Design for Recycling becomes mandatory
An important milestone will be the publication of the Design for Recycling (DfR) guidelines by January 2028. These guidelines will define when packaging is officially considered recyclable, and according to the PPWR, this requirement extends far beyond theoretical standards.
Packaging must:
- be sortable in existing waste streams
- be recyclable in efficient industrial processes,
- produce secondary raw materials that can replace virgin materials.
At the same time, recyclable packaging will be rewarded with lower EPR fees through eco-modulation, while formats that are difficult to recycle will be subject to higher costs. As existing forms of eco-modulation already show, implementing these changes will be challenging in practice and very difficult to monitor.
2030: Recyclability as a Market Requirement
From 2030, packaging must be at least 70% recyclable to enter the EU market. Stricter rules, including the Recycled at Scale (RaS) requirement from 2035, will tie recyclability to real recycling rates. Additional measures like single-use plastic bans and reuse targets will change packaging and infrastructure further.
Mandatory recycled Content in Plastics
The PPWR sets required recycled content levels for plastic packaging:
- 2030, ranges between 10% and 35%, based on plastic type,
- 2040, rising to 25%–65%.
- Exceptions cover some medical or pharmaceutical packaging, and packaging with less than 5% plastic. These rules aim to drive demand for high-quality recyclates in critical uses.
By 2026, the European Commission will set standard rules for calculating and verifying recycled content to improve market transparency and regulation enforcement. Eco-modulation means packaging with higher recycled content may cost less, depending on national implementation.
Recycled at Scale (RaS): Integrating Design with System Effectiveness
The RaS requirement introduces an additional critical aspect. Packaging qualifies as recyclable only if it is recycled to a substantial degree within designated material streams. This criterion establishes a direct connection between product design and the real capabilities and performance of recycling systems. Although some requirements are still far off, current reports for packaging already demand recycling data and evidence.
Packaging Data that you are required to report
We assist you with your packaging reporting and submit your regular reports to the PROs or authority bodies. In this report, you list the amount of packaging you introduce to the market or country. The authority uses this information to calculate the material recycling rates (%) of recycled packaging. After submitting the report with material and packaging amounts, an invoice will be generated.
Reporting to PROs or Authority Bodies
Report packaging volumes in kilograms for all packaging types you put on the market, specifying if they are for households or other uses. Include packaging made from these materials in your report:
- cardboard/paper,
- wood,
- glass,
- metal (steel or aluminium),
- plastics and 6. other packaging materials (such as ceramics and textiles).
Recyclability and Reporting by Recycling Grade
(e.g., Denmark, Sweden, Finland, France, UK)
A number of countries have established graded recycling systems, featuring tiered fees according to the recyclability of packaging. These fees range from green (lower rates) to amber and red (higher rates).
In Sweden, both rigid and flexible mono-material plastic packaging can be easily identified through modern sorting technology, which streamlines material separation and improves downstream recyclability. This results in higher recycling rates and significant cost reductions for customers. Moreover, bonuses are awarded for paper and cardboard that are not laminated or coated, as these materials dissolve more readily during recycling, especially within paper mills.
To sum up, every EPR fee takes into account that mono-materials are simpler to sort and recycle, making them ideal for creating secondary raw materials. Regulations encourage replacing virgin materials with recycled alternatives. Additionally, colourinfluences sorting and recycling processes, which is why some countries require reporting by clear or coloured packaging.
By adopting Design for Recycling (DfR) principles in your packaging, your organisation can fulfil regulatory obligations and lower expenses.
Reporting Requirements for Single-Use Plastic (SUP) Products
For packaging reports in Nordic countries like Sweden and Finland, companies must identify any single-use plastic items in their product portfolio. If your company has single-use plastic products (e.g. plastic carrier bags), you are required to report their quantities in your SUP submission.
Future updates will cover more details on single-use plastics and packaging, including EPR stream information.
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We provide consulting and operational support for importers, producers, and resellers of packaging and packaged goods.