Recyclability
PPWR
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Last Updated
Biki John
Senior Content Marketing Manager
Key Takeaways
Understand how flexible packaging recyclability was previously assessed and why the EN 18120-7 standard is relevant to prepare for PPWR compliance.
Learn about EN 18120’s technical criteria, structural thresholds, and classification tiers used to measure packaging compatibility.
Evaluate how digitising packaging data and assessment processes helps automate EN 18120 compliance and identify high-risk packaging across your entire portfolio.
Introduction
Flexible Polypropylene (PP) and Polyethylene (PE) packaging has long been assessed for recyclability, but the introduction of EN 18120-7 brings a more structured and harmonised approach to evaluating flexible packaging structures.
Understanding what has changed, how different materials are categorised, and what this means for packaging portfolios is becoming increasingly important for teams working across packaging development, sustainability, and regulatory compliance across Food, FMCG, Flexible Packaging, and Industrial sectors.
In this article, we explore the key principles behind EN 18120-7, what the different recyclability classifications mean, and how the standard could affect flexible packaging decisions. We also look at practical next steps for assessing and managing flexible PP and PE packaging compliance at scale.
What was the EU's approach to recyclability assessment pre EN 18120?
Before EN 18120-7, flexible PE and PP packaging recyclability was not assessed using one common European methodology. Instead, companies relied on a range of different industry guidelines and national approaches. For example, Circular Economy for Flexible Packaging (CEFLEX) provided Designing for a Circular Economy (D4ACE) guidance for polyolefin flexible packaging, RecyClass provided Design for Recycling guidelines, while Germany had its own Verpackungsgesetz (VerpackG) Minimum Standard for determining packaging recyclability.
From fragmentation to harmonisation - why was EN 18120 introduced?
Recognising that the upcoming Packaging and Packaging Waste Regulation (PPWR) would require harmonised criteria to function, the European Commission explicitly tasked and commissioned the European Committee for Standardization (CEN) to draft these technical specifications. These CEN guidelines, composed of a series of material standards, were created to support the PPWR by outlining the 2030 recyclability criteria for plastic packaging.
A coalition of over 150 European companies, technical experts, and scientific advisors answered the Commission's mandate, establishing a comprehensive, standardised Design for Recycling framework.
The result of this on April 15, 2026: the European Committee for Standardization (CEN) officially published EN 18120-1:2026, - a 14-part suite of Design for Recycling standards, marking a major milestone for Design for Recycling in Europe. These standards mark a crucial step forward in establishing a clear, unified framework for design-for-recycling in plastic packaging.
The European Commission’s Joint Research Centre (JRC) formally evaluated the plastics framework and validated it. Because CEN developed these standards at the direct request of the Commission, they represent the official reference point for secondary legislation. As rules evolve, technical requirements will only become more detailed and will not reverse direction.
Understanding why and how the flagship plastic standard EN 18120 was created reveals why it serves as a dependable foundation for business planning today. Dr. Dennis Bankmann, Managing Partner at Emerging Motif, was one of the hundreds of experts who participated in assembling the EN 18120 standards, further confirming this. On behalf of CEFLEX, he was tasked with developing the standards for PE and PP flexible packaging.
When asked what role the published EN 18120 series of standards for plastic packaging could play in providing guidance on the detailed requirements under PPWR, Bankmann explained that the series already gave a “good indication of what data will be needed, and to which granularity.”
On the topic of timing of when companies should strategically prepare to meet the requirements of packaging recyclability, Bankmann shared that by “collecting the required data now and checking it for completeness, future compliance bottlenecks can be avoided”.
In addition, while the final design-for-recycling criteria and the method of awarding the packaging performance grades A-C were not yet available, it was “possible to gain a fundamental understanding of the likely future classification of packaging design” and the advantage of this was that it allowed businesses to “work on necessary design substitutions already now, rather than only shortly before 2030."
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By collecting the required data now and checking it for completeness, future compliance bottlenecks can be avoided...which allowed businesses to work on necessary design substitutions already now, rather than only shortly before 2030.
Today, the focus is on EN 18120-7, the chapter that deals with reviewing the design rules and evaluation protocols for the PE and PP flexible packaging stream.
What does EN 18120-7 mean for flexible PE and PP packaging?
EN 18120-7 provides a common framework for assessing the Design for Recyclability of flexible packaging predominantly made from PE or PP. Importantly, the assessment does not stop at the main polymer. Other materials and integrated components are also considered because they can affect the packaging’s collection, sorting and recycling performance.
The standard categorises packaging designs using a three-level system:
Green: Full compatibility - packaging constituents and components are fully compatible with state-of-the-art collection, sorting and recycling.
Yellow: Limited compatibility - packaging constituents and components have limited compatibility with these processes.
Red: Not compatible - packaging constituents and components are not compatible with state-of-the-art collection, sorting and recycling.
To determine a packaging structure's classification, EN 18120-7 provides detailed guidance tables covering different PE and PP flexible packaging types, including differences between household and industrial/commercial packaging, as well as natural-colour, white and coloured packaging.
The assessment considers the main packaging material and its integrated components, with criteria covering areas such as:
Material composition: The standard specifies which PE and PP materials and copolymers are compatible and considers the presence and proportion of other polymers within the packaging structure.
Colours and pigments: Colour can affect sortability, with the guidance distinguishing between different colour categories, including natural, white, light and other coloured packaging.
Additives and fillers: These are assessed based on their potential impact on the packaging’s recyclability, including their effect on the density and properties of the packaging material.
Barriers and barrier coatings: The type and characteristics of barrier materials and coatings are considered based on their compatibility with the recycling process.
Laminating adhesives: The type and amount of adhesive used within the packaging structure are assessed according to their compatibility with recycling.
Inks, lacquers and coatings: The assessment considers factors including the type of ink or coating, its composition and its coverage of the packaging surface. For example, the guidance distinguishes between inks below 30% surface coverage and those covering 30–50% in relevant packaging structures.
Labels and other components: Labels, labelling adhesives, sleeves, closures, valves, seals and tamper-evident components are also included in the assessment.
The key takeaway
While evaluating recyclability was once as straightforward as checking for a PE or PP resin, EN 18120-7 assesses the packaging structure as a whole, including the materials, barriers, adhesives, inks, coatings, labels, closures, additives and other components that can influence its recyclability.
For example: Identical PE films will yield different ratings depending on integrated components: keeping polyurethane adhesive under 1.5wt% and ink coverage below 30% maintains Green status, whereas exceeding adhesive thresholds or applying non-water-releasable paper labels downgrades the package to Yellow or Red.
When do the EN 18120-7-related requirements apply?
EN 18120-7 requirements apply through a phased, evolving timeline starting with national standardization in October 2026 and culminating in mandatory EU market enforcement on 1 January 2030. By October 2026, national standards bodies across all CEN member states must officially endorse EN 18120-7:2026 and withdraw conflicting national guidelines, establishing the standard as the immediate state-of-the-art technical baseline for packaging evaluations and compliance evidence.
However, the standard will not be applied 1:1 in its raw form as law. The European Commission will use the EN 18120 standard series as the technical foundation to draft legal Delegated Acts under Article 6 of the EU Packaging and Packaging Waste Regulation (PPWR). These Delegated Acts will translate the standard’s qualitative design categories (Green, Yellow, Red) into legal Recyclability Performance Grades (A, B, C) and may adjust specific technical thresholds. Furthermore, Clause 6 of EN 18120-7 explicitly mandates ongoing industry revisions to update criteria for complex adhesives, high-coverage ink binders, carbon black detection, and chemical recycling processes as data develops.
The final binding market restriction takes effect on 1 January 2030, from which point all flexible PE and PP packaging placed on the EU market must comply with the iterated, legally adopted Design for Recycling criteria. Packaging that fails to achieve at least Grade C under these finalized rules will be prohibited from the EU market.
What happens if packaging does not meet EN 18120 standards?
Packaging that does not meet the required criteria will be considered technically non-recyclable and from 2030, cannot legally be placed on the EU market. From 2038, the requirements become stricter, with only Grades A and B remaining compliant.
From requirements to action: How should companies prepare for EN 18120-7?
Preparing for EN 18120-7 starts with understanding where your packaging portfolio stands today. By gathering the right packaging data, assessing each structure against the relevant criteria, and identifying potential risks, companies can begin making informed decisions before requirements take effect.
In practice, this means getting a clear, structured view of the packaging data needed for recyclability assessments. This includes information such as material composition, components, weights, labels, adhesives, barriers and other relevant packaging attributes.
Once this data is available, packaging can be assessed against the EN 18120-7 criteria and categorised as: Green for Fully compatible, Yellow for Limited compatibility and Red for Not compatible.
This helps teams identify which packaging designs are performing well and which may require further investigation, testing or redesign. It also highlights the specific design elements affecting recyclability, supporting more informed R&D and packaging decisions.
For larger portfolios, this assessment provides a way to identify where recyclability and future compliance risks are concentrated, helping teams prioritise packaging for optimisation rather than approaching the transition as a portfolio-wide redesign exercise.
Why digitise EN 18120-7 assessments?
While the assessment process can be straightforward for an individual packaging unit, applying it across an entire portfolio is significantly more complex. Teams need to collect and maintain detailed packaging data, determine whether all the required information is available, interpret the relevant EN 18120-7 criteria, and assess potentially thousands of packaging structures.
Managing this manually can be time-consuming and resource-intensive, particularly when packaging information is spread across different teams and suppliers. It can also make it difficult to maintain a consistent view of recyclability performance and quickly identify the packaging units that require attention.
Digitising the process can help companies centralise packaging data, automate assessments and turn individual results into a clear portfolio-level view. Instead of manually working through the standard for each packaging structure, teams can more efficiently identify missing data, assess packaging against the relevant criteria, flag where further testing may be required and pinpoint the design factors driving lower recyclability performance.
Recyda helps companies apply this approach across their packaging portfolios. The platform assesses packaging against the EN 18120 standards, identifies missing information needed for accurate assessments and indicates where further testing may be required.
By connecting detailed packaging data with recyclability assessments, teams can make informed R&D and packaging decisions without manually working through the standard for every packaging unit.
It also provides a portfolio-level view of recyclability performance, helping teams identify high-risk packaging, understand the factors affecting each assessment and prioritise improvement opportunities.
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