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PPWR Recyclability Guidance & Recycled Content Support

Supporting Your PPWR Readiness

As packaging regulations evolve under PPWR, two of the most critical areas for compliance are recyclability and recycled content. This guide is designed to help you understand what to look for, identify potential risks, and make informed decisions when selecting packaging for EU export.

Recyclability Guidance

What “Recyclable” Means Under PPWR

Packaging must be:

Designed for recycling (not just technically recyclable)
Compatible with existing EU collection, sorting, and recycling systems
Able to be processed at scale (not niche or limited recycling streams)

Future requirements will likely grade packaging (e.g. A–C), with poorly performing formats being restricted or phased out.

Key Principles of Recyclable Packaging

1. Prefer Mono-Material Formats

Use single materials wherever possible (e.g. 100% paper, 100% PE film)
Avoid combining materials that are difficult to separate (e.g. plastic + foil laminates)

✔ Good: Single polymer films, corrugated board
✖ Risk: Laminated films, mixed plastic types bonded together

2. Avoid Problematic Combinations

Certain elements can prevent recyclability:

Heavy adhesives
Non-removable labels
Mixed coatings or barriers
Dark/black plastics (hard to detect in sorting systems)

3. Design for Existing Infrastructure

Ask:

Is this packaging widely collected across the EU?
Can it be sorted using standard systems?
Is there an established recycling stream?

✔ Paper/cardboard: widely recycled
✔ Clear PET/HDPE: commonly recycled
✖ Multi-layer flexible films: limited recycling

4. Minimise Contamination

Keep materials clean and easy to separate
Avoid excessive inks, coatings, or residues
Ensure labels do not interfere with recycling

5. Clear Labelling

Include disposal instructions where required
Ensure materials are identifiable
Consider country-specific labelling expectations

Common Recyclability Risk Areas

Multi-material laminates
Overly complex packaging designs
Decorative finishes (metallics, foils, coatings)
Incompatible closures or components

Recycled Content Guidance

What is Recycled Content?

Recycled content refers to material that has been recovered and reused in new packaging.

There are two main types:

Post-Consumer Recycled (PCR): From household or commercial waste (preferred)
Post-Industrial Recycled (PIR): From manufacturing waste

Why It Matters Under PPWR

The EU is introducing minimum recycled content targets, particularly for plastic packaging
Targets are expected to increase over time (towards 2030)
Evidence and traceability will be required

Key Considerations When Using Recycled Content

1. Material Type Matters

Plastics (e.g. PET, HDPE) are a major focus for recycled content targets
Paper products often already contain recycled fibres

2. Percentage of Recycled Content

Understand how much recycled material is included (%)
Higher percentages may support compliance—but must still meet performance needs

3. Certification & Evidence

Look for:

Supplier declarations
Certifications (e.g. traceability schemes)
Documented proof of recycled content

4. Suitability for Application

Food contact packaging may have restrictions
Strength, clarity, or durability may vary
Not all products are suitable for high recycled content

5. Consistency & Supply

Recycled materials can vary in appearance (e.g. colour)
Availability may fluctuate depending on market conditions

Common Recycled Content Risk Areas

No evidence to support claims
Inconsistent supply or quality
Using recycled content where performance is critical without testing
Assuming all “eco” products contain recycled material

What You Should Be Asking

When reviewing your packaging, consider:

Recyclability

Is this packaging widely recyclable in the EU?
Are there any mixed materials or components that could cause issues?
Does the design align with current recycling systems?

Recycled Content

Does this product contain recycled material?
What percentage is included?
Can this be verified with documentation?

How We Can Support You

We understand that navigating these requirements can be complex. While compliance responsibility sits with the organisation placing packaging on the EU market, we are here to support you with:

Material specification sheets
Recyclability guidance based on current industry practices
Information on recycled content and available options
Alternative product recommendations where risks are identified
Bespoke labelling support
General guidance to help you make informed decisions

We encourage early engagement to review your current packaging and identify any potential improvements.

Important Note

Packaging regulations under PPWR are still evolving. Requirements, thresholds, and guidance may change, so regular review is essential to ensure ongoing compliance.