The Packaging and Packaging Waste Regulation

 
The Packaging and Packaging Waste Regulation (PPWR) differs from the Packaging and Packaging Waste Directive (PPWD) in its legal nature and scope. While the PPWD set foundational goals for packaging waste management, allowing member states flexibility in implementation, the PPWR introduces a uniform and binding framework across the EU, with stricter, more ambitious targets for recycling, packaging reduction, and reuse. The PPWR aims to standardise and enforce these rules directly across all member states, addressing gaps in the PPWD and aligning with the EU’s broader sustainability goals.


The coverage and application of the PPWR is unprecedented for reasons including:

  • Its applicability to all packaging placed on the European market, including imported packaging,
  • granting the right to outright banning non-conforming from participation in the European market by certain key dates,
  • and establishing strict definitions and structures to concepts, including the definition of recyclability-at-scale, and the harmonisation of Design for Recycling guidelines.

FREE PPWR Infographic

These requirements are just the tip of the iceberg, and many companies are not yet aware of the impact this will make on their regular business processes. In order to assist you in understanding this new status quo, CIRCPACK has developed a freely available and extensive infographic. Please download this infographic in your language below.

For a full overview of the PPWR, please access our comprehensive European Report, available with your ReCoRe subscription.
 

 

Frequently Asked Questions about the PPWR

The Packaging and Packaging Waste Regulation (PPWR) is a European Union regulation aimed at reducing packaging waste and promoting recycling across all member states. It builds upon the previous PPWD and introduces uniform rules and ambitious targets for packaging reduction, recycling, and reuse.

The PPWR is a regulation, meaning it is directly applicable and enforceable across all EU member states, ensuring uniformity. In contrast, the Packaging and Packaging Waste Directive (PPWD) allowed member states flexibility in how they implemented its goals, which led to variations across the EU.

No, the PPWR will not fully harmonise all requirements. While the PPWR sets uniform rules and standards across the EU, addressing many top-down discrepancies from the previous directive such as country-specific recycling targets, the implementation of EPR and DRS, and refill and reuse requirements.

Local implementations of bonus and penalty schemes in countries like the Netherlands and Spain will continue, including differences in fee categorisation and pricing. These local applications are not expected to significantly change due to variations in recycling systems and differing cost sensitivities across Europe.

The PPWR sets specific targets for reducing overall packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040. It also includes specific reduction targets for plastic packaging and mandates a minimum recycled content for packaging materials starting in 2030.

An overview of key targets will soon be published for our ReCoRe subscribers, split by the 19 packaging formats we currently cover.

The PPWR is expected to begin implementation in 2024/25, with various targets and requirements phased in through 2040.

The effective implementation date is currently subject to EU legislative processes, and will be updated as soon as it becomes available.

Almost all aspects within the PPWR are aimed at the reduction of packaging waste and the better management of materials which are placed on the market.

The PPWR introduces harmonised Design for Recycling (D4R) guidelines and establishes minimum recycled content thresholds for packaging materials. It also establishes the Recycled at Scale (RaS) assessment, which grades packaging based on how well it can be recycled using existing systems.

Businesses will need to comply with stricter regulations on packaging design, including meeting recycling and reuse targets, reducing packaging size, and increasing the use of recycled materials. Non-compliance will result in penalties and restrictions on market access.

The PPWR sets key requirements for all packaging to be met by 2030, including a minimum recyclability threshold and "at-scale" recycling assessment. Not meeting these minimum thresholds means that your packaging will not be allowed to participate in the European market.

While specific Design for Recycling criteria and at-scale requirements are still being developed, CIRCPACK is well positioned to forecast the future performance of your packaging for 2030, 2035, and beyond.

Through our connection with Veolia, collaboration with industry groups like RecyClass, and our comprehensive and freely available Design for Recycling (D4R) guidelines, we can provide actionable and clear insights to help you prepare for upcoming standards.

Reach out to our certification experts via email, or on our website, for a free consultation.

Certain types of packaging, such as medical and pharmaceutical packaging, or packaging for dangerous goods, may be exempt from some of the PPWR’s requirements. However, these exemptions are limited and specific, and not meeting these requirements may have implications for your business.

For example, pharmaceutical packaging not meeting the official requirements may be allowed to participate in the market, but will need to be strictly labelled to inform consumers of its non-recyclability.

Consumers can expect to see more sustainable packaging options and clearer labelling on packaging materials. This is being accomplished in conjunction with stricter European laws on so-called "green" labelling.

The regulation also encourages the adoption of reuse and refill systems, which will become more common in retail.

The PPWR is a key part of the EU’s strategy to transition to a circular economy, reducing reliance on virgin materials, minimising waste, and promoting sustainable packaging practices across the entire value chain.

Contact our experts at CIRCPACK for questions which you have relating to the PPWR and any of its implications or requirements. Our experts will answer your questions from an operational and theoretical perspective, enabling you to make informed decisions before all of the PPWR’s extensive requirements have been confirmed.

Want to ensure that your packaging is allowed on the market after 2030?

 

Test your packaging & get certified!  

Mini-masterclass


The following mini-masterclass serves as a representation of our full-length masterclass on recycling and is displayed in a Q&A format. In it, we introduce you to the critical concepts of packaging recyclability, share insights from our extensive industry experience, and provide practical tools to help you improve your packaging’s environmental impact. Whether you’re new to the subject or looking to deepen your expertise, these three modules are designed to equip you with the knowledge and confidence.
 


Our qualifications

As a key player in supporting brand owners and packaging companies, CIRCPACK helps you understand, assess, and enhance the recyclability of your packaging. What sets us apart is our material-agnostic approach and our strong belief in the benefits of harmonisation and cross-country alignment. These principles drive everything we do.

As part of the Veolia group, we are uniquely positioned to offer global expertise combined with local knowledge. With Veolia’s extensive network spanning 50 countries and supported by over 210,000 employees, CIRCPACK has unparalleled access to the latest innovations and operational facilities worldwide.

 

 

Module 1: Collection, Sorting and Reprocessing

 
This module offers a concise overview of the key aspects of recycling packaging waste. It explains what makes packaging recyclable, the importance of collection and sorting, and the role of Material Recovery Facilities (MRFs). The module also covers global variations in recycling systems, the technologies and innovations driving the industry, and why recycling practices differ between countries. This knowledge is essential for understanding how to design and manage packaging for optimal recyclability.

1.1 Recyclability

Recyclability refers to the ability of packaging to be efficiently collected, sorted, and reprocessed so that its materials can be reused in new applications. Of these four steps, collection and sorting represent the most important checkpoints for your packaging. True recyclability is influenced by several factors, including the availability of recycling infrastructure, market demand for recycled materials, and the overall business case of the recycling process.

At CIRCPACK, we leverage an extensive database that covers the recyclability of over 50 packaging format combinations across 71 countries. This wealth of information, accessible through our ReCoRe platform, helps us determine how likely your packaging is to be successfully recycled.

1.2 The basics

Collection and sorting are the backbone of the recycling process, together representing about 80% of the effort required to make recycling work effectively. These two steps are crucial in ensuring that recyclable materials are properly managed from the moment they are disposed of, so that they might find their way to a reprocessor.

You might wonder why we don’t use the terms "recycling" or "recycler" in this context. CIRCPACK sees the recycling process as being composed of four steps:

  1. Collection of a material ensures the
  2. sorting of a material, which ensures that it is
  3. reprocessed into a new raw material, which can be
  4. applied [1] to a new product.

The final step in the recycling process is often overlook, as it is the application of reprocessed materials into new products. This step ensures that the recycled materials are effectively reintegrated into the production cycle, reducing the need for virgin resources and contributing to a circular economy. The success of this stage depends on the quality and compatibility of the reprocessed material with its intended use, as well as market demand for products made from recycled content.

Collection is a critical first step in the recycling process because it ensures that recyclable materials are captured and not lost to landfills or incineration.

Proper collection gathers all possible materials, creating the foundation for effective recycling. Without efficient collection systems, valuable recyclable materials may never reach the sorting or reprocessing stages, undermining the entire recycling effort.

Sorting is essential because it separates collected materials into their respective streams, directly impacting the quality and efficiency of the reprocessing stages. This often occurs at a MRF.

Effective sorting ensures that materials are properly categorised, preventing contamination and maximising the potential for high-quality recycling. Even the most recyclable packaging can be rendered useless if not correctly sorted, making this step vital for the success of the recycling process.

The reprocessing [2] infrastructure for packaging waste is composed of specialised facilities tailored to handle different materials. Once properly sorted material gets to this step, it is often likely to be recycled into a new raw material.

For example, specific paper grades are sent to paper mills, beverage cartons go to specialised mills designed to handle composite materials, and various types of plastics are directed to reprocessors equipped to manage specific polymers. Similarly, glass, metals, and wood are sent to dedicated reprocessors that specialise in reclaiming these materials for reuse.

A Material Recovery Facility (MRF) [3] is a specialised plant designed to sort and process household waste into distinct material fractions, such as plastics, metals, paper, and glass.

Once sorted, these materials are directed to reprocessors, each specialising in recycling a particular type of material, ensuring that waste is converted back into valuable resources as efficiently as possible. The effectiveness of a MRF can vary widely depending on the technology used, the design of the facility, and the local recycling infrastructure. For example, collection systems which implement source separation, often in the form of different waste bins, have a significant impact on the efficiency of MRFs.

1.3 Technologies and locality

The effectiveness of recycling systems are deeply influenced by the technologies used in collection and sorting, as well as the local context in which they operate. Advanced technologies play a crucial role in optimising the recycling process, from the initial collection of materials to their precise sorting within facilities. However, the maturity and sophistication of these systems can vary widely across different regions, leading to significant differences in recycling outcomes.

Low-tech solutions, such as incentivising citizens to separate waste or collect bottles and cans with deposits, can catch a significant portion of the so called "low-hanging fruit" in a recycling context.

Understanding the local factors that drive these variations—ranging from technological capabilities to economic and cultural influences—is more important than ever.

Collection systems for packaging waste vary widely, not only between countries but often within the same country. For instance, in the UK alone, there are 39 different bin collection regimes managed by 391 Local Authorities, each with its own set of rules and practices. In the United States, the diversity is even greater, with over 3,000 distinct recycling initiatives spread across 50 states. Similarly, across Europe, bin types, colours, and sorting methods can differ significantly from one country to another. However, the upcoming PPWR aims to harmonise these systems to reduce such disparities in the European Union.

To navigate these complexities, ReCoRe provides detailed insights into the collection systems within each country, allowing you to compare different approaches easily. Our platform’s compare tool makes it simple to analyse these variations, helping you understand how collection systems may impact the recyclability of your packaging. For a closer look, you can explore our freely available Italy report.

Collection and sorting infrastructure varies significantly both within and between countries, shaped by factors like local policies, investment in recycling technologies, and public engagement. While some regions boast advanced systems with cutting-edge technology, others rely on more basic or even informal methods. However, it’s important to note that the level of technology does not always equate to the effectiveness of recycling systems.

For example, Brazil, despite having less advanced technology available than some areas, achieves a recycling rate for aluminium cans comparable to that of leaders in recycling. This is largely due to the extensive network of informal waste collectors who play a crucial role in the recycling process by targeting and sorting valuable waste flows. This shows that different systems can be equally effective, even if they operate differently.

To help you understand these dynamics, our ReCoRe platform provides a colour-coded map detailing the maturity of collection and sorting systems across the globe. This tool allows you to compare and assess the effectiveness of recycling systems in different regions, enabling you to make informed decisions about your packaging strategies based on local conditions via a basis of comparison.

Advancements in technology have significantly enhanced both the collection and sorting of packaging waste, making these processes more efficient and effective.

In terms of collection, the use of differentiated curbside bins remains standard in many regions, allowing households to easily separate their recyclables. Additionally, reverse vending machines have popped up in areas with Deposit Return Schemes, enabling consumers to return beverage containers for a refund. Smart bins equipped with fill-level sensors are another innovation, helping waste management services optimise collection routes and reduce operational costs.

When it comes to sorting, a variety of technologies are employed both outside and inside sorting facilities. Mechanical sorting often begins with a barrel drum, which separate materials based on size. Optical sorting technologies, such as Near-Infrared (NIR) detection, are used to identify and separate different types of plastics and other materials. Eddy current separators are used to sort non-ferrous metals, while magnetic separators handle ferrous metals. Ballistic separators are used to sort between 3d and 2d packaging formats.

The integration of Artificial Intelligence (AI) has further revolutionised sorting in new ways, with robotic arms now capable of accurately identifying and ejecting specific types of packaging based on programmed criteria. This AI-driven technology represents another approach to increasing the precision and speed of sorting, helping to maximise the recovery of recyclable materials.

Recycling systems vary widely across countries due to a complex mix of factors including political decisions, economic conditions, cultural awareness, consumer behaviour, market dynamics, historical context, and the availability of infrastructure and investment. Each of these elements influences how waste is managed, from the way materials are sorted to the technologies used for reprocessing.

As a result, no two countries approach recycling in exactly the same way, leading to significant differences in efficiency and effectiveness.

1.4 Innovation

The waste management industry is experiencing a wave of innovations that span from product design materials to cutting-edge technologies in recycling facilities. Among these, Artificial Intelligence (AI) has become an investment hub, with AI-powered robotic arms now being used to enhance the precision and efficiency of the sorting process by accurately identifying and separating materials.

Another groundbreaking innovation is the so-called HolyGrail 2.0, or digital watermarking initiative, which pioneers the use of digital watermarks in packaging. These watermarks, invisible to the naked eye, can be detected by specialised sorting equipment, allowing for more accurate sorting and recycling of materials.


Module 2: Design and Certification

Below you’ll learn the preliminary requirements for creating packaging that is easily recyclable. We explain the principles of DfR, the importance of obtaining recyclability certification, and offer access to free DfR guidelines. The module also guides you on how to assess your packaging’s recyclability before formal certification and provides detailed information on country-specific recyclability schemes, ensuring your packaging meets local and international standards.
 

2.1 Design for Recycling (DfR)

Design for Recycling (DfR or D4R) in the packaging world refers to creating packaging solutions that are easily recyclable at the end of their use. This approach involves several key practices, including but not limited to:

  1. Using single materials within packaging instead of mixed, or composites.
  2. Minimising unnecessary packaging layers
  3. Utilising packaging with mature recycling streams
  4. Clear labelling for efficient disposal
  5. Avoid numerous adhesives, inks or decorations

DfR guidelines are tailored for various packaging formats, and at CIRCPACK, we closely align with RecyClass to ensure that plastic packaging meets these standards, helping to optimise its recyclability. All of our DfR guidelines are available under the glossary found in our knowledge centre.

Yes. You can access comprehensive Design for Recycling guidelines for all packaging formats directly on our website or under the glossary found in our knowledge centre on ReCoRe. For plastics, our guidelines align with RecyClass standards, while all other materials follow CIRCPACK’s proprietary methodology.

These resources are available to help you design packaging that meets recyclability standards and supports sustainable practices.

Some individual countries have developed recyclability schemes and DfR principles that match their local recycling environment [4].

For instance, in Germany, you must comply with the Mindeststandard, a stringent set of criteria that dictates how packaging must be designed to ensure it can be efficiently recycled within the country’s advanced recycling systems. Similarly, in the Netherlands, you need to navigate through the national RecycleCheck program, ensuring your packaging aligns with Dutch standards.

At CIRCPACK, we understand that navigating the diverse landscape of recyclability standards across different countries can be challenging. We have consultants strategically located across Europe, each with deep expertise in the local regulatory environment. This allows us to provide you with tailored advice on how to meet specific recyclability requirements in various markets.

2.2 Certifications

A certification serves as validation of your packaging meeting Design for Recycling guidelines. The certification process itself provides a rigorous assessment of your packaging’s recyclability, offering proof that your materials can be effectively collected, sorted, and reprocessed in a particular market.

Obtaining a recyclability certification for your packaging is important for several reasons. From demonstrating environmental responsibility to ensuring regulatory compliance and enhancing your brand’s reputation, certification enables you to guarantee your commitment to responsible packaging to both consumers and regulators. Additionally, with the upcoming PPWR, your financial obligations may soon be linked to the recyclability grade of your packaging, making certification even more crucial. This becomes even more important when you consider the Green Claims Directive and related topics which increase the requirements associated with making sustainability claims.

CIRCPACK’s team of consultants is uniquely equipped to help you assess and certify the recyclability of your packaging, regardless of the format, ensuring that your packaging meets the highest standards by testing it in one of our Veolia MRFs.

You can get an initial assessment of your plastic or metal packaging’s recyclability using the Recyclass online tool. This tool provides a preliminary score, which you can download as a PDF.

You can then share this report with one of CIRCPACK’s consultants to begin the official certification process, ensuring that your packaging meets all necessary standards.


Module 3: Producer Responsibility

 
Here we cover essential legal frameworks and responsibilities surrounding packaging and packaging waste. We provide a limited overview of the main laws governing packaging, explain the concept and importance of Extended Producer Responsibility (EPR), and detail the role of Producer Responsibility Organisations (PROs). The module also explores how EPR obligations vary across different countries, helping you understand the diverse regulatory landscape and its impact on your packaging practices.
 

3.1 Core concepts

Extended Producer Responsibility (EPR) is a policy approach that holds manufacturers accountable for the entire lifecycle of their products, from design and production through to disposal. While EPR can apply to a wide range of products, including electronics, batteries, and vehicles, our primary focus is on packaging, referred to in the UK as pEPR.

EPR is an effective lever because it aims to reduce excess waste, conserve resources, and promote sustainable product design via fiscal levies, alongside bonuses and penalties. By making producers responsible for ensuring that their packaging can be efficiently collected, sorted, and reprocessed for reuse, EPR not only helps to minimise environmental impact but also fosters greater environmental awareness and accountability by driving companies to design packaging which is easily recycled. This approach creates innovation in packaging design, encouraging the development of more sustainable materials and systems that support a circular economy.

A Producer Responsibility Organisation (PRO) is an entity that plays a central role in the implementation of EPR policies. PROs help companies fulfil their EPR obligations by financing the collection, sorting, and recycling of products and packaging at their end-of-life. They also compile essential data for reporting to local authorities, monitor the performance of different packaging formats, and encourage producers to design packaging with recycling in mind.

While they can exist as either competitive for-profit organisations or non-profits, PROs need to manage these responsibilities, ensuring that EPR systems operate efficiently and that producers are supported in meeting their environmental obligations.

Yes. These differences can manifest in various aspects such as the scope of products covered, financial mechanisms, reporting requirements, enforcement and penalties, eco-modulation (which adjusts fees based on the environmental impact of products), and the level of stakeholder involvement.

Each country implements EPR according to its own regulations and priorities, meaning that businesses must navigate a complex landscape of varying requirements. Please keep in mind that the differentiation between EPR fees in Europe is not expected to simplify under the PPWR.

To help you manage these differences, our ReCoRe platform provides detailed information on how each country implements EPR, including the most recent fees where applicable.

Fees are typically used to fund various aspects of the waste management system, ensuring that producers contribute to the environmental costs associated with recovering their products. These fees are directed toward financing the collection, sorting, and recycling of packaging and other products at the end of their life cycle.

For a direct example, think of companies like Amazon and FedEx, where the last mile is the most difficult and often expensive part of delivering a package. The recycling system has the same problem, but in reverse order. For this reason, collection and sorting often match the 80% rule described earlier with the same amount of every Euro earmarked for operations under an EPR scheme.

In addition, EPR fees support the infrastructure needed for effective waste management, such as the development and operation of MRFs and other reprocessing facilities, public awareness campaigns, and environmental education programs. They may also be used to cover administrative costs associated with managing EPR schemes, including compliance monitoring and reporting.

 

3.2 Local legislation

Packaging and packaging waste are governed by a wide range of laws and regulations worldwide, each with its own specific requirements. Understanding and navigating these varied legal frameworks is crucial for businesses involved in packaging, as compliance not only ensures regulatory adherence but also supports broader sustainability goals and enhances brand reputation across different markets.

All legislation can be efficiently compared by ReCoRe users via our comparison tool.

In the European Union, the foundational legislation has been the Packaging and Packaging Waste Directive (94/62/EC), which has recently been updated and strengthened by the Packaging and Packaging Waste Regulation (PPWR). This new regulation introduces more stringent and harmonised requirements across the EU, focusing on extended producer responsibility (EPR), recycling targets, material restrictions, labelling requirements, waste reduction, and take-back schemes, aiming for a more circular economy.

In North America, both the United States and Canada have a more decentralised approach, with state or provincial-level legislation that works in tandem with federal laws. These regulations address similar themes—EPR, recycling, and waste reduction—but can vary significantly between regions, making compliance a more complex challenge for businesses operating across multiple states or provinces.

The regulatory landscape in AME is diverse and still emerging. Some countries have started implementing EPR schemes and recycling targets, but overall, the region faces challenges related to infrastructure and enforcement. However, there is a growing awareness and push towards more sustainable packaging practices, driven by both international influence and local environmental concerns.

In Latin America (LATAM), packaging waste regulations are evolving rapidly. Countries like Chile and Peru are leading the way with EPR laws and mandatory recycling targets. However, enforcement and infrastructure can vary widely across the region, with some countries still developing their regulatory frameworks.

There is significant diversity in packaging and waste management laws in APAC. Countries like Japan and South Korea have well-established systems with strict recycling and EPR regulations. Meanwhile, other nations in Southeast Asia are in earlier stages of developing comprehensive waste management laws, though there is a growing focus on reducing plastic waste and improving recycling rates.


 

Do you want to learn more about the world of recycling?

 

Register here for our
MASTERCLASS RECYCLING

(Available in English, French, Spanish, Italian and German)

Circpack.veolia.com

4 online sessions
& 1 individual Q&A session

 

The program

 

Here’s what they have to say about it:

 

A very complete overview on Recycling in a record time! It is a must for all pack developers working on Eco-conception development.

Camille Detry Lecointe
Group Leader new sustainable pack material
BEL Group

 

It’s been my pleasure to join the MasterClass! It’s been really good for us as we’re increasing our knowledge in this complex world!

Luiz Campos
Global Senior Packaging Engineer
AVON

Our teammates benefited greatly from this extensive and hugely helpful course on market dynamics and operational nuances in the recycling industry.

Larry Logan
Chief Evangelist, Sustainability Solutions
Digimarc Corporation

 

The Masterclass is a great opportunity to get insights from the experts of recycling. Thank you for sharing your expertise with us!

Stefan Vyge
Business Development & Technical Manager
Yupo Europe GmbH

Packaging materials & DfR guidelines

Polyethylene Terephthalate (PET), a clear, durable, and lightweight polymer, is widely used for product packaging such as soft drink bottles and containers due to its eco-friendly properties. PET is a semi-crystalline polymer with excellent chemical resistance and mechanical properties.

Design for Recycling guidelines for Clear PET Bottles

Design for Recycling guidelines for Coloured PET Bottles

Design for Recycling guidelines for Transparent & Clear PET Thermoforms

These guidelines are considered applicable for bio- or fossil- based PET and validated in coordination with RecyClass.

Polyethylene (PE) is a versatile and lightweight plastic that comes in various forms, including High Density Polyethylene (HDPE). It is widely seen in packaging applications due to being a strong, rigid, and chemical-resistant plastic material and can be used for milk jugs, detergent bottles, and grocery bags.

The differing densities and molecular weights of HDPE, LDPE, and LLDPE result in distinct properties, with HDPE being more rigid and strong. Other versions of polyethylene also exist, tailored to specific applications and requirements.

Design for Recycling guidelines for Natural & White PE Rigids

Design for Recycling guidelines for Coloured PE Rigids

These guidelines are considered applicable for bio- or fossil- based PE and validated in coordination with RecyClass.

Polyethylene (PE) is a versatile and lightweight plastic that comes in various forms, including Low Density Polyethylene (LDPE), and Linear Low Density Polyethylene (LLDPE). These are widely used in packaging applications due to being flexible, lightweight, and moisture-resistant plastic, often used for plastic cling wrap, produce bags, and squeezable bottles. These are subcategories of PE and have lower density when compared to HDPE, making it more flexible and less rigid.

The differing densities and molecular weights of HDPE, LDPE, and LLDPE result in distinct properties, with LDPE being more flexible and pliable, and LLDPE offering enhanced puncture resistance and flexibility compared to LDPE. Other versions of polyethylene also exist, tailored to specific applications and requirements.

Design for Recycling guidelines for Transparent PE Flexibles

Design for Recycling guidelines for Coloured PE Flexibles

These guidelines are considered applicable for bio- or fossil- based PE and validated in coordination with RecyClass.

Polypropylene (PP) is a heat-resistant and durable plastic used in food packaging like yoghurt containers and microwave-safe food trays. It is a semi-crystalline polymer with a high melting point, making it suitable for high-temperature applications. Rigidity in polypropylene plastics can be related to their thickness and grade. These are stiff, strong, and impact-resistant materials used for packaging applications such as bottle caps, closures, and storage bins.

Design for Recycling guidelines for Natural & White PP Rigids

Design for Recycling guidelines for Coloured PP Rigids

These guidelines are considered applicable for bio- or fossil- based PP and validated in coordination with RecyClass.

Polypropylene (PP) is a heat-resistant and durable plastic used in food packaging like yoghurt containers and microwave-safe food trays. It is a semi-crystalline polymer with a high melting point, making it suitable for high-temperature applications. Flexibility in polypropylene plastics can be related to their thickness and grade. These are pliable materials used in packaging applications like plastic bags, cling film, and flexible pouches for food and beverages.

Design for Recycling guidelines for Transparent PP Flexibles

Design for Recycling guidelines for Coloured PP Flexibles

These guidelines are considered applicable for bio- or fossil- based PP and validated in coordination with RecyClass.

Polystyrene (PS), a lightweight and versatile plastic, can be expanded (EPS) or solid (HIPS). EPS, or styrofoam, is used for insulation and packaging, while HIPS is used for disposable cutlery, CD cases, and yoghurt containers.

Design for Recycling guidelines for Natural & White PS

Design for Recycling guidelines for Coloured PS

These guidelines are considered applicable for bio- or fossil- based PS and validated in coordination with RecyClass.

Polyvinyl Chloride (PVC) is a versatile, durable, and chemically resistant plastic material. It is used in various applications such as pipes, vinyl siding, and blister packaging for consumer products. PVC can be rigid or flexible depending on the addition of plasticizers.

No Design for Recycling Guidelines are currently available for PVC.

Residual waste is often locally non-recyclable waste, such as heavily soiled packaging, broken glass, ceramics, and disposable diapers, is placed in the residual waste bin and typically sent to landfills or incinerated for energy recovery.

The definition of materials which qualify as residual waste can differ from country to country, often depending on the local capabilities of collection, sorting, and recycling systems.

Derived from wood pulp and similar sources, paper and cardboard are versatile, biodegradable, and recyclable materials used for a wide range of packaging purposes. Paper is commonly used for wrapping, labels, and bags, while cardboard is typically used for boxes, cartons, and other forms of protective packaging. Their susceptibility to moisture and limited durability can pose challenges in recycling applications.

Design for Recycling guidelines for Paper and Cardboard

Ferrous metals are metals which contain iron, with steel being the most common, and are used in food and beverage packaging, such as canned goods, jar lids, and bottle caps, as well as in construction and automotive industries. These materials are generally magnetic.

Design for Recycling guidelines for Steel

Non-ferrous metals are metals without iron content, primarily aluminium but including tin and copper. These are often lightweight, corrosion-resistant, and recyclable. Aluminium is commonly used for beverage cans, foils, and food trays.

Design for Recycling guidelines for Aluminium

Beverage cartons are a type of multi-layered packaging for liquid products, composed of fibres (generally 75%), plastic ( 20%), and aluminium ( 5%). They are often used for packaging milk, juice, and other beverages, and are commonly known as Tetra Pak or gable-top cartons.

Design for Recycling guidelines for Beverage Cartons

Glass is a recyclable and reusable material often made from silica, soda ash, and limestone. Glass is widely used for packaging food and beverages, as well as various household items such as jars and bottles. Its transparency, chemical inertness, and impermeability make it an ideal choice for preserving product quality, alongside its ability to be recycled with limited loss of quality.

Design for Recycling guidelines for Glass

Bio-based plastics are derived fully or partially from biological resources, such as plants or renewable biomass, and help reduce dependence on fossil resources. Although bio-based plastics do not necessarily guarantee biodegradability or compostability, assessing their environmental impact involves considering factors like land-use, carbon, and the life cycle of the material.

No specific Design for Recycling Guidelines are currently available for Bio-based plastics.

Please use the material specific Design for Recycling Guidelines found on this page if you are interested in design specifications for Bio-PET, Bio-PP, Bio-PE, and Bio-PS.

Biodegradable plastics break down into natural materials, such as water, carbon dioxide, and biomass, under specific conditions at their end of life through the action of microorganisms. These plastics, which do not indicate the raw materials used in manufacturing, can be made from biological resources or fossil raw materials. Their recycling potential depends on the availability of appropriate facilities and infrastructure for collection and processing.

No Design for Recycling Guidelines are currently available for Biodegradable plastics.

Compostable plastics are a subset of biodegradable plastics decompose into nutrient-rich soil under controlled conditions, typically in industrial composting facilities. Derived from biological resources or fossil raw materials, these materials must be collected separately from traditional recyclables to ensure proper treatment.

No Design for Recycling Guidelines are currently available for Compostable plastics.

 

Type of collection

Municipal Solid Waste (MSW) refers to the everyday items and materials discarded by the general public in an urban area. This includes household waste, commercial and institutional trash, and sometimes construction debris.

MSW typically comprises a mix of organic matter, plastics, paper, glass, metals, and other materials.

Refers to the collection of recyclable packaging made of Plastics, Metals, and Beverage Cartons (PMD) (also called Drink cartons). Common across Europe, these waste materials are sent to sorting centres to be separated into dedicated waste streams.

Dedicated to Paper & Cardboard waste, each country defines its own fibre-content threshold, which indicates the minimum percentage of fibre packaging must contain to be accepted. Thresholds range from 50% (France, Spain, Sweden) to 95% (Germany).

Specific to Germany, this waste stream stands for Paper, Paperboard, and Cardboard (PKK in German). Developed due to Germany’s high-quality paper & cardboard packaging requirements, it demands a minimum of 95% fibre content. Packaging with lower fibre content is sorted separately and considered recyclable to a certain extent (downcycling applications due to low-quality input).

This collection combines recyclable waste, including PMD packaging (plastics, metals, beverage cartons) and paper & cardboard packaging. Deployed in a limited number of European countries (France, the United Kingdom, Greece, Ireland, etc) and is more common in developing countries.

Also known as kerbside collection, this system involves collecting waste from containers placed at citizens’ doorsteps.

Citizens bring their pre-sorted waste to dedicated containers shared by a neighbourhood in this collection method.

 

Recycling system terminology

A policy principle that extends producers’ responsibility for their products throughout the entire life cycle, particularly focusing on the post-consumer stage. This is often enacted via eco modulated fees by PROs who are given agency by national bodies.

A system in which consumers pay an additional, visible deposit for beverage packaging and can reclaim the deposit upon returning the packaging to an approved collection point. These systems can be publicly or privately managed.

An organisation that helps producers fulfil their Extended Producer Responsibility by managing the collection, recycling, and disposal of products on their behalf.

A specialised facility where collected recyclable materials are sorted, processed, and prepared for shipment to manufacturers who use these materials to create new products.

A recycling system in which all recyclable materials (such as paper, plastic, glass, and metal) are collected together, rather than being separated by the consumer. The mixed materials are then sorted at a Materials Recovery Facility (MRF).

A recycling system where recyclable materials are separated into two categories, usually paper products in one stream and containers (such as plastic, glass, and metal) in the other. This separation is done by the consumer before collection, leading to a cleaner and more efficient recycling process.

The process of repurposing waste materials into new products with reduced quality and functionality, often resulting from the degradation of material properties during recycling. When recycled materials lose some properties or become degraded by the recycling process, they cannot be fully reintegrated into their original applications. Consequently, these materials undergo downcycling, where they find use in alternative, valuable applications, such as repurposing recycled material for construction or other industrial sectors. While downcycling contributes to resource conservation, it may not offer the same level of sustainability as closed-loop recycling, which maintains the material’s original quality and function.

A recycling system in which waste materials are collected, processed, and used to create new products of the same type, thereby minimising the use of raw materials and reducing waste. This is namely the case for PET bottles recycled into new PET bottles.

A waste management system in which households and businesses are charged based on the amount of waste they produce, incentivizing waste reduction and increased recycling.

 

Recycling maturity

Countries with mature recycling infrastructures have well-established and efficient waste management systems in place. They often achieve high recycling rates, incorporate advanced sorting and processing technologies, and implement comprehensive waste management policies, such as Extended Producer Responsibility (EPR) and Deposit Return Schemes (DRS). Additionally, they prioritise waste reduction and resource conservation through public education and awareness campaigns. Examples of countries with mature recycling infrastructures include Germany and Belgium.

Countries with developing recycling infrastructures have made progress in establishing waste management systems but may not yet achieve the efficiency or recycling rates seen in mature systems. These countries are actively working to improve their recycling capabilities, often through the implementation of new policies, technology adoption, and investments in waste management infrastructure. Public awareness and education around recycling may still be expanding. Examples of countries with developing recycling infrastructures include China and Canada.

Countries with limited recycling infrastructures often face significant challenges in managing waste, resulting in lower recycling rates and higher levels of waste disposal in landfills or through uncontrolled methods. These countries may lack well-developed waste management policies, adequate infrastructure, or public awareness about recycling. Investments in waste management systems and recycling technologies are typically limited, and the implementation of progressive policies such as EPR and DRS is rare. Examples of countries with limited recycling infrastructures include Colombia and Ivory Coast.

How does getting certified with CIRCPACK work?

Why CIRCPACK?

CIRCPACK is uniquely positioned to certify your packaging formats due to our positioning within the Veolia group. As an independent consultant under our packaging organisation, we have unrivalled access to hundreds of facilities around the world where we can test the sorting effectiveness of your packaging.

Our primary sorting facility is a state of the art MRF [5] located in Germany which manages plastics, metals, and drinking cartons. This facility has been outfitted with RFID scanners, allowing us to follow your packaging until the exact point where it encounters a problem.
 

Test your packaging & get certified!

Certification process

At each stage of this process, we ensure that your packaging undergoes the necessary evaluations to meet industry standards for recyclability.
Below is a step-by-step guide outlining what you can expect.

1. Preliminary Stage

 
Once you’ve requested to get in touch, our experts will reach out to you and schedule an introductory call. During the call, we will determine what is required to validate the recyclability of your packaging.

We offer the following certifications:

Design for Recycling

Used for complete and final packaging. It classifies the technical recyclability of plastic packaging within the European market.

Recycling Assessment

Used for complete and final packaging. It classifies and rates the technical recyclability of plastic packaging in a specific country.

Letter of Compatibility

Used for semi-finished packaging. It classifies the technical recyclability of a semi-finished plastic packaging within the European market.

If your packaging is composed of plastic or metal, we recommend that you complete a quick assessment of your packaging format using the RecyClass online tool. By having these results already available, we can ensure that we hit the ground running together.

We typically ask for details about your packaging format, including material data sheets, masterbatch information, and use cases. We always recommend completing the RecyClass online tool if your packaging includes plastic or metal.

RecyClass provides a user-friendly online tool for assessing the recyclability of plastic packaging. Our experts can guide you through the process if needed.

Direct link: https://recyclass.eu/tool/

2. Dedicated Proposal

After our initial discussion, you will receive a dedicated proposal tailored to your needs. Once the document is reviewed and signed, we initiate the certification process.

Costs vary depending on the complexity of the packaging and the tests required. We will provide a detailed cost breakdown in the proposal.

Payment is normally accomplished via a Purchase Order and direct invoicing to your desired destination. We unfortunately cannot take credit card payment at this time.

The timeline varies depending on the complexity of your packaging and whether additional testing is required. On average, the process can take up to three weeks, depending on project scope.

3. Data Collection

We will need you to complete the holistic input data sheet, which is the starting point for our analysis. For plastic and metal packaging, this includes filling in the RecyClass application form and completing their online tool. For fibre-based and glass packaging, we will ask you to complete a separate document matching our CERTIFY methodology.

Yes, you can submit multiple packaging formats for certification. Each will be evaluated based on its unique characteristics and materials.

Each element of a packaging format can affect its overall recyclability. For instance, knowing the inks and adhesives used in a pressure-sensitive label helps assess whether the label could pose a challenge for the packaging to behave as expected during sorting and reprocessing.

Ultimately, accurate certification relies on understanding your packaging from two perspectives: our laboratory, where we look to understand its material composition, and in our Material Recovery Facilities, where we look to understand its real life "in situ" performance. Combining these two perspectives is what sets CIRCPACK apart.

4. Sorting Tests

If necessary, a sorting test is conducted to evaluate how your packaging performs in a recycling facility. This could involve assessing whether your packaging can be properly sorted into the correct recycling stream or whether or not it is behaving as expected, for example based on the description of a raw material supplier.

A typical example of this is cylindrical packaging. While the material composition of such a packaging format might imply that it is effectively recycled, residual product causes it to roll indefinitely on a belt at a MRF, preventing effective ejection into the proper sorting stream. If this happens, these formats are removed due to their impact on efficient recycling in these MRFs.

Cylindrical [6] packaging is a common example of this issue. Although its material composition might suggest that it should preform well, leftover product inside can cause it to continuously roll on the conveyor belts at MRFs. This rolling can prevent the packaging from being correctly sorted into the appropriate recycling stream.

No. Sorting tests are only conducted if necessary, depending on the specific characteristics of your packaging and how it interacts with sorting technology.

For plastic and metal packaging formats, we work in conjunction with RecyClass.

For fibre-based or glass packaging formats, we follow our CERTIFY methodology.

For more information, please visit the RecyClass website or reach out to our consultants.

5. Reprocessing Tests

For certain packaging types, we may need to conduct reprocessing [7] tests. These tests replicate industrial recycling conditions on a smaller scale. This could include evaluating glue removal, fibre loss, or ink bleeding. The testing is based on RecyClass Quick Test Procedures or the EPBP’s QT500-508 guidelines.

To ensure a high level of performance in both our sorting and reprocessing tests, we recommend that you follow our publicly available Design for Recycling guidelines.

These are available in the ReCoRe glossary or our website.

For plastic and metal packaging formats, we work in conjunction with RecyClass.

For fibre-based packaging formats, we align our CERTIFY methodology with the CEPI 2.0 methodology.

For glass packaging formats we follow our CERTIFY methodology, which includes a dedicated optical glass sorting test.

For more information, please visit the RecyClass website or reach out to our consultants.

6. Audit Report

After the data collection phase is complete and any required tests are carried out, we compile an audit report. This report outlines the findings and assessments of your packaging’s recyclability.

Specific PPWR requirements have not yet been published by the European Commission. However, it is expected that the upcoming Design for Recycling rules are going to be in line with both RecyClass and CIRCPACK guidelines due to their high-level alignment on a common principle: the proportion of your packaging format which is composed of recyclable material. This is directly measured in your audit report.

Final DfR guidelines from the EU are expected at a maximum of 18 months after entry into force of the PPWR.

Yes, the certificate will detail your packaging’s overall recyclability grade, including the proportion of your packaging format which is composed of recyclable material.

Even if it’s not fully recyclable, the report provides insights into why that is.

7. Certificate

Upon completion of the audit, a certificate will be issued specific to your project. This document details your packaging’s final recyclability grade and a recyclability rate for one or more European countries if requested.

The results of your certification not meeting your expectations can be the result of a variety of factors.

In our experience, these factors can stem from issues such as inconsistencies in the material composition or masterbatch information, which can lead to unexpected outcomes during the certification process. Additionally, the performance of your packaging after it is collected as waste may impact its ability to be effectively sorted.

In the event that a score does not meet your expectation, CIRCPACK is happy to walk you through the exact reason why this occurred alongside our technical team.

Once certified, you will receive guidance on the use of logos, allowing you to communicate your packaging’s recyclability grade to consumers (B2C) and partners (B2B) as defined by RecyClass.

You are also given the opportunity to enter into further discussions with our consultants about improving your packaging format’s performance in a recycling context.

8. Use of Logo

Once certified, you will receive guidance on the use of logos for plastic and metal packaging, based on RecyClass claim guidelines. For other materials, CERTIFY aligns with industry-specific requirements for logo usage.

Your packaging’s grade must be a C or above in order to make claims.

The type of certification you’ve undertaken determines the possible use-cases for communication.

For Design for Recycling certifications, the logo cannot be used on final packaging but can but used within B2B and B2C communication.

For Recyclability rate certifications, the logo can be used on both final packaging and within B2B and B2C communication.

For Letters of Compatibility, the logo cannot be used on final packaging but can be used within B2B and B2C communication as long as class and use case is stipulated.

Yes, certification needs to be renewed around every three years to ensure that your packaging continues to meet recyclability standards. Renewal frequency will be outlined in your certification guidelines.


Want to ensure that your packaging is recyclable?

 

Test your packaging & get certified!

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