You dream of using sustainable packaging. Packaging that is good for the planet, that enhances your brand image and that your customers appreciate. But when you delve into sustainability, you soon come across terms like “recyclability” and “circularity. And then the search begins for exactly what that means technically, and how to make sure your packaging really contributes to that circular economy.
Navigating through all the rules and directives, such as the current Dutch Essential Requirements and the upcoming EU PPWR, can feel quite like a maze. You wonder: what should I pay attention to now Where do I start What if I make the wrong choices and my packaging will soon no longer comply Or worse, what if I think my packaging is recyclable, but technically it’s not at all
We get those frustrations. Sustainability in packaging is more than just a pretty picture or a marketing term. It is in the technical details, in the material and in the design. And those very details determine whether your packaging really can be given a new life after use. At MultiTray we have been breathing the technical side of packaging for years. We believe in transparency and a no-nonsense approach, so you know exactly where you stand. Let’s dive into those technical criteria together, so you’re well prepared for the future.
The current basic essential requirements in the Netherlands
Currently, the Essential Requirements from the 2014 Packaging Management Decree apply in the Netherlands. This is the basis. In short, these requirements say that your packaging must meet a few key points. These include, for example, minimizing weight and volume. You don’t want to use more material than necessary. Logical after all
In addition, your packaging must be suitable for reuse or recovery, such as material recycling. And very importantly there are limits on the presence of heavy metals, such as lead and mercury. Together, these must not exceed 100 ppm. These are pretty important points, and as a producer you are responsible for demonstrating that your packaging complies with them. There is often an internal administration or process to keep track of this. European Directive 97/129/EC also provides guidelines for the identification codes on your packaging so that it is clear what material it is made of. This is the current reality. But the world of packaging is not standing still.
The EU packaging and packaging waste regulation PPWR
Why is there now new legislation coming from Europe again? Why can’t it just stay with those Dutch rules? Good question. The EU saw that the current rules, a directive, were not being adhered to equally strictly across Europe. This creates an uneven playing field and less effective recycling. The new EU Packaging and Packaging Waste Regulation (PPWR) is therefore a regulation. This means that the rules apply directly in all EU member states, without countries still having to put them into national law. This creates clarity and consistency across Europe.
The PPWR has ambitious goals. The main goal is to make all packaging on the EU market recyclable by 2030 and then actually recycle it on a large scale. There are also targets for using recycled material and reducing unnecessary packaging.
The timeline of the PPWR is important to keep an eye on. The regulation was recently adopted and will officially take effect soon. Starting in 2030, packaging must meet specific technical criteria for recyclability. Further deadlines will follow after that for recycled content and “Recycled at Scale,” for example. So it is really important to look ahead now.
The PPWR has a broad scope. It deals with all packaging, regardless of material, placed on the EU market. It also considers the relationship with existing legislation, such as the SUP (Single Use Plastics) Directive.
PPWR Recyclability Core Criteria.
Okay, now it gets technical. Because what exactly does “recyclable” mean according to the PPWR?
Requirement 1 Be recyclable by 2030
From 2030 it will be mandatory: all packaging you put on the EU market must be designed for recycling and recyclable at scale. This may sound logical, but the technical interpretation of this is crucial and is defined by specific criteria within the PPWR.
Criteria Detail 1 Design for Recyclability DfR
This is where the design of your packaging becomes as important as the material itself. Design for Recyclability is all about choices you make while developing your packaging so that it can be easily and efficiently sorted and incorporated into existing recycling processes.
Consider, for example, the use of monomaterials. This means that as much as possible, a package consists of one type of plastic (such as only PET or only PP). Why is this important? Because sorting machines, often using Near-Infra-Red (NIR) technology, separate different types of plastic from each other based on their chemical composition. If your packaging consists of a mix of different plastics (a multilaminate), sorting and thus recycling becomes much more difficult, if not impossible. Monomaterials increase the chances that your packaging will end up in the right recycling stream.
But DfR goes further. Look at components such as closures, labels, adhesives and inks. Are they made of the same material as the main packaging Can they come off easily or are they recognized by sorting machines and can be recycled with them A label that, for example, is larger than 50% of the surface area of a PET tray and is made of a non-compatible material can interfere with the sorting process. An adhesive that does not dissolve during the washing processes at the recycling plant may affect the quality of the recyclate. Ink colors that mask NIR signals may cause problems.
The EU is still developing detailed DfR guidelines (expected in 2028), but based on current knowledge and best practices, we can already do a lot. Examples include avoiding certain dyes (such as black in PET, although solutions to that are now emerging), choosing easily removable labels with compatible adhesives, and designing closures that can be recycled along with the base material. At MultiTray, we keep a close eye on these developments and are happy to advise you on smart DfR choices. Our customization process is entirely focused on this: we help you develop packaging that meets the highest DfR standards.
Criteria Detail 2 Recycling Performance Grades RPGs.
The PPWR is introducing a system of Recycling Performance Grades (RPGs). Packaging is assessed and given a score, probably divided into grades such as A, B, C, D, and so on. This score indicates how well the packaging performs in terms of recyclability.
From 2030, only packaging with a score in the higher classes (A, B or C) may be placed on the market. This means that your packaging must be able to demonstrate a minimum recyclability of 70% based on technical criteria. Packaging with a lower score (class D or lower) will be banned. This directly impacts the market access of your products. It can also affect the fees you pay for producer responsibility (EPR). The more recyclable your packaging is, the lower the fees can be.
As with DfR, the exact calculation methodologies for these RPGs are still being worked out by the EU (expected in 2027). But the basics are clear: the design and choice of materials must ensure that at least 70% of the weight of your packaging can be effectively recycled.
Criteria Detail 3 “Recycled at Scale” by 2035
This criterion goes a step further than just the potential for recyclability (DfR and RPGs). “Recycled at Scale” means that a particular type of packaging is actually widely collected, sorted and processed within the EU, and that there is a market for the resulting recyclate.
Starting in 2035, specific packaging types must demonstrate that a minimum of 55% (for most materials) or 30% (for wood) of the weight placed on the market is actually recycled in the EU. This emphasizes the effectiveness of the entire packaging system, from consumer to recyclate user.
Methods to measure this are also still being specified (expected in 2030). It is a complex process involving collection systems, sorting facilities and recycling technologies throughout Europe. But it does emphasize that your packaging must not only be technically recyclable, but also fit within the existing infrastructure. This is where our knowledge of materials such as rPET and processes is important. rPET, for example, is a highly demanded and highly recyclable material in the Netherlands and Europe with an established collection and recycling infrastructure.
Practical preparation for businesses
Okay, those were the technical details. Now how do you deal with this as a company And where do you start
- Assess Your Current Packaging: The first step is to know where you stand now. Are your current packaging already designed with recyclability in mind Are they monomaterials What about labels and closures There are tools, such as the KIDV Recyclecheck, that can help you with this.
- Implement DfR in your Design: This is the time to take Design for Recyclability seriously. Involve this already in the design phase of new packaging. Work with suppliers who have expertise in this. Think about material selection (preference for monomaterials), minimizing multiple components and choosing compatible adhesives and inks. Our new product tool is just for streamlining this process and taking the right criteria into account right away.
- Make Conscious Material Choices: Each material has its own recycling challenges and opportunities. PET, PE, PP, paper, glass, metal they all have specific DfR concerns. In plastic packaging, for example, rPET(circularsource) is an excellent choice because it is made from recycled material and is itself highly recyclable. Make sure your partner informs you well about this.
- Cooperation in the Boiler: Recyclability doesn’t stop at your door. Talk to your packaging suppliers (that’s us), but also consider the impact on collection, sorting and recycling. A good packaging partner understands the whole chain.
- Compliance and Documentation: The Packaging Passport: The PPWR places a heavy emphasis on documentation. You must be able to demonstrate that your packaging complies with DfR and RPG requirements. This is called the “packaging passport.” It is essential to keep detailed records of your packaging, materials, components and associated technical specifications. This is the basis for the declaration of conformity that you must prepare under the PPWR. Setting up a robust system for this is crucial to avoid penalties or market restrictions.
Related PPWR requirements
In addition to recyclability, the PPWR has other important requirements, such as ambitious targets for the proportion of recycled material in plastic packaging (from 2030 and 2040), packaging minimization rules (e.g., maximum void space in certain packaging), and even bans on specific single-use packaging types from 2030. These too are elements to consider when designing and sourcing packaging.
Conclusion
Truly sustainable packaging requires you to look beyond just the material. The technical criteria for recyclability, as defined in the upcoming EU PPWR and building on the current Essential Requirements, determine the future of your packaging. Design for Recyclability, RPG scores and “Recycled at Scale” are not abstract terms, but concrete requirements that impact your operations, your costs and your brand reputation.
Deadlines are approaching. Now is the time to critically review your current packaging, adjust your design processes and make sure you have proper documentation. Start on time so there are no surprises. With the right knowledge and a partner who thinks with you, like us at MultiTray, you can confidently take the steps toward truly circular and compliant packaging. We’d love to help you get started.
Do you have questions about how your packaging meets these criteria or would you like to spar about a new packaging design that is ready for the future Please feel free to contact us or request a quote directly. Together we will make sure your packaging is technically and practically recyclable.
frequently asked questions
- My current packaging has a recycling logo does that mean it is 100% recyclable?
Not necessarily. A recycling logo indicates that the material may be recyclable. Whether it is actually and effectively recycled depends on many factors, including design (DfR), the presence of other materials or components, and the availability of collection and sorting infrastructure. The PPWR introduces more technical clarity into this.
I use a mix of materials in my packaging e.g. cardboard with a plastic window is that still allowed soon
This depends on the extent to which the different materials can be separated from each other during the sorting process and the impact on recycling quality. The PPWR’s DfR guidelines will have specific requirements for this. Often monomaterials are preferred, or combinations that are very easy to separate.
- What exactly does “recycled content” mean and is it mandatory?
Recycled content means that some of the material from which the packaging is made comes from previously recycled material. Indeed, the PPWR sets mandatory minimum percentages for recycled content in plastic packaging (with exceptions), with deadlines in 2030 and 2040.
- Do I have to keep a separate “packaging passport” for all my packaging?
Yes, the PPWR requires you to have the necessary documentation for each packaging unit or format that demonstrates compliance with the essential requirements and PPWR criteria (DfR, RPGs, recycled content, etc.). This constitutes the “packaging passport” and is the basis for your declaration of conformity. This requires good internal record keeping.
- Are there packaging that will soon be banned altogether
Yes, the PPWR contains a list of specific single-use packaging that will be banned from 2030, especially where reusable alternatives are readily available (think of certain packaging in the hospitality industry, hotels, etc.). It also regulates unnecessary packaging, such as oversized packaging with too much empty space.
