Design for recycling: standards, frameworks and the documents behind a recyclable film

Design for recycling means building a packaging structure so its material can re-enter an existing recycling stream. It is the principle behind the PPWR recyclability requirements, the RecyClass and CEFLEX frameworks, and the EN 13430 standard. This page maps the frameworks, the standards and the documents that prove compliance.

A mono-material film is not automatically recyclable. Adhesives, pigments or inks can prevent effective sorting even with a single base polymer. This page covers the frameworks and the paperwork. The A, B and C thresholds and the 2030-2038 market calendar are covered on the PPWR recyclability grades page.

The three layers behind the term

Summary: the frameworks and standards that apply

RecyClass v3.1: how the rating works

RecyClass assesses a finished packaging structure, not a raw material. The assessment covers the base polymer, printing inks, lamination adhesives and any functional elements, such as valves or zippers. The structure is rated A, B, C or below C, based on its compatibility with the target recycling stream.

A supplier self-assessment is not a certified RecyClass class, and the two should not be presented as equivalent in compliance files.

CEFLEX D4ACE Phase 2: the design guidance for flexible packaging

CEFLEX is the European consortium for a circular economy in flexible packaging. Its Designing for a Circular Economy (D4ACE) guidelines, Phase 2, were published in September 2025. The update is grounded in testing of over 600 samples across five laboratories and three universities. It prioritises mono-PE and mono-PP structures over polyolefin blends, for better sortability and higher recyclate quality. D4ACE is guidance, not certification: it informs design decisions rather than rating a specific structure.

EN 18120: design for recycling becomes a CEN standard

In April 2026, CEN published EN 18120-1:2026, the first part of a standard series dedicated to design for recycling of plastic packaging. The series adds a normative layer above the voluntary industry guidance. It sets uniform definitions, principles for assessing each component against real collection, sorting and recycling processes, and a compatibility classification. Part 13 covers the recyclability evaluation of PE and PP flexible packaging, and the polyolefin parts were developed with input from the CEFLEX programme.

Article 6 PPWR requires the European Commission to take CEN standards into account when defining the harmonised recyclability criteria. The delegated acts due by 1 January 2028 are therefore expected to build on the EN 18120 series. Until they apply, recyclability is legally covered by the surviving essential requirements of Directive 94/62/EC and the EN 13430 standard. The Commission’s 2026 interpretative guidance on the PPWR, together with its official FAQ set of 131 questions, confirms this transitional reading. Structures designed to the RecyClass and CEFLEX guidance are already largely aligned with the EN 18120 principles, because the standard was developed with those organisations’ contributions.

The documents behind a compliant structure

A structure worth specifying should come with paperwork, not just a description: a technical data sheet, a food-contact Declaration of Compliance where relevant, a RecyClass or CEFLEX reference, and the supplier’s ISO 22000 certificate. Under Article 16 PPWR, suppliers are legally required to pass this compliance information down the chain. What each document must contain, the EU food-contact rules and the technical questions to ask before an order are covered on mono-material film standards and compliance documents.

For film structures designed under these frameworks, see monomaterial PE and monomaterial PP. The wider legal framework, deadlines and penalties are mapped on the PPWR Regulation overview.

Frequently asked questions