We received active participation and various questions during the webinar, which we are addressing in this article in a question-and-answer format.
Compliance and Regulation
- Collection, sorting, and recycling infrastructure varies significantly among EU member countries, and there's a lack of harmonization. At what level will compliance be required – EU level, or based on available infrastructure and national legislation in the national markets where the packaging is placed?
The PPWR is a binding legislation enforced at EU level, so the Member States, regardless of their individual infrastructure and national legislation, are expected to comply with the obligations set out in the PPWR.
PPWR mandates various obligations for both Member States and economic operators, which include manufacturers and distributors. For instance, Member States are given specific targets for recycling and waste prevention that they must comply with. Similarly, economic operators are required to meet certain criteria. For example, they must adhere to guidelines concerning the recycled content and design for recycling (DfR) of their packaging materials. These are essential conditions for market access and must be validated through technical documentation, as outlined in the Regulation.
Regulation aims to enhance the efficiency of the internal market by establishing rules that harmonize national measures. - Will products produced outside of Europe and imported into Europe need to comply with the PPWR?
Yes, PPWR should apply to all packaging placed on the market in the EU area, including imported packaging. - Do we know the exact penalties for failure to comply, or does it depend on each case?
The PPWR has not yet defined penalties. These may differ depending on the degree of non-compliance and the particular Member State where the packaging is being sold. The responsibility to establish and implement penalties for PPWR violations lies with the Member States. - When do you expect more information to be available about PPWR? Q4?
We expect more information to become available once the European Parliament and the Council endorse all the different language versions of the text. Then we move towards entering into force which we expect to be at end of Q4, 2024. That is the next checkpoint when we expect to receive more information. - Are you not too optimistic in saying that PPWR sets a global example? The real problem lies in markets with inadequate waste management infrastructure.
The PPWR does set a good global example. One of the aims of the regulation is to promote recyclability and boost the circular economy which also means promoting and developing the waste management infrastructure. Particularly with ecomodulated EPR fees, it is anticipated to establish a system that encourages the adoption of more sustainable and circular packaging solutions.
Recycling and recyclability
- What is behind the grades A / B / C?
Recyclability performance will be graded as A, B, or C, based on the ‘design for recycling’ criteria set by the European Commission by January 2028. Each grade represents a different level of recyclability per unit, with A indicating a recyclability of 95% or more, B indicating a recyclability of 85% or more, and C indicating a recyclability of 70% or more. These grades consider factors such as the ability to separate packaging waste into different material streams for recycling and the available recycling technologies and their economic and environmental performance.
Starting from 2035, an additional factor, ‘recycled at scale’, will be introduced. This factor is based on the volume of material that is effectively recycled across different packaging categories. It provides a measure of the scale at which recycling is successfully implemented for each type of packaging.
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Is there a special RecyClass guideline for self-adhesive labels?
RecyClass has established guidelines for different types of plastic packaging materials. These guidelines cover the requirements for all components of the packaging, labels included. -
What is the equivalent of RecyClass for fiber-based packaging?
The 4Evergreen Alliance is a cross-value chain initiative within the fiber packaging industry, with a primary focus on enhancing the recycling of fibre-based packaging in Europe. The Alliance develops Recyclability evaluation protocols, which assess the recyclability of packaging, Circularity by design guideline, which provides design principles for circularity, and guidance on enhancing the collection and sorting of fibre-based packaging to facilitate recycling. -
Will mass balance be allowed in the future?
The role of the mass balance approach in achieving minimum recycled content levels is yet to be detailed in secondary legislation. The European Commission will define the calculation and verification procedures for recycled content by the end of 2026. -
Is there still an issue with claiming recyclability for self-adhesive labels due to the glue constituents? If so, what is UPM Raflatac doing to develop friendlier glue so that paper labels can be claimed as recyclable when applied to any surface?
We continue to work on developing a wider variety of labels that enhance the recyclability of packaging. While the adhesive is a critical component of self-adhesive labels, it is essential that the entire label, in combination with the packaging, supports material recycling. Therefore, we focus on creating functional label solutions tailored to specific packaging types, including developing specialized adhesives.
Currently, we offer paper label materials certified as recyclable for fiber packaging, as well as HDPE, PP, and PET rigid packaging material streams. We remain committed to investing in research, innovation, and collaboration across the value chain to develop recycling-compatible solutions that meet market needs and drive the industry beyond fossils. - What about labels used in the food chain and recyclability challenges due to food legislation? Will there be more development in solutions for the food chain?
Labels used in the food chain face unique challenges due to food safety and hygiene regulations. Labels must comply with food safety standards, which can limit the types of adhesives and materials that can be used. We continue developing solutions for the food chain keeping a close eye on the development of recycling streams, including the increasing closed-loop systems and their special requirements.
Recycled content
- Will labels have to comply with mandatory recycled content?
The specifics of when plastic labels must contain post-consumer recycled content are not yet fully defined. In PPWR, derogation applies to plastic components that constitute less than 5% of the total packaging weight. This derogation also extends to certain types of packaging, such as some contact-sensitive and compostable packaging. By the end of 2026, the European Commission is set to establish calculation methods for recycled content through secondary legislation, which will further clarify these requirements, including those for labels. - Can recycled plastics be used for primary food packaging?
Yes, certain types of recycled plastics can be used for primary food packaging, provided they meet the stringent requirements set by food safety regulations. For example, PET bottles are often recycled and reused for the same purpose. Additionally, chemically recycled PP and HDPE have been approved for use in food packaging.
Furthermore, there are label solutions made from recycled plastics that are also suitable for use in food packaging. However, it’s important to note that not all recycled plastics are suitable for this purpose, and each type must adhere to regulatory requirements to ensure it doesn’t pose a risk to food safety.
New Wave Label Specifics
- I don't fully understand the New Wave concept. It is compatible with HDPE and PP recycling and it washes off. So, can it be removed from the HDPE and PP stream?
The New Wave is a recycling compatible paper label for rigid HDPE and PP packaging. RecyClass Letter of Compatibility confirms its compatibility across HDPE and PP streams, including white and natural materials. New Wave labels wash off cleanly in 40°C plain water and they separate easily from HDPE and PP due to material density difference. In addition, they are paper labels with no fiber loss and maintain the high clarity of the washing water. Thanks to these properties, New Wave paper labels can be removed from the HDPE and PP material streams. - Is the New Wave adhesive better for recycling of the packaging compared to conventional adhesives if it is not removed before recycling?
Yes, the New Wave adhesive is better for recycling of the packaging compared to labels with conventional adhesives. In the recycling process, there is typically a washing stage. Conventional labels may not detach and separate during this stage, potentially contaminating the recycling stream and affecting the quality of the recycled material. However, the New Wave adhesive is designed to wash off at 40°C, ensuring that the label detaches effectively during the washing process. This allows for a cleaner recycling stream and improves the overall recyclability of the packaging. - The New Wave paper label washes off at 40°C water. Could it be used in the shower without falling off?
The New Wave Label is a mid-gloss paper label material designed for high-quality, multicolor decorative labels, particularly in home and personal care applications where premium moisture resistance is required. This label material washes off at 40°C water, which raises questions about its performance in a shower.
For the New Wave label to wash off, it needs to be properly soaked with water to activate the adhesive removal. Under standard shower conditions, the New Wave label should withstand exposure without falling off. However, we are currently engaging with industry experts to conduct extensive testing to ensure its durability and performance also in extreme shower conditions. - Up to what coldest (freezing) temperature is the New Wave label adhesive-resistant?
Based on our most current knowledge and experience we recommend a minimum labeling temperature of 5°C and a minimum service temperature of -5°C. Nevertheless, the performance of the product should always be tested in the actual application conditions.
Key takeaways from the webinar highlighted the importance of following the development of the EU secondary legislation on Design for Recycling, which will define the criteria and performance requirements for recyclable packaging. Currently, the practical approach in the packaging value chain is to engage with leading bodies that provide Design for Recycling guidelines tailored to different packaging types and materials in specific geographical areas.
In conclusion, navigating the PPWR transformation requires a proactive approach, staying informed about legislative developments, and embracing collaboration. By focusing on these key areas, businesses can not only comply with new regulations but also drive innovation and sustainability in packaging.