New minimum standard for determining the recyclability of packaging
Under Article 6 of the EU Packaging and Packaging Waste Regulation (PPWR), packaging must generally be recyclable. Exceptions apply, among other things, to contact-sensitive packaging for medical devices covered by Regulation (EU) 2017/745 and packaging used for the transport of dangerous goods in accordance with Directive 2008/68/EC.
The specific methodology for assessing recyclability will be set out in further acts adopted by the European Commission.
Until then, the minimum standard for determining the recyclability of packaging, published by the Central Agency Packaging Register (ZSVR) in agreement with the German Environment Agency, provides useful guidance for businesses. Taking actual sorting and recycling practices into account, it determines what proportion of a packaging item’s weight is available for material recycling.
An example from the ZSVR shows how strongly individual design features can affect the assessment. For a PET bottle with PP labels, a label adhesive that cannot be removed in an alkaline hot wash is classified as an incompatibility. Although the adhesive accounts for only a small proportion of the packaging’s weight and the PET bottle body is, in principle, available for recycling, the entire packaging item is rated 0% recyclable under the minimum standard. If a wash-off adhesive is used instead, the assessed recyclability in the example rises to 94.3%. This shows that even a single packaging component can have a decisive effect on the recycling outcome.
In future, producers of packaging that is not subject to system participation will require authorisation to fulfil their extended producer responsibility obligations. Under a transitional provision, producers may continue to make such packaging available on the German market without authorisation under section 19 of the German Packaging Law Implementation Act (VerpackDG) until 31 December 2027. From 1 January 2028, authorisation by the ZSVR will be required.
Bitkom Compliance Solutions would be pleased to help you prepare for the new requirements, from concise introductory seminars to in-depth workshops and in-house training.
