PPWR Mirror Clause: Will Imported rPET Count in 2030?

The PPWR has applied since 12 August 2026, and the debate has moved on. The question now is not whether plastic packaging must contain recycled content from 2030, but which recycled content will count. In August the European Commission opened calls for evidence on the Article 7 acts; on 2 September the recycling associations asked for a “Made in Europe” preference. For anyone trading rPET across the EU border, this is the file to watch.

The 2030 targets, briefly

From 1 January 2030, Article 7 of Regulation (EU) 2025/40 requires minimum post-consumer recycled content in the plastic part of packaging: 30% for contact-sensitive packaging made mainly of PET, 10% for contact-sensitive packaging made of other plastics, 30% for single-use plastic beverage bottles and 35% for all other plastic packaging, calculated per packaging type and manufacturing plant, per year. The regulation already allows waste collected and recycled outside the Union, provided collection and recycling meet standards equivalent to the EU’s. How that equivalence is proven is what remains to be written (see our PPWR overview).

Three acts due by 31 December 2026

The Commission must adopt three pieces of secondary legislation by the end of the year, and has just closed the first round of evidence on all of them (14 August to 16 September):

• Article 7(8): an implementing act on the methodology for calculating and verifying the percentage of recycled content, and the format of the technical documentation.
• Article 7(9): a delegated act on sustainability criteria for plastic recycling technologies.
• Article 7(10): an implementing act on how to assess, verify and certify, including through third-party audit, the equivalence of the rules applied when post-consumer plastic waste is collected or recycled in a third country. This is the so-called mirror clause.

None of these is a compliance deadline for companies, but together they decide whether a tonne of rPET produced in Türkiye, North Africa or Asia can be reported against a European brand’s 2030 obligation.

What the recyclers’ associations are asking for

In their joint statement of 2 September, FEAD, Plastics Recyclers Europe and Recycling Europe asked for three principles. First, packaging produced or filled in the EU should meet its targets with recyclates from waste collected and recycled in Europe (EU27, EFTA and the UK). Second, for packaging produced and filled outside the EU, recycled content should only count where equivalence is shown at two levels: a country assessment by the Commission, and facility-level certification by an independent third party, valid for one year. Third, harmonised verification and a chain-of-custody model, so that waste origin can be checked at every stage.

Plastics Recyclers Europe expects Europe to have lost almost one million tonnes of recycling capacity between 2023 and the end of 2025, and names low-priced imports as a main cause. The pressure for strict verification will shape the final text.

What is law, and what is lobbying

The regulation allows third-country material on condition of equivalence; it contains no “Made in Europe” preference, and a blanket exclusion would raise trade-law questions. A Commission study on the administrative burden of Article 7(10) is under way, which points to a verification system rather than a closed door. The most likely outcome is a demanding but open regime: country-level recognition plus annual, audited certification of each plant, with documentation that follows the material to the packaging manufacturer.

What this means for rPET from Türkiye

Türkiye starts from a stronger position than most non-EU origins: a customs union with the EU, OECD membership, and a deposit return system, live since 1 July 2026, that brings separately collected bottles into the stream. On the facility side, the criteria the associations describe (audited process, documented input origin, a certificate renewed every year) are close to what a GRS chain-of-custody audit already checks annually.

At Doğa Pet’s Kırklareli plant every stage leaves a record: bale origin at intake, sorting purity, wash-line parameters, batch-level laboratory release and the certificates that ship with the food-grade rPET granulate. We walk through that chain in From Bale to Food-Grade rPET: Inside a PET Recycling Plant. If an equivalence audit arrives in 2027, the paperwork exists today.

What buyers should do before the act is adopted

Three steps cost little now and save a lot later: ask each non-EU supplier for its current third-party certification (GRS, EuCertPlast, RecyClass) and for documentation of where its bales come from; put an equivalence clause in 2027 contracts that links volumes to the final Article 7(10) act; and keep more than one certified origin, so that a strict act does not leave a line without qualifying material.

We will update this analysis when the draft acts are published. To see the documentation behind our material before then, contact us for a plant visit or a sample with its full batch record.

Sources

• Regulation (EU) 2025/40 (PPWR), Article 7 – EUR-Lex
• EUROPEN – PPWR Secondary Legislation Tracker
• European Commission – Conditions for importing recycled materials into the EU for use in packaging (call for evidence)
• FEAD, PRE, Recycling Europe – Joint Statement, 2 September 2026
• Packaging Europe – Plastics Recyclers Europe reports increased facility closures