Circular packaging: regulations and challenges

All forecasts indicate that the volume of plastic packaging waste will grow rapidly if current consumption and production trends continue. At EuRIC, we are working to ensure that the forthcoming European Directive on packaging and packaging waste is reinforced with a view to increasing recycling rates, improving packaging design to facilitate recycling, and increasing the recycled material content of new packaging products.

María Vera Duran, Project Officer at EuRIC AISBL

Review of legislation: from packaging design to recycling

We assume that waste production increases as the population and consumption grow. However, packaging waste production grows at a much higher rate than population growth or GDP. In 2019, each EU citizen produced an average of 177.4 kg of packaging waste, 34.4 kg of which was plastic packaging, a new all-time high.

Although the volume of recycled plastic packaging waste increases every year, the recycling rate remains low due to the increased production of such waste: only 41% of this packaging is recycled in the EU. In addition, there are significant disparities between Member States: while in Lithuania 70% of plastic packaging is recycled, and the figures for the Netherlands and Spain are 57% and 52% respectively, recycling rates in countries such as France and Malta are as low as 27% and 11%, respectively (Eurostat, 2019).

This suggests that collection systems and separation models must be further optimised throughout the EU and that the capacity of recycling operations needs to be expanded to cope with the increasing volume of plastic packaging generated.

To address these challenges, the European Commission is completing its review of Directive 94/62/EC on packaging and packaging waste, a process that began two years ago and is expected to conclude between July and October 2022.

This is, therefore, a crucial period in terms of adopting ambitious measures, and establishing and defining new recycling targets and mandatory requirements for all packaging placed on the market in Member States under the new Directive.

At EuRIC – the European Recycling Industries’ Confederation, based in Brussels – we are convinced that only through increasing plastic packaging recycling and incorporating recycled plastic into new products will it be possible to close the circular economy loop.

“This product contains of recycled plastic”

Ensuring that all new packaging incorporates a mandatory minimum recycled plastic content is of paramount importance. This is already the case for beverage bottles (PET bottles) under Directive (EU) 2019/904, which stipulates that such bottles must have a minimum recycled plastic content of 30% from 2030. Now is the time, therefore, to set mandatory recycled content targets for all packaging products.

Currently, only 12% of recycled plastic is incorporated into the manufacturing process of new packaging. The establishment of mandatory recycled content targets in the new directive will not only ensure the demand for recycled material, but will also boost the competitiveness of recycling companies, stimulating capital investment to increase the capacity of their facilities.

EuRIC supports the inclusion in the directive of a 40% mandatory recycled content target for all plastic packaging by 2030. In addition, the harmonization of a methodology to quantify and verify the content of recycled material in each packaging item is essential to avoid so-called “green-washing”: brands that advertise recycled content when in fact the entire packaging is based on virgin materials.

To prevent undesirable substitution in the selection of materials and protect recyclability, this legal obligation to include recycled content in packaging should be extended to other types of materials (aluminium, steel, glass, paper and cardboard, etc.). Moreover, it remains imperative that Member States report the recycled content of all packaging placed on the market within their respective territories.

Designed to be recyclable

Another key to increasing the volume of recycled plastics is to ensure that all packaging on the EU market is recyclable in an economically viable way by 2030. This requirement, together with a harmonized definition of “recyclability”, is expected to be included in the directive.

To this end, it is necessary to assess the actual recyclability of packaging, and to identify and phase out packaging that is not recyclable. Such assessment should be carried out in practice before the product is placed on the market and on the basis of existing sorting and recycling techniques implemented on an industrial scale (in a laboratory, practically everything is recyclable). This should take account of geographical factors, since a package may be recyclable in one European country, while another neighbouring country may lack the necessary facilities.

It should be noted that, if the material entering the recycling plant is not recyclable, it is virtually impossible to obtain quality recycled material as output. Ultimately, design to facilitate recycling and rigorous evaluation of packaging recyclability are key tools to improve the efficiency and quality of recycled material.

EuRIC is calling on the European Commission to establish a definition of “Circular Packaging”. This should incorporate not only a definition of packaging recyclability but should also include the recycled material content target for the new product.

CIMPA project: promoting the recycling of multilayer flexible packaging

Crisp bags, snack and candy wrappers, coffee packaging, frozen and vacuum food packaging… multilayer plastics are part of our day-to-day and one of the most common types of packaging in the food industry. Thanks to the combination of several types of materials (PET, PE, PA, aluminium, etc.) with different properties, the shelf life of food is extended, and its quality and freshness guaranteed. For this reason, around 2 million tonnes of multilayer films are used for food packaging each year.

However, this multilayer structure in which several materials merge with one another makes recycling very complex. Therefore, this type of packaging currently ends up being incinerated or, worse still, in landfills.

The CIMPA project seeks to address this problem and proposes innovative solutions to develop the first value chain for the recycling of multilayer plastics from the food industry and agriculture. The goal is to retain between 12% and 72% of the original value. These solutions include the eco-design of plastics, the development of new technologies for the sorting and separation of different films (combining Near InfraRed NIR- and digital watermarking sorting technologies), mechanical and physical (dissolution) recycling processes, and decontamination processes and upgrading solutions. These latter solutions are key as plastic packaging may contain residues and contaminants from previous use. Therefore, a decontamination process is required to produce a quality recycled material suitable for food contact. This will enable the reintroduction of recycled polymers into manufacturing processes and meet the demands for recycled content in new products.

This project, funded by the European H2020 program, brings together 13 partners from 5 countries, covering the entire value chain: waste management company (PAPREC), sorting technology providers (Filigrade and Pellenc ST), research institutes (IPC, AIMPLAS, VTT and TNO) and multilayer film producers (Eversia, Leygatech, Barbier), an institute for consumer attitude studies (Prospex), consultants (Benkei) and the European confederation representing the recycling industry (EuRIC).

EuRIC is contributing to the project as a partner representing the recycling industry and is coordinating the activities related to communication, dissemination, and exploitation of results, in addition to carrying out pre-legislative studies. The latter focus on the review of European and national legislation, as well as on identifying needs for modification in regulations and standards related to the circular design, manufacture, and recycling of multilayer films.

All information on the project and results can be consulted at

Published in: Nº 90 FuturENVIRO – May-June 2022