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New Work Item Proposal - WG10 Rigid pack. biodegradable eval.

Scope

This document defines requirements for the evaluation process for the part of the rigid packaging unit which comprises the main body and the integrated components predominantly made of biodegradable plastics and for separate components predominantly made of biodegradable plastics with respect to compatibility of the design with the sorting and recycling processes.

Purpose

Purpose

This document establishes requirements for the evaluation process of rigid packaging made of biodegradable plastics. It defines clear criteria for assessing the material recyclability of the main body and integrated components predominantly made of biodegradable plastics, as well as separate biodegradable plastics components, supporting sustainable packaging design and the circular economy. 

 

Justification

1. Regulatory Background and EU Objectives

Packaging in Europe has been regulated by Directive 94/62/EC on Packaging and Packaging Waste, which set key principles for waste reduction and recycling. Despite its success, packaging waste continues to rise. To address this, the EU has revised its packaging legislation, introducing the Packaging and Packaging Waste Regulation (EN2025/40) to ensure full recyclability of all packaging by 2030. 

Article 9 paragraph 3 requires that packaging made of biodegradable plastic polymers and other biodegradable materials which is not designated for composting, shall be designed for material recycling in accordance with Article 6 without affecting the recyclability of other waste streams.

Article 6, paragraph 4 of the EN2025/40 requires the development of design-for-recycling criteria and recyclability performance grades by 2028, taking into account: 

·         The ability of packaging waste to be effectively sorted and recycled into secondary raw materials of sufficient quality. 

·         The impact of substances of concern on recyclability and potential restrictions on such substances. 

·         Established collection and sorting processes and available recycling technologies. 

·         The environmental and economic performance of recycling technologies, including energy use and emissions. 

These recyclability performance assessments will categorize packaging into grades (A, B, C, or “technically not recyclable”) based on compliance with defined criteria. 

2. Standardization to Support PPWR

This document will support the European Commission in developing delegated acts by establishing:

·         Definitions and principles for design-for-recycling (DfR) of packaging made of biodegradable materials.

·         Design-for-recycling criteria specific to packaging made of biodegradable materials.

·         A process for evaluating recyclability performance.

3. Comprehensive Coverage of packaging made of biodegradable materials

This document applies to packaging made predominantly of biodegradable plastics, covering:

·         The main body and integrated components of the packaging unit.

·         Separate components that are also predominantly made of biodegradable plastics.

4. Enhancing Recycling Efficiency

This document sets evaluation criteria to assess:

·         Material composition.

·         Compatibility with recycling infrastructures.

·         End-of-life processing efficiency.

5. Alignment with Existing Standards and Guidelines

Background: currently the prEN 18120 covers Design for Recycling and Recyclability Evaluation specifications for PET bottles, PET rigid packaging, PE & PP rigid packaging, PE & PP flexible packaging, PS, XPS and EPS packaging. In January 2025, it was acted at TC level that a NWIP would be needed to create new guidelines for PET bottles, PET rigid packaging, PE, PP, PS, XPS and EPS. The plan of CEN is to deliver the TS reviews on December 31st of 2025, for a publication in April 2026.

 

Biodegradable Plastics are very different from other plastics in that they have several end-of-life options and should not be treated together with the general group. While compostability was in the focus for many years, biodegradable plastics are also recyclable as was proven in numerous studies. This is especially true for the biodegradable polyesters like PLA, PBAT, PHA and the like, which behave similar to PET. However, separate sorting and recycling at scale must be still built up and technologies are not mature yet. Therefore, the planned TS, in the beginning, will have to be based on experience from other plastics and from currently ongoing European projects scaling up sorting and recycling procedures. It will have to be updated according to the technical progress. This new TS could also provide valuable new information for the TS or standards of other materials.

This document will take into account:

·         Existing material-specific recycling guidelines.

·         Standards and Technical Specifications, such as series prEN 18120, developed under Mandate M/584 as part of the Circular Plastics Alliance project CEN/TS 13688, which addresses substances that hinder recycling.

·         EN 13430, which sets requirements for packaging recoverable by material recycling.

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Please email further comments to: debbie.stead@bsigroup.com

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