Materials and recyclability

    Design for recycling (DfR)

    Designing packaging so it can be collected, sorted and reprocessed at scale, and under PPWR a legal requirement graded from A to E.

    Design for recycling means treating recyclability as a design constraint rather than an end-of-life hope. In practice it covers material choice, the number of materials in a pack, the separability of components, pigmentation, label and adhesive selection, and closure design.

    PPWR converts this into a grading system. Packaging is assessed against design-for-recycling criteria and assigned a performance grade; packaging that falls below the threshold grade may not be placed on the market once the relevant date applies. This is a market-access rule, not a fee adjustment, which distinguishes it from eco-modulation.

    The recurring failure modes are consistent across categories: carbon black and dark pigments that defeat near-infrared sorting, PVC or metallised labels on PET, multi-material laminates that cannot be separated, and adhesives that survive fibre repulping.

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    Related terms

    • PPWR (Packaging and Packaging Waste Regulation)

      The EU regulation that replaces the packaging directive with directly applicable rules on recyclability, recycled content, reuse and labelling.

    • Recyclability

      Whether packaging is actually collected, sorted and reprocessed into new material at scale, not merely whether it is theoretically recyclable.

    • Near-infrared (NIR) sorting

      The optical sorting technology used in most material recovery facilities, which cannot detect carbon-black pigmented plastics.

    • Eco-modulation

      Adjusting EPR fees up or down according to the environmental performance of the packaging, rewarding recyclable design and penalising problem formats.

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