Design for Recycling Flexible Packaging EU: Compliance Guide

This guide provides a practical and regulatory-focused overview of Design for Recycling (DfR) for flexible packaging in the European Union. It explains how design choices influence real-world recyclability, compliance with the Packaging and Packaging Waste Regulation (PPWR), Extended Producer Responsibility (EPR) costs and the use of recycled content, including food-contact applications. The guide is intended for packaging designers, converters, brand owners and quality or regulatory professionals who need to translate sustainability objectives into technically and legally robust packaging solutions.

 

What Is Design for Recycling (DfR)?

Design for Recycling (DfR) is the practice of designing packaging so that it can be effectively collected, sorted and recycled into secondary raw materials using existing or realistically deployable recycling infrastructure. In the context of flexible packaging, DfR focuses on the full material system: polymer selection, layer structure, thickness, inks, coatings, adhesives and labels.

A flexible package is not recyclable simply because its main polymer is recyclable in theory. It must be compatible with actual European sorting and recycling processes, produce a recyclate of sufficient quality and not introduce substances or structures that disrupt recycling operations.

 

Why It Matters: Regulation, Costs, Brand Reputation and EPR

Design for Recycling has become a central compliance issue rather than a voluntary sustainability initiative. The PPWR establishes binding rules on recyclability, recycled content and chemical restrictions, while EPR schemes increasingly modulate fees based on how recyclable packaging is in practice. For flexible packaging, which has traditionally relied on complex multilayer structures for performance, this represents a structural shift.

Poor DfR decisions can lead to higher EPR fees, redesign costs, market restrictions and challenges in substantiating environmental claims. At the same time, packaging that is well designed for recycling can reduce compliance risk and support recycled content targets while strengthening brand credibility. Design for Recycling, therefore, sits at the intersection of regulation, cost control and reputation management.

 

Key Principles of Design for Recycling in Flexible Packaging

Recycled Content

A central principle of Design for Recycling is the integration of recycled content into flexible packaging, in line with regulatory requirements and material performance constraints. Under the PPWR, minimum recycled content targets apply to plastic packaging, making the use of recycled polymers a structural design parameter rather than a voluntary sustainability choice.

Incorporating recycled content for flexible packaging, in particular, requires careful evaluation of material quality, consistency and suitability for the intended application, particularly where mechanical properties, barrier performance or food-contact compliance are critical. Designers and manufacturers must also ensure traceability of recycled materials and, where applicable, source recycled content from authorized recyclers, especially for food-contact applications.

 

Use of Mono-Material Structures

For flexible packaging, mono-material plastic structures (e.g. PE-based or PP-based laminates) currently offer the highest recyclability potential in Europe.

Why mono-materials matter:

• They can be sorted using existing NIR systems
• They melt and get reprocessed more consistently
• They generate higher-quality recyclate

Multi-material laminates (e.g. PET/PE, PA/PE, paper/plastic/aluminum) often provide excellent barrier performance for the food products but are difficult or impossible to recycle mechanically at scale.

 

 

Material Minimization and Efficiency

Material minimization (lightweighting) is equally important, as reducing overall material use lowers environmental impact, decreases EPR fees and can also improve recycling efficiency by reducing residue and contamination per pack. However, while reducing material use remains a core sustainability target, but it must be balanced with recyclability.

Key points:

• Thinner films reduce material consumption and EPR fees
• Excessive downgauging can cause performance failures (leaks, food waste)
• Lightweighting should not introduce incompatible materials or coatings

DfR focuses on efficient use of recyclable materials, not just minimal weight. Importantly, minimization must be achieved without compromising functionality or safety, especially for food packaging.

 

Avoiding Problematic Coatings and Mixed Materials

Certain materials significantly reduce recyclability, especially in flexible formats:

• Aluminum layers
• PVDC coatings
• Siliconized or heavily cross-linked coatings

Barrier needs should be addressed with recyclable-compatible alternatives (e.g. EVOH at controlled thickness, or coated mono-material solutions validated by recyclers such as AlOx or SiOx).

 

 

Labels, Inks and Adhesives: Hidden Recyclability Risks

Small components can have a large impact. Common issues include:

• Inks with carbon black pigments that disrupt NIR sorting
• Adhesives that do not dissolve or separate during washing
• Labels made of incompatible polymers

Best practice:

• Use wash-off or recycling-compatible adhesives
• Minimize ink coverage and avoid problematic pigments
• Align label materials with the base film polymer

 

Design Guidelines

At the moment, there are no fully harmonized, EU-wide design guidelines specifically defining how packaging must be designed to be considered recyclable in practice. In the absence of official European guidance, companies can rely on technical design guidelines and assessment methodologies developed by recognized industry and waste management organizations. These include initiatives such as RecyClass, cyclos-HTP, Interzero and Citeo, as well as national schemes like OPRL in the UK. While these frameworks are not legislation, they provide practical, widely used criteria that help industry align packaging design with current recycling infrastructure and regulatory expectations.

 

Recycling Processes for Flexible Packaging and Common Challenges

Sorting

To understand Design for Recycling, it is essential to understand how flexible packaging is recycled in practice. After collection, flexible plastics are sorted using a combination of near-infrared (NIR) detection, density separation and manual quality control. Complex structures, mixed materials and certain pigments reduce sorting accuracy and increase rejection rates.

 

Cleaning

Once sorted, materials undergo cleaning processes that include shredding, washing and friction cleaning to remove food residues, or any inks and adhesives. Designs that generate excessive contamination increase water use, require more energy and cost more in processing. Poor washability is one of the main reasons flexible packaging is rejected by recyclers.

 

Reprocessing

During reprocessing, cleaned flakes are melted and re-granulated. At this stage, incompatibilities between polymers, residual barrier materials or adhesive residues can cause defects such as gels, discoloration or odor. These defects limit the applications of the recycled material and reduce its economic value. Many of the recyclability challenges associated with flexible packaging originate from design decisions made long before the packaging reaches a recycling facility.

 

Material Trade-Offs: Plastics, Paper and Metal in Flexible Packaging

Material choice in flexible packaging always involves trade-offs between performance, sustainability and recyclability.

• Plastic-based flexible packaging offers excellent barrier properties, low weight and efficient use of resources, but its recyclability depends heavily on design.
• Paper-based flexible packaging can provide a renewable image, yet often relies on plastic coatings or laminations that complicate recycling.
• Aluminum-based structures offer superior barrier performance but require separate collection streams and energy-intensive recycling processes.

Design for Recycling does not imply that one material is universally superior. Instead, it requires system-level evaluation, considering the entire life cycle, available recycling infrastructure and regulatory requirements. Substituting one material for another without addressing recyclability in practice, can shift impacts rather than reduce them.

 

 

Regulation & Standards Related to Recyclability, Recycled Content, Labeling and Environmental Claims (PPWR)

The Packaging and Packaging Waste Regulation (PPWR) sets binding EU rules for packaging design, recyclability, recycled content, chemical safety and labeling. It applies directly to flexible packaging and is enforced through market surveillance and EPR systems.

 

Article 5 – Substances of Concern

Packaging must not contain substances that negatively affect human health or the environment, including during recycling. This directly impacts inks, adhesives, coatings and additives, and requires documented compliance aligned with EU chemicals legislation.

 

Article 6 – Recyclable Packaging

All packaging must be recyclable: designed for material recycling, separately collected and sortable, recyclable at scale, and able to produce quality recyclate. Recyclability performance classes (A, B, C) determine market access and influence EPR fees.

 

Article 7 – Minimum Recycled Content

Mandatory post-consumer recycled (PCR) content targets apply to plastic packaging from 2030 and increase by 2040, with different thresholds for beverage bottles, contact-sensitive and other plastic packaging. Compliance is calculated per manufacturing plant and must be verified.

 

Labeling, Environmental Claims and Certification

The PPWR strengthens requirements for consumer information and claim substantiation, including:

• Harmonized labeling on material composition, recyclability and disposal
• Use of standardized symbols and/or digital carriers (e.g. QR codes)
• Mandatory availability of technical documentation and a Declaration of Compliance
• Prohibition of misleading recyclability or recycled content claims

While the PPWR does not mandate a specific certification scheme, third-party certifications play a key role in practice. ISCC PLUS and ISCC EU are commonly used to verify recycled content and traceability, and particularly relevant for food-contact flexible packaging, where recycled plastics must originate from authorized recyclers and comply with EU food-contact legislation

For broader guidance on environmental labeling and procurement in EU, read our related article on EU Ecolabel.

 

Conclusion

Design for Recycling is no longer a theoretical sustainability concept for flexible packaging. Under the PPWR, it becomes a measurable, enforceable requirement that directly affects market access, EPR fees and the credibility of environmental claims. Packaging structures that cannot be effectively sorted and recycled under real European waste management conditions will increasingly face regulatory pressure, higher costs and probable reputational risks. For flexible packaging in particular, where multilayer structures have historically dominated, DfR forces a shift toward simpler, more transparent and recycling-compatible designs.

At the same time, Design for Recycling should not be treated in isolation. Recyclability, chemical safety, recycled content and documentation obligations are now interconnected. Early technical decisions on materials, inks and adhesives determine not only recycling performance, but also compliance with chemical restrictions, food-contact rules and Declaration of Compliance requirements. Companies that integrate DfR into their design and development processes early will be better positioned to control their costs, demonstrate compliance of their packaging and respond efficiently to the evolving EU legislation.

 

PDF – Actionable Tips Checklist for Manufacturers in EU

 

References

1. European Commission (2004) Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food. Available at: https://eur-lex.europa.eu/eli/reg/2004/1935/oj (Accessed: 2 February 2026).
2. European Commission (2025) Regulation (EC) No 2025/40 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Available at: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng  (Accessed: 2 February 2026).
3. European Commission (2020) A new Circular Economy Action Plan – For a cleaner and more competitive Europe. (2020) 98 final. Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0098 (Accessed: 2 February 2026).
4. European Commission (n.d.) Packaging and packaging waste – EU policy overview. Available at: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en (Accessed: 2 February 2026).
5. European Commission (n.d.) Extended Producer Responsibility (EPR) for packaging. Available at: https://environment.ec.europa.eu/topics/waste-and-recycling/extended-producer-responsibility_en (Accessed: 2 February 2026).
6. European Commission (n.d.) Food Contact Materials – Plastic recycling and food safety. Available at: https://food.ec.europa.eu/safety/chemical-safety/food-contact-materials/plastic-recycling_en (Accessed: 3 February 2026).
7. European Commission (n.d.) EU Ecolabel – Sustainable products and services. Available at: https://environment.ec.europa.eu/topics/circular-economy/eu-ecolabel_en (Accessed: 2 February 2026).
8. European Commission (2023) Environmental claims and substantiating green claims. Available at: https://environment.ec.europa.eu/topics/circular-economy/green-claims_en (Accessed: 2 February 2026).
9. European Commission (n.d.) Market surveillance and compliance of products. Available at: https://single-market-economy.ec.europa.eu/single-market/market-surveillance_en (Accessed: 3 February 2026).
10. European Commission (n.d.) Harmonized rules on packaging labeling and consumer information. Available at: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en (Accessed: 3 February 2026).
11. ISCC (n.d.) ISCC PLUS and ISCC EU Certification Schemes – Traceability and recycled content verification. Available at: https://www.iscc-system.org (Accessed: 2 February 2026).
12. European Commission (n.d.) Authorized recycling processes for recycled plastics intended for food contact. Available at: https://food.ec.europa.eu/safety/chemical-safety/food-contact-materials/recycled-plastics_en (Accessed: 3 February 2026).