EU recycled-content rules for stretch film start in 2030: why 2027 is the year to test

1 January 2030 sounds far away.

For a stretch film change, it is not. A proper film trial takes months. Recycled resin has to be approved grade by grade. And the evidence a European buyer will ask for has to be collected from the first trial roll, not rebuilt later.

Checked against official sources on 28 October 2026.

My short answer: under the EU Packaging and Packaging Waste Regulation (PPWR), pallet wrapping film placed on the EU market must contain at least 35% recycled plastic "recovered from post-consumer plastic waste". The date is 1 January 2030, or three years after the Commission's calculation act comes into force, if that is later. The FAQ published by the Commission puts pallet wrap in that 35% group. The calculation method, and the rules for recycled plastic from outside the EU, are both due by 31 December 2026. So 2027 is the first year you can test film against rules that actually exist. It is also the last comfortable year to do it.

Which target applies to pallet wrap?

Article 7(1) of Regulation (EU) 2025/40 sets four groups.

1. 30% for contact-sensitive packaging made mainly of PET, except beverage bottles.
2. 10% for contact-sensitive packaging made of other plastics.
3. 30% for single-use plastic beverage bottles.
4. 35% for all other plastic packaging.

Stretch film round a pallet is not contact-sensitive, and it is not PET. The PPWR FAQ from the European Commission (second edition, August 2026) uses this exact case as its first worked example: "Pallet wrapping film to transport goods", non-contact sensitive, other than PET, "Art. 7(1)(d), 35%". By 1 January 2040 the figure rises to 65% (Article 7(2)(d)).

The same FAQ says the recycled-content rules apply to "any plastic part of sales, grouped, and transport packaging". Transport packaging is not let off.

There are exemptions in Article 7(4) and (5). The one exporters meet most often is packaging used to carry dangerous goods (Article 7(4)(f)). If you ship chemicals, check it.

When does it start, and can the date move?

The exact words are "By 1 January 2030 or 3 years from the date of entry into force of the implementing act referred to in paragraph 8 of this Article, whichever is the latest".

That implementing act sets the method for calculating and verifying recycled content, and it is due by 31 December 2026 (Article 7(8)). The planning record for it on the Commission website is called "Rules for the calculation and verification of recycled content in plastic packaging". It shows a call for evidence that closed on 16 September 2026 with 188 responses, and adoption planned for the fourth quarter of 2026. No draft had been opened for feedback by 28 October 2026.

If the act comes into force during 2027, the 35% date moves to three years after that. I would still plan for 1 January 2030. A late act buys you months, not years.

Three more dates sit around it.

1. Calculation and verification must follow the new method by 1 January 2029, or 24 months after the act enters into force (Article 7(11)).
2. By 1 January 2028, the Commission must assess whether some packaging in the 35% group needs a derogation (Article 7(12)). That is a review, not a promise of relief.
3. The FAQ says the rule applies to packaging placed on the market from the start date. There is no sell-off period for packaging supplied to manufacturers but not yet placed on the market by them.

What counts as recycled content?

Only post-consumer plastic counts. That rules out your own edge trim and production scrap, however clean they are.

For plastic recycled outside the EU, Article 7(3) adds two conditions. The waste must have been collected under separate-collection standards equivalent to those in the EU. And it must have been recycled in an installation under emission rules equivalent to the EU rules for industrial installations. A second implementing act, on how to assess and certify that equivalence, is also due by 31 December 2026 (Article 7(10)). Its planning record, "Conditions for importing recycled materials into the EU for use in packaging", shows the same plan for the fourth quarter of 2026.

For an Indian film maker like us, this is the point I watch most closely. Polyethylene collected and recycled in India will count in the EU only if its collection and recycling can be shown to be equivalent, by a method that is not yet published. The paper trail from waste collection to recycler has to start in 2027 if it is to cover film sold in 2030.

The target is also "calculated as an average per manufacturing plant and year". The FAQ explains that each plant must document, for each packaging type and format it makes for a manufacturer, that its yearly average meets the target.

Who has to prove it?

Article 7(6) puts the proof on "manufacturers or importers", in the technical documentation described in Annex VII.

For unbranded stretch film, the FAQ says the manufacturer is "the company that physically manufactures the wrap and places it on the market as packaging", not the company that buys the wrap and uses it to secure goods. That reading is disputed. On 19 August 2026, European Plastic Films, an industry group, asked the Commission to withdraw the example. It says national packaging registers from 16 countries published a different explanation on 25 June 2026. Until this is settled, I would write into every supply contract who keeps the recycled-content records.

Where the film is made outside the EU, the EU importer must make sure the non-EU manufacturer has done the conformity assessment and drawn up the declaration of conformity (Article 18, as explained in the FAQ). In practice, the evidence from the film maker has to travel with the film, or with the goods the film is wrapped round.

Why 2027 is the year to test

1. The rules arrive. The two methods due by the end of 2026 will say what evidence counts. A trial that collects that evidence from the first day is worth far more than one that has to be pieced together later.
2. Recycled resin varies. ExxonMobil's factsheet on recycled content in machine wrap is written by a resin maker that sells its own answer to the problem, so read it as vendor data. It notes that post-consumer feedstock usually contains LDPE and gels, which can reduce stretch and cause holes. In its test, a C4-LLDPE film with 20% recycled content broke earlier than the reference film. You need a grade that works on your loads, and then a second source of it.
3. Seasons matter. I would run the trial once in the hot months and again in the humid months, so you see the film in your own warehouse conditions.
4. India moves first. For obligated brand owners and producers in India, Category II film needs 20% recycled plastic from 1 April 2027. One well-recorded trial can serve both rules. See who carries the 20% under India's EPR.
5. Contracts come early. If your film contracts run for a year or more, the ones covering 2030 will be agreed in 2028 or 2029. I would want test data in hand before those talks.

A trial plan for 2027

1. Measure what you have

Before any new film, record five numbers for your current film: grams of film per pallet, containment force at top, middle and bottom (take the lowest), the pre-stretch the machine really achieves, film breaks per shift, and transit damage. Our guide to cast and blown film, pre-stretch and film per pallet explains each measurement.

2. Get lab data on the same basis

Ask each supplier for the recycled film and its virgin equivalent at the same gauge, tested by the same methods.

1. ASTM D5748, puncture resistance of stretch wrap film.
2. ASTM D5458, peel cling of stretch wrap film.
3. ASTM D1709, dart impact.
4. ASTM D882, tensile properties.
5. ASTM D5459, elastic recovery and stress retention.

I do not compare a number unless I know its test method. Neither should you.

3. Run it on the wrapper

Start at your current machine settings. Then adjust pre-stretch and wrap force within the film's rated range, one setting at a time. Include your heaviest and most awkward loads, not just the easy ones.

4. Ship it

Send trial pallets on real lanes, with at least one export container if you export. ASTM D8314 covers performance testing of stretch film as applied to a load, if you also want a lab test. For container loads, our guide on securing cargo in a container still applies.

5. Collect the paper

For every trial lot, keep the recycled percentage, the post-consumer share, the recycler's name and location, where the waste was collected, and the batch numbers. This is the start of the technical documentation you will need in 2030.

6. Decide with numbers

Keep the recycled film only if three things hold. Containment force stays at or above your standard. Grams per pallet stay within the band you agreed. Breaks and damage do not rise.

What we can and cannot offer today

We make blown polyethylene film in Jaipur. Our GRS certificate, issued by Intertek and valid to 23 March 2027, covers packing sacks and bags made with 50 to 100% post-consumer recycled polyethylene. It does not cover stretch film.

So if you ask us for recycled-content stretch film for an EU customer, we will tell you before you order what evidence we can supply for that grade. I would rather lose an order than sell a claim we cannot prove.

If you want to start a trial in 2027, tell us what you wrap, on which machine and for which market, through our contact page. We will help you set up the baseline in step 1.

This article is general information, not legal advice. The EU methods for calculating recycled content are still being written, so please confirm your position with your EU customer and an adviser on EU packaging law.