Introduction and Regulatory Framework: Positioning of the PPWR
The term “recycled content” refers to the proportion of secondary raw materials in packaging and is gaining increasing importance in the context of European regulation. With the EU Packaging and Packaging Waste Regulation (PPWR), the regulatory landscape has fundamentally changed. The regulation entered into force in 2025 and is now being implemented step by step.
Whilst specific minimum quotas for the use of recycled materials (input) have been set for plastic packaging, the PPWR focuses primarily on recyclability (output) for metal packaging. This means that, from 2030, tinplate will also be subject to binding design requirements under the Recyclability Performance Grading.
Packaging must achieve high efficiency classes (A to C) in order to remain marketable in the long term. Due to its material properties and highly efficient sortability, tinplate already meets these requirements at the highest level today.”
This regulatory distinction is closely linked to the material properties of steel. Steel is considered a so-called permanent material that can be recycled without significant loss of quality. At the same time, there is an established and economically relevant market for steel scrap, meaning that the use of secondary raw materials already occurs intrinsically within the system and does not need to be enforced by regulation.
Challenge of Measurement: System vs. Individual Product
The precise determination of a recycled content at the level of a single package is, in the case of steel, technically not directly measurable. The reason lies in the production processes: in blast furnaces and electric arc furnaces, primary and secondary raw materials are used together and are completely mixed.
In Europe, tinplate production takes place within a highly interconnected production system. While there are numerous steelworks, there are only a limited number of specialized facilities for tinplate production. . This results in a logistical reality: packaging steel is not necessarily recycled where it is later reused as packaging.
From an environmental perspective, however, this is not a problem. What matters is not the return to the same product (‘closed loop’), but the maintenance of the material cycle as a whole. Steel from packaging can also be used in construction, automotive or mechanical engineering applications – and thus remains permanently within the cycle.
This system follows the principle of regional material flows within the EU, where transport distances are minimized and resources are used efficiently.
Recycled content in practice To nevertheless provide guidance for market players, Steel for Packaging Europe (the association of European manufacturers of packaging steel, based in Brussels) works with statistical model values. These compare the quantity of packaging steel collected in Europe with the total production of packaging steel.
Current estimates for 2026 range from approximately 65 to 70 per cent. These are explicitly model-based average values intended for communication and comparison purposes. Due to the complete mixing of materials in the production process, physical traceability of individual material flows is not possible.
Recycling Rates: The Key Metric
In contrast to recycled content, the recycling rate is a directly measurable and reliable metric. This is where the strength of tinplate becomes particularly evident.
In Germany, the recycling rate for packaging steel has been at a very high level for years and regularly exceeds 90 percent in the consumer sector. Most recently reported values were above 94 percent for private end consumers. At European level, too, the recycling rate remains stable at around 80 per cent. Steel thus already meets key objectives of the European circular economy, which are being further specified within the framework of the PPWR.
The high recyclability is largely based on the physical properties of the material. Steel is magnetic and can therefore be efficiently separated from waste streams, enabling almost complete recovery.
Recyclability and Future Evaluation Systems
The PPWR provides for the introduction of a standardized assessment system for the recyclability of packaging. This so-called “Recyclability Performance Grading” will influence the level of license fees within the framework of Extended Producer Responsibility (EPR).
Due to its excellent sortability and recyclability, tinplate packaging is expected to be classified in high rating categories. However, specific and binding classifications have not yet been finalised.
Material properties: Recyclability without loss of quality
A key advantage of steel lies in its virtually unlimited recyclability. Unlike many other materials, its fundamental properties are retained even after multiple recycling cycles. Whilst impurities can play a role in the process, these are largely eliminated during steel production.
Organic components such as coatings or lacquers are removed at high temperatures, resulting in a high-quality material that can be reused in a wide range of applications.
Conclusion: System performance rather than individual metrics
Tinplate is a prime example of a functioning industrial circular economy. Whilst the focus for other materials is heavily on recycled content, steel demonstrates that the overall performance of the system is decisive.
For companies, this means that the key metric is not the calculated recycled content of a single piece of packaging, but rather the high recycling rate, efficient recovery and the associated reduction in CO₂ emissions.
