Reuse or recycle? This is the dilemma in the era of the Packaging and Packaging Waste Regulation or PPWR. On the recyclability of cellulose-based materials and products, however, the paper industry does and has done a lot over the years, aiming at sustainable and recyclable packaging. One wonders, therefore, how to proceed along this path and how to study packaging with these characteristics already at the design stage
When it comes to the recyclability of cellulose-based materials and products, the most frequently asked question is how to design packaging that is sustainable, recyclable and meets market demands. All this taking into account, of course, the relevant regulatory developments.
Europe – but not only Europe – has now embarked on the long road of transforming its economy from linear to circular. An economic model in which production and consumption are focused on the re-use, repair and recycling of existing materials and products, to extend their life cycle as far as possible.
Europe and circularity
Precisely in order to promote the transition to a more sustainable economic model, the European Union is updating its legislation on waste management. The numbers leave no doubt: over 2 billion tonnes of waste are generated in the EU every year. Within this, packaging waste has increased over time, rising from 66 million tonnes in 2009 to 84 million tonnes in 2021, “so on average, each European generated around 188 kilograms of packaging waste in 2021, a figure that is expected to rise to over 200 kilograms in 2030 if no further measures are taken”. This was spoken by Cristina Lugli, EU market development manager at Lifeanalytics – Ecol Studio, who discussed these topics during a webinar dedicated to recyclability, as part of the “Coffee with the Specialist” initiatives organised by Lifeanalytics.
However, the packaging chain – which, by the way, generates income, if we consider that in 2018 it generated a turnover of 355 billion euros in Europe – is also the one that can make a concrete contribution to the circular economy, in particular through the recyclability of paper and cardboard packaging.
In Europe – considering the Cepi (Confederation of European Paper Industries) area – the leading paper and board producing country is Germany (25.5% in 2022, according to Assocarta data), followed by Italy (10.3%) and Sweden (10.1%).
It is precisely Italy that has succeeded over the years in building up a solid paper collection and recovery system, also becoming the second largest European user of paper for recycling, with a consumption of around 5.4 million tonnes, or 11.4% of the volumes used in the Cepi area as a whole, which amounted to 47.3 million tonnes in 2022. Germany still ranks first in Europe for the utilisation of this valuable secondary raw material, while Spain and France ranked third and fourth respectively, behind Italy.
The recycling rate of cellulose packaging is also remarkable, with excellent figures for Italy: in 2022, the recycling rate exceeded 81%, confirming that the European targets for 2025 will be exceeded, while the recycling rate of cellulose put on the market in 2023 – Comieco (Consorzio Nazionale Recupero e Riciclo degli Imballaggi a base Cellulosica – National Consortium for the Recovery and Recycling of Cellulose-based Packaging) data – exceeded the European target set for 2030. “Recovered paper is confirmed as the main source of cellulose fiber for the Italian paper industry. And these figures highlight the solidity of the collection, recycling and recovery system in a complicated context,” says Lugli. “And this is so because the general drop in consumption, particularly food, linked to the rise in energy and raw material costs, has had a clear effect on utilisation rates.”
Packaging waste regulations
On the subject of packaging and packaging waste in Europe, Directive 94/62/EC is currently still in force, which “lays down the requirements with which the Member States must comply, e.g. the essential requirements concerning the composition of packaging and its reusability and recyclability, and sets recovery and recycling targets,” Lugli continues.
As far as the management of packaging is concerned, there is a set of harmonised standards in Europe, among which the manager mentions UNI EN 13430:2005 “Packaging – Requirements for packaging recoverable by material recycling which defines the requirements that packaging must have in order to allow recovery by recycling processes of the materials of which it is composed”.
It should also be kept in mind that up to almost 80 per cent of the environmental impact of a packaging is determined at the design stage; to manage this crucial component from the perspective of material recovery and recycling, ecodesign is important. “Recycling-oriented packaging design is one of the most efficient measures to improve the circularity of packaging, also increasing the recycling rate and the use of material recycling content”.
The time horizons of recycling
To ensure that all packaging is recyclable by 2030, as stated in the European Union’s Circular economy action plan (Paec), packaging must already be designed for material recycling.
Even the text of the Packaging and Packaging Waste Regulation (PPWR), in Article 6, talks about recyclable packaging. It states that packaging is considered recyclable if it complies with certain specific conditions, Lugli continues, i.e. if – paragraph 2a) – it is designed for recycling, the so-called design for recycling, in such a way that the secondary raw materials are of sufficient quality compared to the original materials to be used as a substitute for the primary raw materials. And if – paragraph 2b) – when it becomes waste, it can be separately collected, sorted into specific streams, without compromising the recyclability of other streams, and recycled on a large scale.
The article also provides the timelines for these specifications: the first condition, paragraph 2(a), will apply from 1 January 2030 or 2 years after the entry into force of the delegated acts, whichever is later; the second, paragraph 2(b), from 1 January 2035 or 5 years after the entry into force of the implementing acts, whichever is later.
The regulation also makes it explicit that it is the manufacturer who assesses the recyclability of packaging on the basis of delegated acts, a recyclability assessed per unit, in weight, [assessment of recyclability per unit, in weight] and expressed in classes A (greater than or equal to 95 per cent), B (greater than or equal to 80 per cent), C (greater than or equal to 70 per cent) and three legislative horizons are given:
– from 2030, non-recyclable packaging according to classes A, B, C will not be placed on the market
– from 2035 they will have to comply with classes A, B, C and ‘large-scale recycled’.
– from 2038, class C will be eliminated and will no longer be allowed on the market.
“The concept of ‘recycled at scale’ [‘packaging waste recycled at scale’] therefore becomes important,” adds Lugli. Large-scale recycled packaging waste is ‘packaging waste which is collected separately, sorted and recycled in installed infrastructure, using established processes proven in an operational environment which ensure, at Union level, an annual quantity of recycled material under each packaging category’] which, for paper, is 55 per cent or more.
The recyclability assessment method
Article 6, Lugli recalls, also states that by 1 January 2028 the European Commission, after taking into account the standards developed by the European standardisation organisations – the CEN – will adopt delegated acts to establish: design-for-recycling criteria and recyclability performance classes, the modalities to be followed to carry out the assessment, a description for each packaging category and a framework for modulating the financial contributions for producers to fulfil their obligations according to the packaging recyclability performance classes.
“To date, there is a working group within CEN/TC 172 ‘Pulp, paper and board’ that is developing this standard on the basis of the Cepi method; it is WG2, which, among other things, aims to revise, on an ongoing basis, the nomenclature for the European standard describing standard grades of ‘Paper for recycling (PfR)’”.
To date, existing standards are used to measure recyclability. In Italy, for example, Lugli recalls, there is the UNI 11743:2019 standard ‘Paperboard. Determination of recyclability parameters of predominantly cellulose materials and products’. “The standard specifies a method for determining the most significant parameters for assessing recyclability on a laboratory scale; it practically simulates some of the main stages of industrial papermaking processes. The method makes it possible to assess two types of parameters: process parameters – coarse rejects, flakes, content of adhesive particles – and parameters related to the quality of the product that is obtained from the recycled fibers – i.e. sheet formation, adhesiveness, optical inhomogeneity. And the standard only applies to paper and board understood as predominantly cellulose materials”.
At European level, there is also the Cepi Recyclability Test Method “This is a harmonised method that simulates the most common industrial steps to measure recyclability. The use of the Cepi method makes it possible to assess the recyclability required by EN 13430, which however is a generic standard and does not explain how to assess recyclability; guide eco-design with regard to recyclability of cellulose-based products; and support manufacturer’s claims of recyclability”.
Then there is Aticelca Test Method 502, which assesses how easily and effectively paper and non-paper constituents of materials and products, including packaging, can be separated by hand by consumers. “The method applies to all materials and products made up of two or more constituents, at least one of which is predominantly cellulose – paper and cardboard – so that it can be sent for recycling into paper in accordance with current regulations and the instructions of Conai (National Packaging Consortium). The objective of the Aticelca 502 method is to complement the Aticelca 501 Assessment System of the recyclability of predominantly cellulose materials and products, allowing different materials to be separated so that only the constituents of paper and cardboard are subjected to recyclability. So again, it is a useful tool to promote ecodesign in terms of design” .