Sustainability Perspectives: A CEN design for recycling standards deep dive

0:08The main thing that brand owners will see when they are looking at the DFR guidelines is the EPR fees that will come as a penalty for materials or packages that are not very

0:23Elisabeth Skoda: well recyclable. So the lower your grade, your recyclability score, category A, B, C, the higher the EPR fee will be. That amount can be quite substantial. For example, in the Netherlands at this moment, the upcharge on EPR fees for a plastic packaging that is poorly recyclable is already€1 ,000 per ton for polypropylene, roughly. That means that your price for your container and material price is going to double, which is substantial.

1:01Ronald Wiegers: Hello and welcome to the latest podcast in our sustainability perspective series. My name is Elisabeth Skoda, I'll be your host today. Earlier this year, the European Committee for Standardization, in short SEND, published a new series of design for recycling standards, which cover a wide range of plastic packaging formats from rigids to flexibles. But what does this actually mean for the packaging value chain in practice and particularly for labels and how is this all related or tie in with the PPWRG regulations? For this podcast, we're going to delve a bit deeper into this question. And I'm very pleased to welcome Ronald Vigas to the podcast today.

1:43Ronald Wiegers: He is Principal Scientist at Avery Dennison and also a SEND Guidelines Expert. And yeah, we'll discuss what the guidelines entail, timelines designed for recycling and recycled content mandates, ongoing collaborations, innovations, especially from Avery Dennison's side, of course, and much more. Welcome, Ronald. It's great to have you on the podcast today.

2:07Elisabeth Skoda: It's great to be here.

2:08Ronald Wiegers: To get us started, maybe for our listeners who are not that familiar with the guidelines, could you give me a brief overview of what they entail and also how they fit into the wider framework of the PPWR timeline? Sure.

2:23Elisabeth Skoda: Sure. The whole PPWR came from the notice that there's just not simple enough recycled content floating around in the value chain to increase the amount of recycled content in packaging. And the European Union has a desire to reach circularity somewhere in 2050. And for that, you need packaging that is made up of largely recycled content. There's just not enough recycled material around. So they want to boost the quality and the amount of good recycled material. And to do that, they have ordained that from 2030 onwards, all packaging that is being put on the market in Europe needs to be designed for recycling.

3:18Elisabeth Skoda: And then there are a couple of things that are attached to that. from 2030 onwards, you will find that your packaging needs to have a certain recyclability score attached to it. It can be a grade A, a grade B, a grade C. And based on that grade, you will have to pay a certain EPR fee, extended producer responsibility. And also based on that, your packaging may not be admitted to the market. If you are, for example, below the recyclability score of 70%, you won't be allowed on the market from 2030 onwards. And if you're in class C, that from 2038, you won't be allowed on the market. So that is how the European Commission wants to improve the quality and amount of recyclate suitable for usage in packaging.

4:10Elisabeth Skoda: And that is where SEND comes in, because you need certain criteria in order to find out if a package is designed for recycling. And the guidelines that have been published now by SEN, they give you an idea or guidelines how to decide whether your package is designed for recycling. A couple of things that we need to stress here is that at this moment, we do not know what the final outcome of this whole process will be. SEN has published a series of guidelines. They are being revised over the coming period again. And then in 2028, the European Commission will publish the Delegated Act based on those guidelines.

4:58Elisabeth Skoda: And only then will we know what the actual law is going to be in terms of design for recycling guidelines. And also then we will know what the calculation method will be, how you end up from the design for recycling guidelines to this A, B, C category. So that's in a nutshell what the PPWR will mean for packaging in the short and a little bit longer run.

5:26Ronald Wiegers: And yeah, I wanted to zoom in a bit on labels and wanted to ask you, could you talk us through some of the key points of the same guidelines that are relevant for labels.

5:37Elisabeth Skoda: Yeah, sure. Happy to do that. The labels are an important part of the packaging because it shows, it gives you aesthetics, it gives you information, and so they will always be there. And so far there has been doubt about whether or not labels are compatible with recycling. So there has been in CEN quite a lot of discussions on how to ensure that labels are compatible with recycling. And there are a number of points that you need to address there. So first and foremost is that the label should not interfere with the sorting. So if you throw everything or your plastic packaging in a recycled container, your yellow bag or whatever you use to dump your plastic waste, that plastic needs to be sorted.

6:31Elisabeth Skoda: There's PET, there's PP, ACP, LDPE, there's polystyrene, there's a lot of variants, varieties in the plastic stream. That has to be sorted. If you have the wrong label or a label that has a certain type of decoration or a certain type of inks, they can tamper with the sortability of the plastic packaging. So that is one thing that you need to make sure is that your label does not interfere too much with the sortability. There are processes and protocols for in place in one of the design for recycling guidelines. That's first. Then we need to go into a little bit into the packaging formats. Then we're talking about rigid packaging.

7:19Elisabeth Skoda: We have flexible packaging. And what we see in rigid packaging that those are, for example, PP containers like shampoo bottles, pet bottles, pet meat trays, those kind of packaging. Those are rigid packaging. What we see there is that the label needs to separate in the recycling process from the container. The container is the price that the recycler will want to retrieve. The label with the inks and all the decorations and the varnishes and the adhesives, they want to get rid of that because that contaminates the valuable quality of the container. So in the guidelines, it's said that labels need to be removed.

8:04Elisabeth Skoda: There are different protocols and processes per type of packaging that tells you how to assess that. But by and large, the labels need to be removed. For flexible packaging, that is not the case. Anyway, not at the moment. It is very difficult in the recycling process for flexibles to separate the label from the flexible packaging because there's so much alike. And therefore, the strategy there is to have more or less a mono material, a PE label on a PE container, a PP label on a PP container. And that is the weight for flexibles. So that is where those three aspects, sortability, removability from rigid containers, and mono material for flexible containers, Those are the key learning points that you need to remember for the design for recycling guidelines when it comes to labels.

9:02Ronald Wiegers: I wanted to hear a bit more about what Avery Dennison does around making sure that labels can be removed during the recycling process and all the other factors you mentioned. Could you talk a bit more about that?

9:16Elisabeth Skoda: Oh, yes, sure. We have a number of solutions already available and there are other solutions in the pipeline. that are compliant to the DFR guidelines as they are currently known from SAM. We have, for example, our clean flake portfolio for PET containers where the adhesive very nicely is removed together with the label from the PET container and you have perfectly clean PET flakes after that process and the label is very nicely washed away with the label and the adhesive. For that alkaline process that you have with PET, you don't have that with PEPP. Those are relatively simple recycling processes where you have a lot of friction, a lot of shear and a bit of cold or warm water.

10:14Elisabeth Skoda: But we have shown in a very large industrial scale trial that a number of our adhesives are compatible with those kind of processes as well. So that means that we have now in Sen put a protocol in place where you can apply a lot of shear. And if you can show that that shear removes the label from your container, then the label solution is classified as being compatible with recycling process. So there are a number of solutions in place that we have, and there's still some more to come in the future.

10:53Ronald Wiegers: Great, and we look forward to hearing more about those, of course, when they come as well. I was also wondering, is there anything in these new CEN guidelines on the topic of adhesives? Because obviously they're a key point for labels.

11:06Elisabeth Skoda: Not so much on adhesives as well to the materials. One thing that is still very common, you see that quite often, is that paper labels are being applied to plastic containers. and what is now very clear in the guidelines is that paper and plastic recycling is not very compatible especially papers that are very water sensitive and so non-wet strength papers as they are called they they will be banned so from 2030 onwards you won't be able to to apply a simple cheap paper label to a plastic container. Not on PET, not on PP, not on PE. You can apply to a certain extent a wet strength paper. Those are more expensive papers.

12:00Elisabeth Skoda: But the best of obviously is filmic labels, plastic labels that are much better compatible with the recycling process. So paper labels never will get you full compatibility with recycling process, only limited compatibility in recycling processes.

12:15Ronald Wiegers: From your experience working with brands, what are the main challenges that they face around label recyclability and what would your advice be to them or how would you help them to tackle these challenges?

12:30Elisabeth Skoda: So the main thing that brand owners will see when they're looking at the DFR guidelines is the EPR fees that will come as a penalty for materials or packages that are not very well recyclable. The lower your grade, your recyclability score, category A, B, C, the higher the EPR fee will be. And we don't know what that is going to be. That calculation is not clear. The EPR fees will deviate country per country. The calculation for the ABC score that will be harmonized throughout Europe, but EPR fees can differ. And also the ECHO modulation, the difference between a grade A and grade B can also be different between the various countries.

13:21Elisabeth Skoda: But that amount can be quite substantial. For example, in the Netherlands at this moment, the upcharge on EPR fees for a plastic packaging that is poorly recyclable is already 1000 euro per ton for polypropylene roughly that means that your price for your container and material price is going to double which is substantial so that is that is going to be a key driver for brand owners to make sure that their packaging costs are as low as possible to make sure that you end up as high as possible in your categories in your recyclability score. That is one thing. Then also what we see is, we already briefly touched upon that, the size of the label, the decoration.

14:10Elisabeth Skoda: Brand owners want to increase their label size as much as possible in order to have better shelf appeal, more information surface on the container. But there's a limit to what you can do. if your label is too large the recycler won't be able to sort the package in the right container in the right stream so that is something that brand owners also need to realize that there is a limitation to how much label you can apply of course we want to sell as many square meters

14:41Ronald Wiegers: as we can but there's a limitation do you have any examples or maybe case studies of how Avery Denison's label solutions already align with SEND guidelines. Is there anything you'd like to highlight there?

14:54Elisabeth Skoda: Of course, we have the earlier mentioned CleanFlake solutions where we are compatible with a number of guidelines, be it RECICLAS, be it PETCOR, and also compatible with the DFR guidelines from SEND, where you have to show that in a certain laboratory environment, your adhesive cleanly detaches from the pet container. And our CleanFlake portfolio is doing that very nicely. The other topic we also just briefly touched on is the fact that we have shown that P-labels or PP-labels from a P-E container, HDPE container, they are already detaching very nicely if you select the right adhesive. And we have a number of adhesives in place, S7000ER, but also S692N.

15:44Elisabeth Skoda: that are compatible with a PE recycling process. And we have shown that in the industrial trial that we have done about two years ago. And of course, we have the capability in-house to run all these simulation tests with shredders and washing solutions. We are uniquely qualified to do all these tests in-house and make sure that every adhesive that we put on the market is going through all the rigorous testing that these all these various guidelines are are requiring.

16:21Ronald Wiegers: And is Avery Dennison involved in any industry collaborations working on recyclability criteria that you'd like to talk about in this context?

16:33Elisabeth Skoda: Yes the SEN effort is already an industrial collaboration. It is an independent institute, SEN, that organizes this but the participants come from all over the industries. But already before everything is being discussed in SEN, there are various consortia that are discussing, proposing, testing all these these various recycling streams, recycling solutions. We mentioned Recyclast, but if you look at the efforts that are currently ongoing in the papers world, we talk about Forever Green, if we talk about the glass industry, we have the various discussions within SETI in France. With these kind of consortia, it is necessary to already start doing the work in a very early stage that we know what we can expect, what the guidelines may end up to be and then we can at a very early stage start tuning our product and selecting our products to make sure that they're compatible with whatever comes out.

17:46Ronald Wiegers: Perfect, thank you. And I'd like to wrap up by looking to the future a bit. How do you expect the regulatory landscape to develop? What What developments do you expect and how will that shape innovations and strategy at Avery-Denison?

18:02Elisabeth Skoda: The PPWR is here and is here to stay. So that will not go away. What actually is going to happen over the next two to four years, that is going to be a very interesting development. We don't know what the outcome will be. We already have at some points some pushback from the industry, from some industry partners that can we change this? Can we change that? this is we don't like this and those are all valid points so it may be that in the next revision those will uh those will change it may be that the european commission will not 100 take over whatever comes out of sen and put it in the in the in law and that is finally the proof of the pudding and then it's going to be very interesting and that is date that everybody's looking forward to is in 2035 you don't need only to have something designed for recycling but you also need to show that that recycling is taking place at scale and that is going to be very important because then is that's where the rubber starts meeting the road and this is where you start looking at okay is this really something that is viable, commercially attractive, and giving the right quality?

19:22Elisabeth Skoda: So that is something that everybody's looking forward to. Yeah, and what we will do from Avery Dennison's side is we will very closely follow all these developments and where necessary start tuning our products and start. And one thing that we also will do is help our customers and brand owners to select the right label solution for their DFR questions. Every package is unique and we will make sure that you can keep your package unique.

19:54Ronald Wiegers: Perfect. That sounds great. So yeah, it sounds like there's going to be much more material for further discussions and podcasts for the years to come. I think that will keep us all busy. Absolutely. Looking forward to that. So yeah, that brings us to the end of our conversation today. Thank you very much for being on the podcast today, Ronald.

20:15Elisabeth Skoda: Entirely my pleasure.

20:17Ronald Wiegers: Thank you. And yeah, if you'd like to hear more from Avery Dennison, they will also be at the Sustainable Packaging Summit, which this year is taking place again in Utrecht in the Netherlands from November 10th to November 12th. Make sure you head over to our website to get your tickets for that if you haven't done so yet. and also make sure to subscribe to our podcasts on whatever platform you might be listening to it so you don't miss out on any of the latest episodes thanks very much for listening goodbye

21:05Thank you.