PPWR Glossary: 73 Essential Terms for 2030 Compliance

PPWR (Packaging and Packaging Waste Regulation)

Regulation (EU) 2025/40 on packaging and packaging waste, which entered into force on 11 February 2025, replaces Directive 94/62/EC and applies directly in all EU member states without national transposition. Introduces requirements on recyclability (Art. 6), PFAS restrictions (Art. 5), minimum recycled content (Art. 7), harmonised labelling (Art. 12 and 13), packaging minimisation (Art. 10) and eco-modulation of EPR contributions (Art. 45(6) in conjunction with Art. 6).

Key deadlines:

• 12 August 2026: general applicability, PFAS restrictions (Art. 5), mandatory Declaration of Conformity
• estimated 2027 and 2028: delegated acts with technical criteria
• estimated July 2029: EPR eco-modulation
• 1 January 2030: mandatory recyclability, recycled-content (PCR) threshold
• 2035: intermediate waste-reduction target
• 1 January 2038: Grade C ban

Annex II PPWR (recyclability assessment)

The technical annex to Regulation (EU) 2025/40 that sets out the methodology and criteria for assessing packaging recyclability (packaging categories and calculation parameters). The official system of recyclability performance grades (3 formal grades A, B, C, plus the Non-Recyclable category for structures below the Grade C threshold) and the related market bans are established by Article 6 PPWR, based on the percentage of packaging weight that can actually be recycled.

Grades A and B remain permitted on the EU market after 1 January 2038, Grade C is accepted between 2030 and 2038, and the Non-Recyclable category is banned from 1 January 2030. Until the delegated acts are published, the industry reference methodology is RecyClass v3.1, aligned with this A, B, C and Non-Recyclable system.

The exact technical assessment criteria will be set through delegated acts of the European Commission, expected in 2027 and 2028.

Annex VII PPWR (technical documentation)

The technical annex to Regulation (EU) 2025/40 that sets out the structure of the mandatory technical documentation for packaging placed on the EU market: packaging description, material specifications, test reports, supplier declarations, recyclability assessment. Documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging, under Art. 15(3). This is the basis for the PPWR Declaration of Conformity.

Art. 5 PPWR (PFAS restrictions)

The article of Regulation (EU) 2025/40 that bans the use of per- and polyfluoroalkyl substances (PFAS) in food-contact packaging from 12 August 2026. The ban applies via three cumulative thresholds: 25 ppb per individual substance, 250 ppb total sum of PFAS, 50 ppm total organic fluorine.

Art. 7 PPWR (minimum recycled content)

The article that requires minimum proportions of post-consumer recycled content (PCR) in plastic packaging placed on the EU market. Thresholds are differentiated by packaging category.

Thresholds applicable from 1 January 2030:

• Contact-sensitive PET packaging: 30% (rising to 50% from 2040)
• Contact-sensitive packaging made of plastics other than PET (including flexible PE and PP films): 10% (rising to 25% from 2040)
• Other plastic packaging: 35% (rising to 65% from 2040)

Art. 10 PPWR (packaging minimisation)

The article requiring that packaging be designed and produced so that its weight and volume are reduced to the minimum necessary for product protection, compliance with applicable regulations and consumer acceptance.

From 1 January 2030, grouped, transport and e-commerce packaging cannot exceed an empty-space ratio of 50% (Art. 24 PPWR). Explicitly banned: double walls, false bottoms, unnecessary layers.

EPR eco-modulation (Art. 45(6) in conjunction with Art. 6)

The mechanism by which EPR contributions are modulated according to the packaging's recyclability performance, across all national EPR schemes in the EU, under Art. 45(6) PPWR in conjunction with Art. 6 (which establishes the recyclability performance grades), expected from July 2029.

Contributions vary with the recyclability grade: higher-grade packaging (A, B) pays less, lower-grade packaging (C) pays more. The difference in contribution between Grade A and the Non-Recyclable category can be 3 to 8 times for the same volume, depending on the national EPR scheme.

EPR (Extended Producer Responsibility)

A legal principle whereby the economic operator placing the packaging or packaged product on the market bears the costs of collection, sorting and recycling. Responsibility usually falls on the brands and importers placing packaged products on the market.

In Romania, EPR registration is handled through a Producer Responsibility Organisation or through authorised collective organisations under Law 249/2015 and Government Emergency Ordinance 196/2005. The main collective organisation in Romania is Eco-Rom Ambalaje SA.

PPWR Declaration of Conformity (DoC)

A mandatory technical document by which the manufacturer or importer of packaging attests that the product complies with the requirements of Regulation (EU) 2025/40: recyclability, PFAS restrictions, recycled content, labelling and minimisation.

Important: the PPWR DoC is different from the Declaration of Conformity for food contact under Regulation (EU) 10/2011, and from the one for recycled plastics under Regulation (EU) 2022/1616. For food packaging, all applicable declarations are required.

Kept for 5 years for single-use packaging and 10 years for reusable packaging, under Art. 15(3) PPWR.

REACH (Regulation (EC) 1907/2006)

The EU regulation on the registration, evaluation, authorisation and restriction of chemicals, managed by the European Chemicals Agency (ECHA). Manufacturers and importers of substances must register and document chemical safety.

For flexible packaging, REACH applies to raw materials (polymers, adhesives, inks, additives) and interacts with PPWR's specific restrictions (PFAS, heavy metals, substances of concern).

FCM (Food Contact Materials)

Materials in contact with food, a category regulated separately from PPWR. The European FCM framework comprises:

• Regulation (EC) 1935/2004 (general principles)
• Regulation (EU) 10/2011 (plastic materials)
• Regulation (EU) 2022/1616 (recycled plastics)
• Regulation (EU) 2023/2006 (good manufacturing practice)

CSRD (Corporate Sustainability Reporting Directive)

The EU directive requiring large companies to report sustainability indicators, including packaging recyclability and recycled content, as externally verifiable data. Through the Omnibus package and the "Stop-the-clock" directive (2025), the timeline was postponed and the scope narrowed to companies with more than 1,000 employees and over €450 million in turnover.

Updated reporting calendar:

• Large public-interest companies (already under NFRD): FY2024, reported in 2025
• Other large companies: postponed to FY2027, reported in 2028
• Listed SMEs: removed from mandatory scope via Omnibus; may report voluntarily (VSME standard)

PPWR recyclability grades (A, B, C, Non-Recyclable)

The official system of recyclability performance grades established by Article 6 of Regulation (EU) 2025/40, with the percentage thresholds for each grade set out in Annex II. The official text uses 3 formal grades (A, B, C) plus the "Non-Recyclable" category for structures below the Grade C threshold.

Grade A (minimum 95% recyclable): minimum EPR fees, permanent compliant status on the EU market. Correctly designed mono-material PE or PP structures target Grade A.
Grade B (80-94% recyclable): reduced EPR fees, permanent compliant status on the EU market alongside Grade A after 1 January 2038. Typically includes PE/EVOH/PE and PP/EVOH/PP structures with EVOH under 5%.
Grade C (70-79% recyclable): accepted between 2030 and 2038, higher EPR fees, banned from the EU market from 1 January 2038. Grade C structures require mandatory redesign by 2038.
Non-Recyclable (below 70% recyclable): banned from the EU market from 1 January 2030. Typically includes PET/Al/PE structures, PVDC and non-compatibilised multilayer laminates.

The exact technical criteria for grade classification will be defined through delegated acts of the European Commission, expected in 2027 and 2028. Until the delegated acts are published, the reference methodology accepted by industry, retailers and authorities is RecyClass v3.1.

RecyClass v3.1

A non-profit initiative coordinated by Plastics Recyclers Europe (PRE), providing assessment and certification protocols for the recyclability of plastic packaging in Europe. Publishes periodically updated Design for Recycling guidelines and a free online tool for preliminary assessment.

Current version: v3.1 (August 2025), aligned with the A, B and C grade system plus the Non-Recyclable category. Grades A, B and C represent recyclable packaging, while structures that do not meet the minimum thresholds are classified as Non-Recyclable.

It is the reference tool accepted by industry, retailers and authorities until the official PPWR criteria are published through delegated acts, expected in 2027 and 2028.

CEFLEX D4ACE (Design for a Circular Economy)

Technical guidelines published by the European CEFLEX initiative for designing flexible packaging compatible with the circular economy. Phase 2 (September 2025) is based on the most extensive testing programme specific to flexible packaging carried out in Europe: over 600 samples, 55 materials tested across 5 laboratories and 3 universities.

Defines compatibility thresholds for adhesives, EVOH, carbon black, PET and PVDC in PE and PP structures. A European alternative to RecyClass for assessing recyclability, with its own methodology and independent experimental data.

Cyclos-HTP

A German packaging-recyclability assessment body, an alternative to RecyClass, particularly recognised in Germany and Austria under the national Dual System Germany EPR scheme. Used by brands selling into the German market that need certification compatible with local EPR requirements.

Its methodology differs partly from RecyClass, and a package can score differently under the two systems. For exports to Germany and Austria, Cyclos-HTP certification is frequently requested alongside RecyClass.

Design for Recycling (DfR)

A design principle whereby packaging is conceived from the outset for compatibility with industrial recycling streams: NIR sorting, component separability, recycled-pellet quality.

PPWR imposes mandatory DfR criteria through delegated acts of the European Commission, expected in 2027 and 2028. Until the delegated acts are published, RecyClass v3.1 and the CEFLEX D4ACE methodology are the reference tools accepted by industry. The European standard EN 18120-1:2026, published by CEN in June 2026, provides the formal framework of definitions and design-for-recycling principles.

Recyclable by design vs. actually recycled

A fundamental distinction in PPWR separating two frequently confused concepts.

Recyclable by design: packaging is recyclable by design if its structure is compatible with recycling streams, testable through the RecyClass v3.1 or CEFLEX D4ACE methodology.
Actually recycled: packaging is actually recycled if real collection, sorting and industrial recycling infrastructure exists in the area of use.

From 2035, PPWR requires demonstrated recyclability at industrial scale, not just theoretical recyclability by design, under the recyclability requirement in Art. 6.

Recycled at scale

A PPWR requirement applicable from 1 January 2035, under Art. 6, requiring that packaging be not just recyclable by design, but actually collected, sorted and recycled in real industrial infrastructure.

The assessment methodology, including the actual-recycling percentage thresholds by packaging type, will be set by the European Commission through implementing acts. This requirement makes the future of flexible packaging dependent on the development of PE4 and PP5 streams across all member states.

Sortability

The ability of a package to be correctly identified and separated in automated NIR sorting facilities. A concept distinct from recyclability: a package can be sortable but not recyclable (the resulting pellet is of inferior quality), or technically recyclable but not sortable (local collection and sorting infrastructure does not exist).

The RecyClass v3.1 methodology assesses sortability as one of the components of the final grade (A, B or C). Elements that disrupt NIR sorting: metallised layer, carbon-black pigments, density incompatible with the target stream.

HDPE, LDPE, LLDPE (polyethylene types)

Types of polyethylene differentiated by density and molecular structure:

• HDPE (High Density PE): rigid, used in industrial sacks and containers
• LDPE (Low Density PE): flexible, used in packaging films and bags
• LLDPE (Linear Low Density PE): with puncture resistance superior to LDPE, frequently used in coextruded structures for flexible packaging

PP (Polypropylene)

A polymer used in flexible packaging for its relative stiffness and higher heat resistance compared with polyethylene. Recycling code PP5, density 900-910 kg/m³, melting temperature 160-170°C.

PP is the only flexible polymer that withstands retort temperatures (up to 125°C) and is compatible with hot-fill processes. Mono-material PP structures reach RecyClass Grade A in the flexible PP stream.

BOPP / OPP (Biaxially Oriented Polypropylene)

Biaxially oriented polypropylene, PP film stretched simultaneously in the machine and cross directions, giving stiffness, transparency and mechanical properties superior to standard PP. Density 910 kg/m³.

Used as a printable outer layer in flexible structures, combined with CPP for sealing. Compatible with the PP5 recycling stream, can achieve higher RecyClass grades (A or B) in BOPP/CPP or BOPP/SiOx/CPP structures without metallisation.

CPP (Cast Polypropylene)

PP film produced by extrusion onto chilled rolls, without orientation. Density 900 kg/m³, non-oriented.

Properties: high transparency, excellent sealability at moderate temperatures, grease resistance. Used in mono-PP and CPP/PP structures for hot-fill applications and bakery products. Compatible with the PP5 recycling stream and can reach higher RecyClass grades (A or B) in correctly designed structures.

MDO-PE (Machine Direction Oriented Polyethylene)

Polyethylene oriented in the machine direction, obtained by stretching PE film along the machine direction, giving stiffness, transparency and mechanical properties superior to standard PE, with a density lower than PET (940 kg/m³ vs. 1390 kg/m³) and comparable to OPP.

MDO-PE remains compatible with the PE4 recycling stream and can reach higher RecyClass grades (A or B) in correctly designed structures. Used as a mono-material alternative to PET or OPP in applications with high optical and mechanical requirements.

BOPE (Biaxially Oriented Polyethylene)

Polyethylene oriented biaxially, obtained by stretching PE film in two directions (machine and cross), giving stiffness and mechanical strength superior to standard PE.

BOPE remains compatible with the PE4 recycling stream and can reach higher RecyClass grades (A or B) in correctly designed structures. Used as a mono-material replacement for OPP or PET in applications with high mechanical requirements. A superior alternative to MDO-PE, with better optical and mechanical properties in both directions.

PET (Polyethylene Terephthalate)

A polymer frequently used as the outer layer in classic PET/PE or PET/aluminium/PE laminates, valued for stiffness, transparency and print quality. Density 1390 kg/m³, melting temperature 245-260°C.

Incompatible with the PE4 recycling stream, since the presence of PET in a laminate degrades the quality of recycled PE pellets. The mono-material alternative: MDO-PE or BOPE for applications with optical and mechanical requirements similar to PET, compatible with higher RecyClass grades (A or B) in correctly designed structures.

PA / Nylon (Polyamide)

A polymer with high mechanical strength and oxygen barrier, used in PA/PE or PA/EVOH/PE multilayer structures.

Incompatible with the PE4 recycling stream: the presence of PA above 5% by weight results in classification as Non-Recyclable under the RecyClass assessment. The CEFLEX D4ACE methodology accepts PA6 in PE structures only below 35%, with specific tie layers and demonstrated acceptable impact on pellet quality.

PVDC (Polyvinylidene Chloride)

A polymer with excellent oxygen and moisture barrier, traditionally used in some pharmaceutical and food packaging structures. Incompatible with PE and PP recycling streams.

The CEFLEX D4ACE methodology explicitly classifies it as incompatible based on 2024 testing. Contains chlorine, and releases HCl on incineration, contaminating mechanical recycling streams.

Monomaterial

A packaging structure built on a single base-polymer type (PE or PP), without combining with incompatible polymers (PET, PA, aluminium). The standard threshold is a minimum of 95% of a single polymer for RecyClass Grade A.

Mono-material packaging is not automatically recyclable, since recyclability also depends on adhesives, inks and functional elements. The RecyClass v3.1 assessment confirms whether the specific structure qualifies for higher grades in the corresponding recycling stream.

The EcoMonoFilm® range includes mono-material PP structures (BOPP/CPP) and PE structures (MDO-PE/PE, BOPE/PE) designed for PPWR 2030 compliance.

Functional barrier

A layer or combination of layers in a package that prevents substances from migrating towards the product: oxygen, moisture, light, fats, aromas.

In flexible packaging, the functional barrier is provided by EVOH, metallisation, SiOx, AlOx or combinations of polymers with complementary properties. PPWR introduces recyclability criteria which, together with Design for Recycling guidelines, favour barriers compatible with mechanical recycling over those that block sorting or recycling.

EVOH (Ethylene Vinyl Alcohol)

A copolymer used as an oxygen barrier layer in flexible PE/EVOH/PE or PP/EVOH/PP structures.

Unlike metallisation, EVOH does not disrupt NIR sorting and is conditionally accepted in PE and PP recycling streams, provided the proportion does not exceed 5% of total packaging weight under the RecyClass v3.1 and CEFLEX D4ACE methodologies.

Provides an OTR of 1-5 cm³/m²/day, versus 0.1-1 cm³/m²/day for metallisation.

Metallised layer / MET

A thin layer of vaporised aluminium applied to the surface of a plastic film, providing superior barrier to oxygen, moisture and light. Typical thickness 300-500 Å (30-50 nanometres).

Problematic for recycling because it blocks the NIR radiation used in automated sorting, making the base polymer undetectable. RecyClass classifies structures with a metallised layer above the compatibility threshold as Non-Recyclable in the PE and PP streams.

SiOx (silicon oxide coating)

A thin ceramic layer of silicon oxide deposited on polymeric films by vacuum vapour deposition. Typical thickness 40-80 nanometres, while preserving transparency.

Provides a high oxygen barrier (OTR below 1 cm³/m²/day) and moisture barrier, without disrupting NIR sorting. A recyclable alternative to metallisation in BOPP/SiOx/CPP, PE/SiOx/PE or BOPE/SiOx/PE structures.

Used in premium applications for coffee, food supplements and oxidation-sensitive foods, as a barrier solution compatible with PPWR 2030.

AlOx (aluminium oxide coating)

A thin ceramic layer of aluminium oxide deposited on polymeric films by vacuum vapour deposition. Provides a high oxygen barrier (OTR below 1 cm³/m²/day) and moisture barrier, without disrupting NIR sorting.

A recyclable alternative to metallisation in BOPP/AlOx/CPP or PE/AlOx/PE structures. Typical thickness around 10 nanometres, while preserving transparency. Properties are similar to SiOx; the choice between the two depends on supplier availability and specific barrier requirements.

Aluminium (aluminium foil)

A metal layer used in laminates to achieve a very high barrier to gases, vapour and light. Typical thickness 7-12 μm, OTR below 0.05 cm³/m²/day.

Incompatible with mono-material PE/PP recycling. PET/Al/PE and BOPP/Al/CPP structures are classified as Non-Recyclable under RecyClass v3.1 and become non-compliant with PPWR from 1 January 2030.

For applications with extreme barrier requirements (pharmaceutical, ultra-sensitive products), the alternative is a BOPP/SiOx/CPP or PE/AlOx/PE structure, which keeps OTR below 1 cm³/m²/day with recycling compatibility.

Tie-layer (PE-g-MAH, PP-g-MAH)

A chemically modified polyolefin with maleic anhydride groups, used as a bonding layer in coextruded PE/EVOH/PE or PE/PA/PE structures.

The functional groups form covalent bonds with EVOH's hydroxyl groups or PA's amide groups, ensuring strong interlayer adhesion. The equivalent for PP structures is PP-g-MAH.

Tie layers are essential for the stability of coextruded structures without adhesive. For EVOH in a PE stream, the EVOH-to-PE-g-MAH tie ratio is critical for reaching RecyClass Grade A.

PCR (Post-Consumer Recycled content)

Plastic material sourced from packaging waste collected from end consumers and reprocessed into recycled pellets (rPE, rPP, etc.).

PPWR Art. 7 requires a minimum percentage of PCR in plastic packaging placed on the EU market:

• Minimum 10% from 2030, rising to 25% from 2040 for contact-sensitive packaging made of plastics other than PET (including flexible PE and PP films)
• Minimum 35% from 2030, rising to 65% from 2040 for other plastic packaging
• Minimum 30% from 2030, rising to 50% from 2040 for contact-sensitive PET packaging

Post-consumer vs. pre-consumer recycled

An essential distinction in PPWR Art. 7 separating two frequently confused concepts:
Post-consumer recycled (PCR): material from waste collected from end consumers. Qualifies for PPWR's minimum recycled-content targets.
Pre-consumer recycled: material from production-process scrap reintegrated into manufacturing. Does not qualify for PPWR targets, even if reused internally and reducing virgin-material consumption.

rPE and rPP (recycled polyethylene and polypropylene)

Polyethylene or polypropylene pellets obtained by reprocessing collected and sorted packaging waste.

PPWR Art. 7 requires a minimum percentage of post-consumer rPE and rPP in flexible packaging from 2030. For direct food contact:

• Mechanically recycled rPE and rPP: requires specific authorised technology under Regulation (EU) 2022/1616
• Chemically recycled rPE and rPP (pyrolysis, depolymerisation): offers an alternative with approvals per process and per volume

ISCC PLUS

A certification scheme for sustainability and recycled content, used particularly for mass balance in chemical recycling.

The industry-accepted standard for demonstrating chemically recycled content (rPE, rPP obtained through pyrolysis or depolymerisation) until PPWR implementing acts on the calculation methodology are published.

Manufacturers using chemical rPE or rPP must hold, or require from suppliers, ISCC PLUS chain-of-custody certification. Certification is issued annually and requires independent audit.

Mass balance

A methodology for tracking and allocating recycled content through the production chain, allowing a manufacturer to claim chemically recycled content without the physically recycled material being directly blended into the final product.

Used especially for chemically recycled rPE and rPP intended for food contact. ISCC PLUS certification is the industry-accepted standard.

The exact treatment for certain technologies and the allocation methodologies still depend on the European Commission's secondary acts, expected by 31 December 2026.

Contact-sensitive packaging

A category defined in Art. 3 PPWR: packaging in direct contact with food, cosmetics, medicines, medical devices, infant food or other regulated sensitive products. Many of these categories fall within the industries served by VLM Poliplast.

For recycled content under Art. 7, thresholds are differentiated into 2 subcategories:

• Contact-sensitive PET: 30% in 2030, 50% in 2040
• Contact-sensitive plastics other than PET (including flexible PE and PP films): 10% in 2030, 25% in 2040

Closed-loop recycling

The process by which recycled material returns to the same application or to applications of equivalent quality. Classic example: PET bottles become rPET pellets, which then become new PET bottles.

For flexible PE and PP packaging, closed-loop recycling is technically possible but limited by collection and sorting quality in Eastern Europe. RecyClass Grade A targets materials with potential for closed-loop or high-quality open-loop recycling.

Cascade recycling

The process by which recycled material is used in applications with lower requirements than the original application. The opposite of closed-loop recycling.

rPE pellet from municipally collected flexible packaging is frequently used in cascade recycling for household bin liners or tubing, not for food packaging. RecyClass Grade C targets materials with potential for cascade recycling.

Declaration of Conformity for food contact materials

A mandatory technical document under Regulation (EU) 10/2011 (amended by Regulation (EU) 2025/351) by which the manufacturer attests that the plastic material or article intended for food contact meets EU requirements on migration, authorised substances and traceability.

Distinct from the PPWR Declaration of Conformity. For flexible food packaging, both declarations are required, plus a DoC under Regulation (EU) 2022/1616 if the packaging contains recycled plastic.

PPWR Declaration of Conformity

A mandatory technical document by which the manufacturer or importer of packaging attests that the product complies with the requirements of Regulation (EU) 2025/40: recyclability, PFAS restrictions, recycled content, labelling and minimisation.

A PPWR DoC typically includes: product identification, reference to PPWR and other applicable regulations, packaging composition description, recyclability assessment (with reference to RecyClass v3.1), confirmation of the absence of PFAS, PCR percentage used, authorised representative's signature, date and place of issue.

Kept for 5 years for single-use packaging and 10 years for reusable packaging, under Art. 15(3) PPWR. For full details, see the dedicated page on the PPWR Declaration of Conformity.

Batch certificate

A document issued by the supplier for each batch of raw material or packaging delivered, attesting the characteristics and compliance of that batch with the agreed specifications.

For rPE and rPP, the batch certificate documents the percentage of recycled content, the origin of the PCR and applicable certifications (ISCC PLUS, EuCertPlast). An essential element of traceability in the PPWR Art. 7 compliance chain.

CoA (Certificate of Analysis)

A document issued by the raw-material manufacturer or an accredited laboratory, attesting the analytical test results for a specific batch: composition, purity, absence of restricted substances, compliance with specifications.

For flexible packaging, the CoA is a mandatory supporting document in the PPWR compliance file, alongside the TDS and supplier declarations. For food contact, the CoA includes migration tests (OML, SML) against standardised food simulants.

TDS (Technical Data Sheet)

A document issued by the raw-material supplier specifying the material's technical properties: composition, mechanical, thermal and barrier properties, and compliance with applicable standards.

For flexible packaging, resin suppliers' technical data sheets are mandatory supporting documents for issuing the Declaration of Conformity under Regulation (EU) 10/2011 and PPWR.

LCA (Life Cycle Assessment)

A standardised methodology (ISO 14040 and ISO 14044) for calculating the environmental impact of a product across its entire life, from raw-material extraction to disposal.

Used to calculate the carbon footprint of packaging and to compare mono-material versus multilayer structures. Without a specific, externally verified LCA study, claims about reduced carbon footprint can be difficult to substantiate and may raise the risk of misleading environmental claims.

For CSRD, an LCA is frequently requested as a supporting document for reporting indirect (Scope 3) emissions on the packaging component.

Migration and migration limits (OML, SML)

The transfer of chemical substances from packaging material into the food product. Regulation (EU) 10/2011 defines two types of limits:

• OML (Overall Migration Limit): 10 mg/dm² of contact surface, or 60 mg/kg of food
• SML (Specific Migration Limit): for individual restricted substances (residual monomers, additives, antioxidants), expressed in mg/kg of food

NIAS (Non-Intentionally Added Substances)

A category of chemical substances present in packaging material without having been intentionally added: raw-material impurities, degradation products, reaction products, process contaminants.

Regulation (EC) 1935/2004 requires that NIAS be assessed for safety, through a risk assessment documented by the manufacturer. Particularly relevant for rPE and rPP from municipal collection, where the NIAS spectrum is broader than for virgin material.

SoC (Substances of Concern)

A PPWR category covering chemical substances present in packaging with a potential negative impact on human health or on material recyclability.

PFAS represent the main SoC category targeted by PPWR Art. 5. The European Commission must publish a report on SoC in packaging by 31 December 2026, and the report may extend restrictions to other substances or to non-food packaging.

Digital Product Passport (DPP)

A digital identifier (QR code, watermark, RFID) linking the physical packaging to a database of technical information: materials, recycled content, sorting instructions, compliance.

The Digital Product Passport is a tool under the Ecodesign for Sustainable Products Regulation (ESPR), not under PPWR. PPWR does not create its own DPP, but does introduce its own labelling requirements: harmonised material-identification labels from 12 August 2028 (Art. 12) and digital information accessible via QR code or other standardised means for reusable packaging from February 2029. A dedicated packaging DPP could be introduced after 2030 through a future legislative act, but is not yet provided for by PPWR.

Flexible packaging

Packaging made of thin-gauge materials that can be folded, rolled or compressed without tearing: films, pouches, bags, sachets.

Unlike rigid packaging (bottles, boxes), flexible packaging more often combines different materials in multilayer structures, creating specific challenges for recycling and PPWR compliance. Transitioning to mono-material is the standard solution for 2030 compliance.

Reusable packaging

Packaging designed and placed on the market with the intention of being reused multiple times within a closed reuse system, under Art. 11 PPWR.

Minimum criteria: resistance to multiple use and washing cycles, compatibility with collection, washing and redistribution systems. PPWR sets mandatory reuse targets from 2030 for transport and beverage packaging (Art. 29). Single-use flexible packaging remains the predominant category.

OTR (Oxygen Transmission Rate)

A measure of the amount of oxygen passing through a packaging film per unit of time and area, expressed in cm³/m²/day. The lower the OTR, the better the oxygen barrier.

Typical reference values:

• Metallised: 0.1-1 cm³/m²/day
• SiOx or AlOx coating: 0.5-1.5 cm³/m²/day
• PE/EVOH/PE with 3-5% EVOH: 1-5 cm³/m²/day
• Mono-PE without barrier: 1,000-3,000 cm³/m²/day

WVTR (Water Vapor Transmission Rate)

A measure of the amount of water vapour passing through a packaging film per unit of time and area, expressed in g/m²/day. The lower the WVTR, the better the moisture barrier.

Typical reference values:

• BOPP: 1-3 g/m²/day
• PE/EVOH/PE: 2-5 g/m²/day
• Standard mono-PE: 5-15 g/m²/day

MFI / MFR (Melt Flow Index / Melt Flow Rate)

A standardised parameter (ISO 1133) measuring the flow of molten polymer under defined temperature and pressure conditions, expressed in g/10 min.

Indicates the polymer's molecular weight and processability: a low MFI means a more viscous polymer, suited to film extrusion, while a high MFI means a more fluid polymer, suited to injection moulding.

MFI variability is one of the technical challenges in integrating rPE and rPP into production, since recycled pellets have more variable MFI than virgin material.

Shelf life

The shelf life of the packaged product under normal storage conditions, determined by the packaging's barrier to oxygen (OTR), moisture (WVTR), light, and by storage temperature.

Moving from a classic PET/PE laminate to a mono-material structure can affect shelf life if the barrier is not equivalent. A product-by-product and structure-by-structure technical assessment is mandatory before any transition.

MAP (Modified Atmosphere Packaging)

A technology in which the air inside the packaging is replaced with a gas mixture (CO₂, N₂, O₂) tailored to the product, to extend shelf life.

Requires a high oxygen barrier, typically OTR below 5 cm³/m²/day. Compatible with PE/EVOH/PE structures with under 5% EVOH, which can reach higher RecyClass grades (A or B) in correctly designed structures.

VFFS and HFFS

Types of automated packaging machines that form the bag from film, fill it and seal it:

• VFFS (vertical): used for bulk products (granules, powders, vegetables)
• HFFS (horizontal): used for flat products (slices, bakery products)

Coextrusion

A process for manufacturing flexible films by simultaneously extruding multiple layers of molten polymers through a single die, without lamination adhesive.

An advantage for recyclability compared with lamination if all polymers are compatible. Coextruded PE/EVOH/PE structures contain no adhesive, and the EVOH is bonded directly to the PE layers through compatible tie polymers.

Solventless lamination

A lamination technology for flexible films using adhesives without organic solvents, unlike solvent-based lamination.

Advantages: no volatile organic compound (VOC) emissions during production, no residual solvents in the final structure, easier compliance with the requirements of Regulation (EU) 10/2011 for food contact.

VLM Poliplast uses exclusively solventless lamination in converting flexible structures.

Solvent-based lamination

A traditional lamination technology using adhesives dissolved in organic solvents (ethyl acetate, ethanol). The solvent is evaporated in a heat tunnel before the layers are combined.

Drawbacks: volatile organic compound (VOC) emissions, requires solvent-recovery systems, risk of residual solvents in the final structure, mandatory migration testing for food contact.

Its share of the European industry is declining as solventless technology becomes standard.

NIR (Near-Infrared Spectroscopy)

A technology used in automated waste-sorting facilities to identify the polymer type of packaging.

The NIR sensor emits infrared radiation and analyses the reflected spectrum, and each polymer has a unique spectral signature. Structures with a metallised layer or carbon-black pigments disrupt NIR sorting by absorbing or reflecting the radiation before it reaches the base polymer.

Carbon black

A black pigment used in printing inks and in plastic compounds. Problematic for flexible-packaging recycling because it absorbs the NIR radiation used in automated sorting, preventing correct identification of the base polymer.

RecyClass and the CEFLEX D4ACE methodology classify carbon-black inks as incompatible with the PE and PP streams. Recommended replacements are organic or inorganic pigments free of carbon black, detectable by NIR.

Component separability

The ability of a package's components (cap, label, zipper, valve) to separate from the main structure during the recycling process.

Inseparable components made of incompatible polymers can reduce the recyclability grade of the whole package. PPWR and the RecyClass v3.1 methodology assess separability as a distinct criterion.

A PA zipper on a PE bag can lower the grade if the PA is inseparable and exceeds 5% of the weight.

Zipper / press-to-close closure

A repeatable closure system applied to flexible bags, made of complementary plastic profiles that close by pressing together.

The typical zipper material is LDPE or PP, selected based on the bag structure for compatibility with the recycling stream. Technical requirements: opening force between 8 and 15 N/cm, seal integrity after 20 open/close cycles without loss of pressure.

In the PPWR context, the zipper is a separable component assessed distinctly in RecyClass v3.1 analysis. If the material is incompatible with the bag structure (e.g. a PA zipper on a PE bag), it can lower the recyclability grade of the whole package.

Degassing valve

A technical component applied to roasted coffee packaging that allows CO₂ to be released from inside the packaging without letting oxygen in.

Essential for coffee packaged immediately after roasting, which continues to release CO₂ for several days. From a recyclability standpoint, the valve is a separable component made of a different material and must be assessed together with the bag structure in RecyClass v3.1 analysis.

Recycling stream (PE4 / PP5)

The material category into which packaging is sorted and processed at recycling facilities:

• PE4: the stream for flexible polyethylene packaging
• PP5: the stream for flexible polypropylene packaging

Packaging carbon footprint

The total CO₂-equivalent emissions associated with the production, transport, use and disposal of a package.

Mono-material packaging generally has a lower carbon footprint than multilayer laminates at equal volume, due to simplified production and the possibility of mechanical recycling. An exact calculation requires a specific LCA study for the structure being assessed.

Without an externally validated LCA, claims about reduced footprint can be difficult to substantiate and may raise the risk of misleading environmental claims.