Consistent design for recycling to achieve the best recyclability performance grade

Design-for-Recycling requirements are one key element of the draft Packaging and Packaging Waste Regulation (PPWR) which was submitted by the EU Commission in November 2022. They shall consider state of the art collection, sorting and recycling processes and shall cover all packaging components.

Introduction of recyclability performance grades in PPWR

In this context the draft Regulation contains in table 2 of the annex the following recyclability performance grades based on the assessment of recyclability per unit, in weight:

• Grade A, higher or equal to 95 %
• Grade B, higher or equal to 90 %
• Grade C, higher or equal to 80 %
• Grade D, higher or equal to 70 %
• Grade E, lower than 70 %

The lower the recyclability performance, the higher the financial contributions the producer of the finally marketed product has to pay to comply with their extended producer responsibility (EPR) obligations. From 1 January 2030, packaging shall not be considered recyclable, if it corresponds to performance grade E (lower than 70 %).

The introduction of recyclability performance grades with corresponding financial incentives shall induce the entire packaging value chain to do without complex composite packaging structures and look for as much mono-material packaging solutions as possible.

Recommendations for better recyclability

Since also aerosols consist of different components such as coatings, valve, actuator and cap, the actors in the aerosols supply chain (i. e. coating, printing ink, valve, can and filling goods producers) must efficiently cooperate to find the best possible design for recycling to optimize the recyclability performance grade.

With a view to the aerosol system, the following aspects could be relevant:

• Avoid the use of too many different alloys for can production
• Limit the weight of non-aluminium components in aluminium aerosols to a minimum
• Use aluminium valves on aluminium aerosol cans
• Prefer a removable cap to an integrated dispensing system so that the cap can be manually removed and separately recycled
• Optimize the easiness to completely empty aerosols to limit residual product
• Prefer direct printing to plastic labels
• Limit the use of coatings and inks to a minimum and use “safe” coatings and inks following existing industry guidelines (e. g. European Printing Ink Association EUPIA)

Possibility of conflicting interests in a highly competitive environment

In fast moving consumer goods markets with fierce competition different aspects of a product decide on the final buying decision of the consumer and thus on the economic sustainability of the product. In many cases, e. g. convenience and/or marketing interests might compete with environmental and recycling aspects. Finally, it is up to the brand owner to decide on a packaging specification and design which ensures market success. He might be willing to tolerate a lower recyclability performance grade and thus higher financial contributions to the EPR systems for a better convenience and/or marketing performance, if he thinks that the majority of consumers has the same preferences. In many cases, in a competitive environment it will always be a trade-off between different interests and product properties, for the brand owner and the consumer alike.