Last updated: August 17, 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 EU-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 compounded the problem. EPR fee revenues also fell in 2024, reducing cash flow to recyclers.
Total installed EU plastics recycling capacity was 13.5 million tonnes in 2024, well below the 6% annual growth rate required to meet PPWR targets. The PPWR's mandated recycled content requirements from 2030 are designed to create structural demand for recycled material that is insulated from commodity price swings. But that structural 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 flexible films in Europe stood at approximately 2.7 million tonnes in 2020. This represents about 28% of total plastics recycling infrastructure. 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 in 2024, 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 consistently achieves the highest overall packaging recycling rate in the EU at 80%, already exceeding the EU's 2030 target of 70%, and does so 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.
- The Triman sorting instruction logo is being replaced by the harmonised PPWR pictogram system.
- 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 achieves 76% overall packaging recycling 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 November 2023, described as the world's largest plastics sorting plant. It can sort 12 plastic types at 95% efficiency using AI and near-infrared (NIR) sensor technology, with flexible film as one of those 12 streams.
- Swedish packaging collection is municipality-owned and door-to-door, with legislation requiring 100% door-to-door collection nationally.
- 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: TOMRA's 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. TOMRA opened its Oslofjord facility in November 2025, handling 90,000 tonnes of plastic packaging per year and representing a new national infrastructure benchmark.
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 achieved 83% PET bottle collection within 18 months of launching its DRS in 2023, demonstrating how quickly well-designed systems 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.
Of 65 chemical recycling projects planned across Europe with a combined stated capacity of 2.8 million tonnes per year, only 18 plants were operational as of October 2025, producing approximately 290,000 tonnes per year. Economics, feedstock quality challenges, 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.
- EU regulatory clarification on mass balance attribution for chemical recycling is expected in 2026, which is projected to unlock stalled investment.
- The global advanced recycling market is forecast to grow at 13.16% CAGR from 2026 to 2034, with multi-layer films and contaminated packaging as primary feedstocks.
What the PPWR requires for soft plastic
The key milestones for flexible packaging
Already in force since 12 August 2026:
EU Declaration of Conformity required for every packaging item placed on the EU marketPFAS limits in food contact packaging under Article 5(5), applying in full from day one, including to packaging manufactured earlier Heavy metal limits, with a 100 mg/kg sum-of-four-metals thresholdProducer registration in each member state of placementAn EPR authorised representative for producers not established in the member state, one per country, with no size exemption
The PPWR creates the most ambitious regulatory framework for flexible packaging recyclability in the world. Key milestones for flexible film brands are:
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
PPWR mandates that all 27 EU member states implement eco-modulated EPR fees based on packaging recyclability grades by approximately 2029. This eliminates the current patchwork of different national EPR approaches and creates a consistent financial incentive for recyclable packaging design across the entire 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.
€7.6 to 9.1 billion PPWR investment requirements
It has been estimated that achieving EU flexible packaging recycling targets requires €7.6 to 9.1 billion in investment in collection, sorting, and processing infrastructure. PPWR's eco-modulated EPR mechanism from 2029 creates a dedicated, recurring funding stream for this investment that is not dependent on commodity market conditions.
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 EU recycling capacity crisis is real, but it is a cyclical economic problem. The PPWR's structural mechanisms, mandated recycled content, recyclability grades, and eco-modulated EPR fees, will resolve it over time by making recycling infrastructure commercially viable at the necessary scale.
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 no exemption for packaging manufactured earlier. 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, Sweden, and the Netherlands have relatively mature systems for lightweight packaging collection including flexible film. 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. The 2028 publication date gives brands two years to transition any sub-grade-C packaging before the ban takes effect.
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. EPR fee revenues fell significantly in 2024, reducing cash flow to recyclers. These are cyclical pressures. 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.
Sources and further reading