The European Union’s Plastics Strategy, formally adopted in 2020, was ambitious from the outset. By setting out targets like the requirement for 30% recycled content in all PET bottles by 2030, the EU signaled that voluntary commitments were no longer sufficient. It was always going to be about moving the market, not merely nudging it. What’s notable, perhaps, is how quickly implementation guidance began to materialize. By 2022, beverage producers were already being called upon to demonstrate—not simply claim—compliance pathways. And that has profound implications for supply chain management across the sector.
Much of the conversation around the 2022 guidance has focused on the challenge of verification. A target is one thing; proving that your PET bottles contain the specified recycled content is quite another. For large beverage firms accustomed to complex, multi-tiered sourcing structures, this has brought a new layer of scrutiny. Gone are the days when recycled content figures could be accepted at face value from suppliers without robust audit mechanisms. Now, producers are expected to trace plastic feedstock origins with a degree of rigor comparable to what we’ve seen in sectors like timber or conflict minerals.
National open data on recycled resin flows has become an essential tool in this context. Many EU member states now publish detailed data on the quantities and movements of recycled plastics, often as part of their environmental reporting obligations. These datasets—fragmented, yes, but improving—allow producers to cross-check supplier claims against national-level material flow data. It’s not always a straightforward task. Discrepancies inevitably arise, sometimes because of reporting lags or inconsistent methodologies. But the very existence of these data sources represents a significant step forward. Producers that are serious about compliance can no longer argue that independent verification is impossible.
What’s emerging is a picture of supply chain management that is far more data-driven than in the past. Producers are having to invest in systems that can integrate national resin flow data with internal procurement records. The goal is to build a coherent narrative: where the recycled content originated, how it was processed, and how it entered the bottle. It’s easy to underestimate just how difficult this can be. Plastic feedstock sourcing has traditionally been opaque, with multiple intermediaries and varying standards of documentation. The shift to open-data verification is forcing a rethinking of these relationships.
One practical approach for producers involves systematically mapping plastic feedstock origins using publicly available Extended Producer Responsibility (EPR) registries. These registries, which track how producers and importers fulfill their recycling obligations, often contain data that can help trace material flows back to their point of entry into the recycling system. The workflow isn’t always elegant. It might start with a producer extracting supplier declarations of recycled content percentages. From there, procurement teams can match those declarations to EPR registry entries, checking that the quantities reported make sense given national recycling rates and export-import balances.
This process can be time-consuming, but it has the advantage of creating a paper trail—or rather, a data trail—that can be audited. And that matters, not just for regulatory compliance but for reputational risk management. Producers that can demonstrate a defensible methodology for recycled content verification will be better positioned when, inevitably, their supply chains come under public or regulatory scrutiny. It’s a shift from relying on trust to relying on evidence, imperfect as that evidence may sometimes be.
Of course, no data source is perfect. National resin flow data, while invaluable, often suffers from gaps and inconsistencies. EPR registries, too, can vary significantly in quality and accessibility across member states. Producers need to be prepared for this and build flexibility into their systems. That might mean developing internal models to estimate recycled content flows where hard data is missing, or working with suppliers to improve the granularity of their reporting. The important thing is to recognize that data verification is no longer optional. It’s becoming integral to how beverage firms demonstrate alignment with EU policy goals.
This isn’t just a compliance exercise, either. There are strategic dimensions to consider. Firms that get ahead of these requirements can position themselves as leaders in sustainable packaging—a claim that resonates with increasingly eco-conscious consumers. Conversely, those that lag behind risk being locked out of key markets or facing costly remediation if found to be in breach of content targets. And given that the 30% target is only one part of a broader suite of plastics-related regulations, early investment in traceability systems could yield dividends well beyond PET bottle compliance.
One cannot help but note, however, that while the guidance offers a framework, many of the operational details are still being worked out in practice. Different countries interpret and implement reporting standards in their own ways. This creates challenges for pan-European producers trying to standardize processes. The hope is that, over time, greater harmonization of data reporting will emerge, but for now, firms must navigate a somewhat fragmented landscape.
The EU Plastics Strategy, with its 30% recycled content target, is setting a new benchmark for what’s expected of beverage packaging. It’s no longer enough to simply source recycled PET; producers must be able to show, through verifiable data, that they are meeting their obligations. This is driving a transformation in supply chain transparency—one that will likely spill over into other materials and sectors in the years ahead.