PPWR Insights 1 - What do the new recyclability requirements mean for your business?

Exemptions and financial incentives

Certain packaging types, including packaging for medicines and baby food, are temporarily exempt from the new recyclability requirements. Innovative packaging solutions that do not yet fully meet the requirements may also remain on the market for a limited period, provided there is a clear roadmap to compliance.

As of 2030, contributions under Extended Producer Responsibility will be adjusted according to each packaging item’s recyclability score. This means that producers will pay higher fees for hard-to-recycle packaging and lower fees for packaging with a good recyclability score.

Packaging recyclability will therefore not only be a condition for remaining on the market. It will also have a direct impact on costs for companies.
 

What does "recycled at scale" mean?

The PPWR makes a distinction between design for recycling and recycling at scale.

The design-for-recycling criteria assess whether packaging is technically recyclable. This assessment looks at the material, the composition, the components used and their impact on collection, sorting and recycling.

Recycling at scale goes one step further. From 2035 onwards, packaging must also be sufficiently recycled in practice across the European Union. The European Commission will define a methodology for this, based on effective recycling rates for each packaging material.

It remains unclear at this stage how strictly this condition will be applied. A strict interpretation could mean that a material group that is not recycled at scale by 2035 may no longer be placed on the market. Another possible interpretation is that such a material group would receive a lower recyclability grade. Fost Plus is closely following this development. 

What role do CEN standards play?

CEN, the European Committee for Standardisation, translates the PPWR requirements into technical standards, test methods and design guidelines. These standards clarify how packaging is assessed and which design choices are encouraged, tolerated or excluded.

For plastic packaging, the first important step has already been taken. In April 2026, CEN published the 14 new standards for the recyclability of plastic packaging, EN18120. These standards define how plastic packaging is assessed in terms of its design for recycling.

For the different plastic types, the system uses so-called traffic light tables. These classify packaging into three categories:

• Green: encouraged;
• Yellow: tolerated but not ideal;
• Red: banned from the market.

The assessment considers, among other factors, how packaging components behave in sorting facilities. For example, a polystyrene yoghurt pot is assessed together with its sealing film and wrapper, as these components typically end up together in sorting centres. Components are assessed separately only when they are removed by consumers before sorting in the large majority of cases.

The standards for plastic packaging are now entering a revision period. Updated standards are expected during 2028. They will help determine whether plastic packaging may still be placed on the European market from 2030 onwards, which recyclability grade it falls into and which rate will apply.

For other materials, such as paper-board, glass, aluminium and steel, the standards are expected later. Fost Plus is closely following these developments, including through the relevant CEN working groups.

Soon: access to CEN standards via MyFost

Good news for members: Fost Plus has leased, through the Belgian Bureau for Standardisation, a package of CEN standards for a period of three years. The documents will be made available via MyFost, using the login of the person responsible for the declaration.

This is important because CEN standards contain the technical details companies need to correctly interpret and apply the PPWR. For plastic packaging, this currently includes the EN18120 standards on design for recycling and recyclability. In the future, other PPWR-related standards and methodologies will be added.

Normally, companies have to purchase CEN standards individually. This can be expensive, especially as several standards and methodologies are being developed under the PPWR. Through this leased package, Fost Plus members will have access to the relevant standards via MyFost for at least three years.

The first standards that will be available via MyFost relate to the recyclability of plastic packaging. As soon as new PPWR-related standards are published and fall within the scope of the leased package, they will also be made available gradually via MyFost.

Europe may ask CEN to develop harmonised standards or methodologies for, among other things, the calculation of packaging minimisation, the requirements for compostability, the calculation of the percentage of recycled content in packaging and the calculation of the percentage of empty space in packaging.

Access via MyFost is expected in the course of September 2026, for a period of at least three years. All revisions of the standards during that period will also be included.

Important: CEN standards are protected by copyright. They may not be shared or forwarded outside your own organisation. The documents are linked to an individual MyFost login and contain personal data as a watermark. They are usually available in several languages.

Under the leasing agreement between Fost Plus and the Belgian Bureau for Standardisation, the standards may be downloaded, printed and shared with colleagues within your own organisation. The specific conditions of use will be communicated via the MyFost declaration platform.

What can you do right now?

The 2030 deadline may seem far away, but it is approaching quickly when taking into account the development cycles of packaging and packaged products. Waiting until all final criteria and standards are fully completed is therefore not a good idea.

For plastic packaging, there is already sufficient direction today to act with confidence. The first CEN standards have been published and several existing reference frameworks point in the same direction.

To help companies, Fost Plus and Valipac, in collaboration with Verpact, Citeo, Green Dot Norway and NPA Sweden, have developed the No Regrets Playbook for plastic packaging. This Playbook translates the available insights and standards into concrete design choices that companies can already apply today.

The No Regrets Playbook contains examples of well-designed plastic packaging, as well as packaging or components that are best avoided. It helps companies make choices now that are aligned with the direction of the PPWR, without waiting for all final implementing rules.

As a company, you can already take stock of your entire packaging portfolio. For each packaging item, map the exact composition, material choices and components. Then compare this information with the Design4Recycling Guidelines, the No Regrets Playbook and, once available via MyFost, the relevant CEN standards.

This will give you a clearer view of packaging that may be at risk towards 2030 and packaging that may need to be adapted.