Does the 2030 recycled content obligation differ per EU country, or is the same standard applicable everywhere? The answer is that the standard itself does not differ. The requirements for recycled content percentages and the amount of empty space in a shipping packaging are set out in the PPWR, and that is a regulation. A regulation applies directly in every Member State, without a country needing to first transpose it into its own legislation. If you sell from the Netherlands to a customer in France, the same standard applies to that packaging as to packaging that remains in the Netherlands.
What does differ is not the standard but the practice around it: which authority inspects, in which language you must be able to demonstrate that you comply with the requirement, and which national register you are already registered with for your packaging. That practical layer is organised differently in each country, even though the substantive requirement is identical.
Why the standard itself remains the same
A directive leaves each Member State room to determine for itself how an objective is to be achieved, and that explains why EPR registration differs by country in thresholds, fees and registers. A regulation works differently: that text is the law, in every Member State at the same time and without national transposition. The recycled content and empty space requirements for 2030 are set out in the PPWR itself, and therefore fall under that second regime. That is also the reason why you do not need to find a different percentage per country on this point: the baseline is established at European level.
That makes this subject different from, for example, the annual report, where the submission deadline and the form can differ per national register. Recycled content and empty space concern a property of the packaging itself, not a national administrative obligation.
What does differ per country
The first layer that does differ is the registration within which you must demonstrate compliance with the requirement. If you sell in multiple EU countries, you are likely also registered in multiple national registers, each with its own registration procedure and its own times when data is requested. The content of the requirement is the same, but the office where you account for it is not.
The second layer is language and form of evidence. A technical file or substantiation that is drawn up in the Netherlands in Dutch may have to be submitted in the local language in another country as soon as a supervisory authority requests it. The regulation prescribes the standard, not the language in which you document it internally or externally.
The third layer is enforcement. How a national supervisory authority in practice checks whether a packaging meets the recycled content or empty space requirement, and with what intensity this is done, is not set out in the regulation itself and therefore differs by country. We deliberately make no prediction on this; that is a matter for the competent supervisory authority in the country in question.
What this means for your packaging file
Because the standard is the same across Europe, it is practical to establish the substantiation for it once properly and then link it per country to the correct registration. You do not need to rebuild a technical file that demonstrates what material a packaging is made of and what proportion of recycled content it contains for each country. However, it is useful to know per country which register the substantiation may be requested from and in what form.
For companies that supply in multiple countries, an overview of which role you have where is a good starting point before you look at the substantive standards. see in a few questions which countries you have a role in shows whether, and where, a registration obligation applies to you, separate from the recycled content or empty space requirement itself.
The substantiation of material choices and recycled content percentages belongs in the broader packaging dossier, together with the EU declaration of conformity and the other technical data. broken down by subject how that dossier is built up provides its structure without you needing an account first.
Because the standard is laid down in the regulation itself and not in national interpretations, it is advisable to consult the legal text or a legal expert in case of doubt about the correct application in a specific country, rather than relying on assumptions. We cite the guidelines in doing so and refer further; we do not provide a legal opinion on your specific situation.
Do you want to see what the recycled content and empty space requirement concretely means for your packaging and your sales countries, and how this relates to your registration obligation per country? check where our information comes from or start the free quick-scan to see in a few minutes where you already stand for 2030.