2030, with packaging below 70% recyclability banned from the market. PET, PP, and HDPE are priority materials given their established recyclability and high market volume.

In addition, to encourage economic operators to increase the recycled content in the plastic components of packaging, Extended Producer Responsibility (EPR) fees may be modulated based on the percentage of recycled material used, the sustainability of the recycling technologies involved and the environmental costs associated with producing recycled content.

If you are planning for PPWR compliance or looking to prove your recycled material used for eco-modulation under EU EPR, contact us for support.

 

Regulation (EU) 2022/1616

In parallel, the EU regulates recycled plastics in food-contact applications through Regulation (EU) 2022/1616, which is the primary legislation on recycled plastic materials and articles intended to come into contact with food. It establishes specific rules governing approved recycling technologies, decontamination efficiency, and traceability. 

Under this regulation, only two recycling pathways are currently authorised: mechanical recycling of food-grade, separately collected post-consumer PET, and closed product loop recycling. Each individual recycling process must be scientifically evaluated and authorised by the European Food Safety Authority (EFSA) before recycled plastic can be used in food-contact applications. 

This framework operates alongside Regulation (EC) 1935/2004 (the general food-contact materials framework), Regulation (EU) No 10/2011 (which sets migration limits and authorised substance lists for plastics), and Regulation (EC) 2023/2006 (on good manufacturing practice). 

For rPET, rPP, and rHDPE used in food-contact packaging, brands must ensure the recycling process is authorised under Regulation (EU) 2022/1616 and that migration and contamination risks, including overall migration, non-intentionally added substances (NIAS), volatile organic compounds (VOCs), primary aromatic amines (PAAs), and PFAS, are adequately controlled and tested in accordance with Regulation (EU) No 10/2011 and the purity requirements introduced by Regulation (EU) 2025/351.

Contact us to ensure meeting the EU recycled plastics regulations.

 

Regulations on recycled plastics in the UK

The UK regulates recycled plastics, particularly those used in food‑contact applications, under retained EU legislation, with the Food Standards Agency (FSA) serving as the competent authority responsible for enforcement, auditing, and approval. Recycled plastics must meet strict chemical safety and purity standards, and the regulatory framework remains closely aligned with evolving EU rules to support continued market access and compliance.

In addition, the UK has introduced several national requirements and pieces of legislation that affect packaging and recycled packaging, further shaping the obligations for businesses operating in the UK market.

 

Plastic Packaging Tax

The United Kingdom operates its own distinct regulatory framework. The Plastic Packaging Tax (PPT), now set at £223.69 per tonne, applies to all plastic packaging manufactured in or imported into the UK that does not contain at least 30% recycled content. This creates a direct financial incentive for brands to incorporate rPET, rPP, and rHDPE into their packaging.

 

UK Extended Producer Responsibility (EPR)

From 2026, the UK’s Extended Producer Responsibility (EPR) scheme introduces modulated fees, meaning the cost producers pay is adjusted based on the recyclability and recycled content of their packaging. Packaging that has not been assessed through the Recyclability Assessment Methodology defaults to the highest fee band, substantially increasing costs.

 

Upcoming in 2027

Two further milestones are approaching: chemical recycling will be formally recognised under mass balance accounting from April 2027, and the Deposit Return Scheme (DRS) for beverage containers launches in October 2027. Both will directly affect rPET supply chains and compliance strategies.

 

Struggling to keep up with UK recycled plastics regulations? Contact us today, and our team will reply to you shortly.

 

 

Regulations on recycled plastics in the U.S. 

Federal level

At the federal level, the U.S. Food and Drug Administration (FDA) does not establish mandatory post-consumer recycled (PCR) content targets for plastic packaging. Instead, the FDA regulates the safety of recycled plastics used in food-contact applications under the Federal Food, Drug, and Cosmetic Act (FFDCA).

For recycled plastics intended for food contact, manufacturers must ensure compliance with food contact material requirements. The FDA operates a voluntary review program for recycling processes and issues “No Objection Letters” (NOLs) when it concludes that a specific recycling process can produce recycled plastic suitable for food-contact use.

Key aspects of FDA review include:

• Characterization and control of the post-consumer feedstock,
  
• Identification and removal of potential contaminants,
  
• Validation of the recycling process (often via surrogate contaminant challenge testing),
  
• Evaluation of potential migration into food under intended conditions of use. 

Common resin types evaluated under this program include PET (rPET), HDPE (rHDPE), and PP (rPP).

It is important to note that obtaining an FDA NOL is not legally mandatory. However, in practice, most brand owners, converters, and retailers require an NOL (or equivalent assurance) before using post-consumer recycled plastic in food-contact packaging.

Outside the food-contact context, there is currently no federal law mandating minimum recycled content in plastic packaging.

 

State level

Unlike the European Union’s harmonised regulatory framework, recycled content requirements in the United States are driven primarily by state legislation.

As of 2025, several states have enacted laws mandating minimum post-consumer recycled (PCR) content for certain types of plastic packaging. These include:

• California
  
• New Jersey
  
• Washington
  
• Oregon
  
• Colorado

The scope, product categories, and timelines vary by state.

 

California

California has two major regulatory frameworks relevant to recycled plastics:

1. AB 793 (Plastic Beverage Containers)
   This law requires minimum PCR content in plastic beverage containers sold in California, with phased percentage requirements through 2030 and beyond. 
2. SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act)
   SB 54 establishes an extended producer responsibility (EPR) program for single-use packaging and plastic food service ware. Key requirements include:
   
   • 100% of covered material must be recyclable or compostable by 2032.
     
   • A 65% recycling rate for single-use plastic packaging by 2032.
     
   • A 25% source reduction in plastic packaging by 2032.

California also separately regulates PFAS in food packaging and restricts certain single-use plastic products under other statutes.

New Jersey

New Jersey’s Recycled Content Law (NJSA 13:1E-99.135 et seq.), requires minimum recycled content in certain rigid plastic containers, glass containers, paper carryout bags, and plastic trash bags. The law establishes phased PCR percentage increases over time.

Washington

Washington’s Post-Consumer Recycled Content (PCRC) law (RCW 70A.245) applies to specific categories, including beverage containers, trash bags, and certain household and personal care product containers, with phased PCR percentage requirements beginning mid-decade.

Oregon

Oregon has adopted a comprehensive packaging EPR framework under its Recycling Modernization Act. While it does not impose broad PCR mandates across multiple packaging categories comparable to California, New Jersey, or Washington, Oregon does require minimum recycled content for certain plastic beverage containers under its bottle deposit system.

Colorado

Colorado has enacted a packaging EPR framework and minimum recycled content requirements for certain products such as plastic trash bags, but it does not currently impose broad post-consumer recycled content mandates for plastic packaging categories comparable to other states.

 

Contact us now to ensure your consumer products comply with the US recycled requirements at both the federal and state levels.

 

 

Regulations on recycled plastics in China

China has taken a significant step forward with the approval of nine new national standards for recycled plastics, all of which came into effect on 1 February 2026. Administered by the National Technical Committee for Plastics Standardization (SAC/TC 15), these standards cover product evaluation, recyclable design, and quality benchmarks for recycled polymer materials. Currently, China has 23 related national standards systematic to the recycled plastics such as PP, PE, MPO, ABS, PS, PC, PET, PVC, etc.

 

 

How does Eurofins Sustainability Services help you navigate recycled plastics compliance?

Meeting recycled plastics regulations in 2026 requires more than a sustainability narrative. It requires robust, accurate data on the origin and composition of your plastics.

Eurofins Sustainability Services has developed a proprietary recycled plastics testing solution that analyses the physical and chemical properties of polymers, rather than relying on generic chemical markers, to accurately verify recycled content. 

Our service covers rPET, rPP, and rHDPE, enabling you to determine whether materials are genuinely derived from recycled sources or virgin polymers and quantify recycled content in blends. 

We can also help you substantiate marketing and sustainability claims, support supply chain transparency, achieve documented compliance with the EU PPWR, US FDA expectations, UK PPT and EPR, and more. Beyond meeting your own obligations, independently tested data provides greater assurance to your customer base, giving retailers, brand partners, and end consumers the confidence that your products are responsibly and transparently sourced.

Contact us today to design a testing strategy for recycled plastics. You can also visit our Recycled Plastics Testing webpage for more information.