Four stages at which it can go wrong
And all four lie beyond your warehouse
The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and has been largely applicable since 12 August 2026; other obligations are being phased in. Recyclability is one of its more demanding subjects and, at the same time, the subject that attracts the most claims with the least supporting evidence. That is because “recyclable” must mean four things at once:
- Collected. Does the packaging actually enter a separate waste stream at the recipient’s premises? An industrial customer with a baler is very different from a small business with a single residual-waste bin.
- Sorted. Is it recognised as the correct material during sorting? Colour, dimensions and composition all play a part.
- Processed. Can the material technically be processed into a usable raw material without contaminants damaging the process or the end product?
- Sold. Is there a market for the resulting secondary raw material? Without an end market, the chain still comes to a halt.
For your assessment, this means that the question “is this recyclable?” cannot be answered without knowing where the packaging ends up. The circumstances are more favourable for industrial packaging than for consumer packaging — large volumes, clean, sorted and concentrated in one place — but that remains an assumption worth checking with a few customers.
How contaminants affect each stream
Paper and board, and PE film
Recovered paper and board
This process is about fibre recovery: the board is pulped in water and the fibres are extracted. Anything that prevents the fibres from separating or cannot be screened out interferes with that process. Water- and grease-resistant coatings and wet-strength additives make board resistant to the very medium used to break it down during recycling. Bonded plastic windows, non-paper labels and tape must be removed as rejects. Heavy printing primarily affects the quality of the recovered fibre.
None of these components makes a box unusable. The point is that they burden the stream, and quantity matters: a small label is not the same as a fully laminated outer surface. The practical components involved are covered on the page about corrugated board and the PPWR; the difference between kraftliner and testliner is explained in the material guide.
PE film
Film recycling involves melting and re-extrusion, so the purity of the polymer stream is decisive. Mono-PE therefore offers the most favourable starting point. Complications include coloured and especially black film, which is harder to sort; multi-layer films containing other polymers, which cannot be separated in conventional processing; and contamination from labels, tape or product residue, which reduces the value of the bale.
Pallet film has the advantage of becoming available clean and dry in large volumes. This makes the industrial stream relatively straightforward — provided the film is recognisably made from a single material. More information is available on the page about stretch film and the PPWR.
Why your product does not yet have a score
And why that is no reason to wait
The PPWR is moving towards design-for-recycling criteria and recyclability performance classes, but these are still being developed at European level. Until that work is complete, a definitive recyclability class cannot be assigned to an individual product. A supplier that does provide one should be able to explain what it is based on — and that is a reasonable question, not a difficult one.
Useful design-for-recycling guidelines do already exist within the industry. They offer practical help with design decisions, but they have no legal status and do not predict what the European criteria will look like. Use them as a tool for identifying choices that are unlikely to cause debate, not as evidence.
What to record now
Work that will be useful in any event
The inventory below will be useful regardless of the final wording of the criteria, because any version will require this information. Use three columns for each packaging item:
Which components does it contain? Main material, coatings, adhesives, inks, tape, labels, windows and closures — including their weight if you can obtain it.
Why is each component present? Which functional requirement makes it necessary? If nobody knows the answer, that is the first place to investigate.
Is there an alternative? Could another component or design provide the same function with less material or with a single material? Also record the alternatives you rejected and why.
That third column is what will make a later assessment convincing: not a claim that you made the best choice, but evidence that you considered the alternatives. The page on supplier information explains which data to request from your supplier and how to maintain the records.
Frequently asked questions about recyclability
Brief, specific answers in plain English
As a material stream, paper and board are widely recycled; EU Member States have an 85% by weight recycling target for paper and board packaging waste by 2030. That is a target for the waste stream, not proof that every individual box is readily recyclable. Coatings, adhesive, windows, labels and contamination can affect the actual recycling route.
No. The European design-for-recycling criteria and recyclability performance classes are still being developed. I can assess the known areas of concern, identify missing information and help you request it from your supplier. Nobody can guarantee a future class.
It does simplify the recycling route because nothing needs to be separated. However, mono-material can conflict with a functional requirement, such as a moisture barrier. The question is then whether that requirement is genuinely necessary and, if so, whether the proportion of non-recyclable material can be reduced.
Record which non-paper or non-mono-material components your packaging contains, why they are present and whether an alternative can provide the same function. This inventory will be useful regardless of the final criteria and will save work later.
Sources and scope
What this guidance is based on
- EUR-Lex — Regulation (EU) 2025/40 — the text of the Regulation. Opens in a new window.
- RVO — EU legislation: packaging requirements (PPWR) — Dutch government information. Opens in a new window.
- Verpact — About the PPWR — the timeline and implementation in the Netherlands. Opens in a new window.
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