Last updated: October 7, 2026
The Packaging and Packaging Waste Regulation (PPWR) applied across all 27 member states on 12 August 2026. It requires all packaging to be Designed for Recycling by 2030 and Recycled at Scale by 2035. A gap stands between that regulatory ambition and the infrastructure reality on the ground, and the gap widened over the last two years while recycling capacity contracted.
This is the state of soft plastic recycling across the EU, market by market, what actually changed in August 2026, and where the system is heading.
The Europe-wide picture
Ambitious targets, real infrastructure pressure
According to Plastics Recyclers Europe, more than 300,000 tonnes per year of mechanical recycling capacity closed in 2024 alone, the largest contraction on record. Preliminary 2025 data showed a further 50% rise in facility closures, bringing total EU recycling capacity losses to close to one million tonnes over three years.
The cause is economic. A global oversupply of cheap petrochemicals pushed virgin plastic prices down sharply, making recycled plastic uncompetitive. High European energy costs and a surge of low-priced imported recyclate compounded the problem.
Total installed plastics recycling capacity across Europe stood at 13.5 million tonnes in 2024, but it is growing well short of the 6% a year needed to meet PPWR targets. The PPWR's recycled content requirements from 2030 are designed to create structural demand for recycled material that is insulated from commodity price swings. That demand does not exist yet, and the near-term closures are real.
Flexible film recycling capacity in Europe
Installed capacity for recycling PE and PP films in Europe plateaued at approximately 3.5 million tonnes in 2024, about 26% of total plastics recycling capacity. Film was also one of the hardest-hit streams, accounting for a quarter of all capacity closed since 2023. Germany, France and Italy have the most developed lightweight packaging collection systems that include flexible film. Belgium and Sweden have been significantly upgrading their collection and sorting infrastructure. Southern and Eastern European member states lag substantially in both areas.
How soft plastic is collected across the markets
Germany: the strongest system in Europe
Germany has the most mature packaging recycling system in the EU. The dual system (Duales System Deutschland) requires producers to fund yellow bin collection of lightweight packaging including flexible plastic. Flexible film is collected co-mingled with other lightweight packaging and sorted at specialist facilities.
- Germany's 2024 recyclability standards update (published by ZSVR in August 2024) already anticipates the PPWR grading criteria, giving brands an early reference point for recyclability assessment.
- Veolia exited plastics recycling in Germany at the end of 2025, closing its Bernburg complex. This reduced available processing capacity, but Germany's system is deep enough to absorb facility-level closures that would be significant in smaller markets.
Belgium: the EU's highest overall packaging recycling rate
Belgium already recycles almost 80% of its packaging, past the EU's 2030 target of 70%, without a deposit return scheme.
- The Fost Plus EPR scheme operates a household sorting instruction system with detailed guidance on which soft plastic formats go in which bin.
- Flexible plastic packaging is collected as part of the PMC (plastic, metal, cartons) household stream.
- Belgium's performance reflects decades of co-investment in consumer education and physical infrastructure. Both are required; neither works without the other.
Ireland: deposit return scheme launch and growing soft plastic coverage
Ireland launched its deposit return scheme (DRS) for plastic bottles and cans in February 2024. As of July 2026 the operator Re-turn reports a collection rate of 78% to 79%, with more than 3 billion containers returned since launch, and is targeting 90% by 2029.
- The infrastructure investment triggered by the DRS launch is creating a stronger base for broader packaging recycling, including flexible film.
- Ireland's EPR framework aligns closely with PPWR direction, making it one of the more straightforward markets for EU compliance planning.
France: labelling transition and strong EPR
France operates one of the EU's largest packaging EPR programmes through Citeo. MRFs accept lightweight packaging including flexible film in co-mingled collection, though sorting efficiency varies by facility and the quality of recovered film bales is inconsistent.
- France requires the Triman logo and Info-tri sorting instructions on packaging. The European Commission has referred France to the EU Court of Justice over the requirement, and the harmonised EU sorting label will apply from August 2028 at the earliest. Until then, Triman remains mandatory for the French market.
- ADIVALOR operates a voluntary collection programme for agricultural film in France, one of the more developed agricultural soft plastic streams in Europe.
The Netherlands: infrastructure under pressure
The Netherlands has the EU's second-highest overall packaging recycling rate, at 75.8% in 2023, despite significant economic pressure on its recycling sector.
- The Dutch system has relatively advanced sorting of lightweight packaging including film.
- Like the rest of Western Europe, it faces the challenge of making film recycling commercially viable when virgin PE prices are low.
Sweden: Site Zero and advanced sorting
Sweden opened Site Zero in Motala in November 2023, described as the world's largest plastics sorting plant. Using AI and near-infrared (NIR) sensors, it sorts plastic packaging into 12 fractions, including LDPE and PP film, and can send up to 95% of incoming plastic to recycling.
- By 1 January 2027, all municipalities must have introduced door-to-door or near-home collection for household packaging waste.
- Site Zero sets a new technical benchmark for what is achievable in flexible film sorting and anticipates PPWR requirements rather than reacting to them.
Norway: Områ Oslofjord facility
Norway is not an EU member state but is directly relevant to EU market dynamics given its close integration with European packaging material flows. Områ, a joint venture between TOMRA and the Norwegian producer responsibility organisation Plastretur, opened near Oslo in November 2025. It can process 90,000 tonnes of plastic packaging per year, around 80% of Norway's plastic packaging waste by 2030.
Southern and Eastern Europe: the infrastructure gap
Romania, Bulgaria, Hungary, Poland, and other Central and Eastern European member states have substantially lower packaging recycling rates and significantly less developed infrastructure for soft plastic collection and sorting.
- Romania's deposit return scheme, launched in November 2023, reached 83% collection of drinks containers in 2025, its second full year. It shows how quickly a well-designed system can perform.
- For flexible film specifically, collection, sorting, and processing infrastructure across much of Eastern and Southern Europe is still being built.
- The PPWR creates uniform compliance obligations across all 27 member states. The infrastructure base is far from uniform.
What actually happens to the material
The mechanical recycling output challenge
When flexible film is collected and mechanically recycled in Europe, it becomes recycled PE or PP pellets used primarily in non-packaging applications: agricultural film, construction sheeting, pipe, and outdoor furniture. Closed-loop recycling, where flexible film returns to food-grade flexible packaging, is technically possible but commercially rare.
Output quality is constrained by contamination from inks, adhesives, and mixed-material structures in the input stream. Clean mono-material PE film produces higher-grade pellets with broader end-market options. Mixed or contaminated input produces lower-grade material.
Chemical recycling: significant investment but underperforming
Chemical recycling is being positioned as the solution for complex laminates and contaminated film that mechanical recycling cannot handle. The current reality is more qualified.
According to Fraunhofer UMSICHT, 18 chemical recycling plants were operating in Europe as of October 2025, with a combined capacity of about 290,000 tonnes per year. A further 65 projects, totalling 2.8 million tonnes per year, are in the pipeline, and 9 projects have been cancelled outright. Economics, feedstock quality and regulatory uncertainty have all slowed scaling.
The longer-term trajectory is more positive:
- Global advanced recycling capacity reached close to one million tonnes per year in 2024.
- In June 2026 the European Commission adopted mass balance rules allowing chemically recycled content to count towards recycled content targets for single-use PET bottles. Equivalent rules for other packaging, including film, are still to come, which is projected to unlock stalled investment.
What the PPWR requires for soft plastic
The key milestones for flexible packaging
The PPWR creates the most ambitious regulatory framework for flexible packaging recyclability in the world.
Already in force since 12 August 2026:
- EU Declaration of Conformity required for every packaging item placed on the EU market
- PFAS limits in food contact packaging under Article 5(5), applying to all packaging placed on the market from 12 August 2026, whenever it was manufactured
- Heavy metal limits, with a 100 mg/kg sum-of-four-metals threshold
- Producer registration in each member state of placement
- An EPR authorised representative for producers not established in the member state, one per country, with no size exemption
What's coming:
- Design for Recycling criteria and recyclability performance grades adopted by delegated act by 1 January 2028
- From 1 January 2030, packaging below grade C loses EU market access
- From 1 January 2030, minimum recycled content under Article 7. Flexible PE and PP food packaging is contact-sensitive non-PET, at 10%. Non-food flexible packaging falls under other plastic packaging, at 35%. Article 7(1) applies these from 1 January 2030 or three years after the methodology implementing act enters into force, whichever is later
- Recycled at Scale from 2035
Harmonised eco-modulated EPR fees from 2029
The PPWR requires every member state to base producers' EPR fees on the same recyclability performance grades. This applies 18 months after the grading rules are adopted, so from around mid-2029 if the 2028 deadline holds. The PPWR harmonises the criteria, not the fees themselves. Fee levels will still differ by country, and member states can add their own criteria such as recycled content. But for the first time, a recyclable, mono-material design will earn a lower fee in every EU market.
Where EU soft plastic recycling is heading
Site Zero and the AI-sorting wave
Sweden's Site Zero and the Områ facility in Norway represent what is technically achievable now. As the economics of advanced sorting improve and PPWR drives investment, similar facilities will be built across Europe, including in member states that currently have no film-specific sorting capability.
The investment gap
The Circular Plastics Alliance estimated that €7.6 to 9.1 billion of investment in sorting and recycling capacity was needed to reach 10 million tonnes of recycled plastic in Europe by 2025, a target the industry has since missed.
From around 2029, recyclability-based EPR fees will give recyclers a more predictable revenue stream that is less exposed to swings in virgin plastic prices than today's market.
Mono-material design as the structural shift
Industry initiatives to meet PPWR targets are accelerating development of mono-material flexible packaging across the EU. All-PE and all-PP flexible structures, designed to be sortable by NIR and recyclable through the mechanical recycling infrastructure being built, are the direction the EU packaging industry is moving.
Multi-layer laminates combining incompatible polymer families are likely to receive low recyclability grades under the 2028 Design for Recycling criteria, with sub-grade-C packaging banned from 2030.
Deposit return schemes in all 27 member states by 2029
Germany's DRS achieves 98% collection. As DRS rollout improves the quality and quantity of collected material across all member states, EPR systems for the remaining packaging categories, including flexible film, will have better-funded and better-structured infrastructure to build from.
What this means for your business
The near-term recycling capacity crisis is real. It is largely driven by economics, and the PPWR's structural mechanisms (mandated recycled content, recyclability grades and recyclability-based EPR fees) are designed to fix it by making recycling commercially viable at scale. Whether they arrive in time to stop further closures is still an open question.
Three actions are worth prioritising now:
1. Audit your Declaration of Conformity
Every packaging SKU on the EU market has required a Declaration of Conformity since 12 August 2026. If yours are incomplete, you have a live compliance gap rather than a deadline to plan for. For flexible packaging the file needs material composition data by layer, PFAS test results for food contact formats, heavy metal evidence, and recyclability assessment evidence.
2. Address PFAS in food contact packaging immediately
The PFAS limits in food contact packaging have applied since 12 August 2026, with no grace period and including packaging manufactured before that date but placed on the market after it. If your flexible packaging uses fluorinated grease resistance or barrier coatings in food contact applications, test for total fluorine now. Fluorine-free alternatives exist. The lead time sits in testing, validating and transitioning supply.
3. Plan the transition to mono-material PE
Multi-layer laminates that combine incompatible polymers are likely to receive sub-grade-C recyclability ratings under the 2028 criteria, with a ban from 2030. Mono-material PE flexible structures are the format best positioned for the post-2030 EU market. Brands selling meaningful volumes across the EU should treat the laminate-to-mono-material transition as a near-term project, not a 2028 problem.
Frequently asked questions
Is soft plastic recycling infrastructure the same across all EU member states?
No, it varies considerably. Germany, Belgium and the Netherlands have mature systems for lightweight packaging collection, including flexible film. Sweden has world-leading sorting at Site Zero and is completing a national rollout of household packaging collection by 2027. France and Italy have large-scale EPR systems with variable MRF sorting quality. Southern and Eastern European member states generally have much less developed collection and sorting infrastructure for flexible film.
What will the PPWR recyclability grades mean for my flexible packaging sold in the EU?
The Design for Recycling criteria and A to C recyclability grades will be published by 1 January 2028. Packaging below grade C will be banned from the EU market from 1 January 2030. Multi-layer laminates combining incompatible polymers, foil-based structures, and metallised films are likely to receive lower grades because they cannot be effectively sorted and processed by European recycling infrastructure. Mono-material PE flexible structures are better positioned for higher grades. If the criteria are published on time, brands will have two years to move sub-grade-C packaging before the ban takes effect. Any delay to the criteria shortens that window, so waiting for publication is risky.
Why are EU plastic recycling facilities closing when demand should be increasing?
The closures reflect near-term economics, not long-term trajectory. Global oversupply of cheap petrochemicals has pushed virgin plastic prices down sharply, making recycled plastic uncompetitive on price. High European energy costs raise recycling operating costs. These are largely market pressures rather than a lack of long-term demand. The PPWR's mandated recycled content targets from 2030 will create structural demand for recycled PE and PP that is not subject to the same commodity volatility. That structural demand is what the recycling industry needs to invest in capacity with confidence.
What actually changed on 12 August 2026?
PPWR became directly applicable law in all 27 member states. From that date every packaging item on the EU market needs an EU Declaration of Conformity, PFAS limits apply to food contact packaging, heavy metal limits apply, producers must be registered in each market of placement, and non-established producers need an EPR authorised representative. It is not the date non-compliant packaging is banned. That is 1 January 2030, when Design for Recycling criteria, recycled content minimums and the Annex V single-use bans all take effect together. The harmonised EU labelling requirements do not apply in August 2026 either. They apply from 12 August 2028 at the earliest.