PPWR 15 – Design for Recycling becomes measurable: what EN 18120 changes for plastic packaging

In 2026, the EN 18120 family provided the European plastic packaging industry with a common technical framework for Design for Recycling. The significance goes beyond the publication of another series of standards: the statement “this packaging is recyclable” is increasingly being replaced by a much more concrete question — can we demonstrate that the packaging can be sorted, processed and turned into usable recycled material?

IN BRIEF

• EN 18120:2026 is a family of 15 European standards on Design for Recycling for plastic packaging, adopted in Romania as SR EN 18120:2026.
• Its architecture consists of three general parts — principles, a general evaluation process and sortability — plus six material streams, each with a design guideline and an evaluation protocol.
• A design guideline helps determine how packaging should be designed for compatibility with recycling; an evaluation protocol assesses its behaviour against the relevant sorting and recycling processes and the resulting material.
• Sortability is treated as a separate technical issue from the recyclability of the material itself.
• Compliance with EN 18120 does not, at this stage, automatically mean legal compliance with PPWR.
• Companies can already use the series as a technical preparation tool while the legal criteria and methodologies required by PPWR are being completed.

"It's recyclable." But can we prove it?

For years, a packaging item's recyclability claim rested largely on the polymer from which it was made. If it was PET, PE or PP, the word "recyclable" often followed almost automatically, regardless of how many other components the finished packaging contained or how it actually behaved in real collection, sorting and recycling systems.

There is a real technical gap in that approach. Packaging is not a homogeneous block of polymer but a system: a main body, closure, label, sleeve, adhesive, ink and, where applicable, barrier or coating layers, additives and pigments. All of these can influence the packaging's route through collection, sorting, washing, separation and reprocessing. Actual recyclability is therefore not determined only at polymer level, but at the level of the complete packaging system and its compatibility with the relevant recycling technologies.

This is the area addressed by the EN 18120:2026 series. It provides a common technical framework through which recyclability can be analysed and evaluated, rather than merely declared.

What exactly are the 15 EN 18120:2026 standards?

The "Design for recycling of plastic packaging" series, developed within CEN/TC 261 "Packaging", follows a relatively simple logic when viewed as a whole.

The first three parts are general: Design for Recycling principles and terminology, a general recyclability evaluation process and, separately, sortability evaluation.

The remaining twelve parts are organised around six streams: PET bottles, other rigid PET packaging, rigid PE/PP packaging, flexible PE/PP packaging, rigid PS/XPS packaging and EPS packaging. Each has a design guideline and a recyclability evaluation protocol. Three general parts plus six streams with two documents each form the family of 15 EN 18120:2026 standards, adopted in Romania as SR EN 18120:2026.

The structure reveals an important aspect of the series: the industry is no longer treated as a single category of "recyclable plastic", but as distinct technical streams with their own sorting, processing and evaluation characteristics.

The guideline tells you how to design. The protocol checks what happens next.

The distinction between guideline and evaluation protocol is arguably the most important technical idea in the entire series.

A Design for Recycling guideline provides criteria for designing packaging so that its components remain compatible with the targeted recycling stream. It is primarily a tool for the specification and packaging-development stage.

The evaluation protocol comes afterwards. It allows an already-designed packaging item to be assessed against the relevant stages of sorting and recycling and, where applicable, the resulting material to be characterised through the operations specified by the protocol. It should not be assumed that every protocol physically reproduces every possible stage of the recycling chain; the actual operations depend on the material stream and the applicable protocol.

The series makes an essential distinction: following a design guideline does not, by itself, guarantee that the resulting recycled material will have the quality required for a particular end application. In simple terms, the guideline helps you design; the protocol provides a means of verification and evaluation.

Sortability: before recycling, packaging has to reach the right stream

A packaging item may be made from a perfectly recyclable polymer and still never reach the appropriate recycling process if it is not correctly sorted. EN 18120 therefore treats sortability as a distinct technical stage.

EN 18120-3 addresses sortability evaluation, and CEN-CENELEC identifies current technologies including near-infrared detection — NIR, magnetic separation and eddy-current separation. To enter the appropriate stream, packaging must be capable of being identified and separated correctly by the available infrastructure.

Other elements are also considered in Design for Recycling practice — labels, sleeves, colours and pigments, metallic components, barriers, adhesives, inks and multilayer structures. These are legitimate technical considerations, but it should not be assumed that every one of them constitutes an explicit point-by-point requirement of EN 18120-3. Exact requirements must be checked against the relevant part of the series and the applicable protocol.

Six material streams, six different situations

EN 18120 does not treat "plastic" as a single category because each stream behaves differently during sorting and reprocessing. PET bottles, other rigid PET packaging, rigid PE/PP, flexible PE/PP, rigid PS/XPS and EPS each have their own characteristics and therefore their own guidelines and protocols.

For example, elements such as the sleeve and adhesive of PET packaging, pigmentation and labelling of a rigid PP container, or the barrier structure of flexible PE packaging may become relevant when assessing the compatibility of the complete packaging with sorting and recycling. These are illustrative technical examples of the type of questions Design for Recycling brings into the development process; specific requirements must be checked in the applicable EN 18120 part for each stream.

The consequence is straightforward: "it's PET, therefore it's recyclable" or "it's PP, therefore it's recyclable" is no longer a sufficient technical assessment. The relevant stream needs to be identified and the complete packaging assessed against it.

Why "mono-material" is not enough

Mono-material design is rightly regarded as an important direction in Design for Recycling. Reducing incompatible components can eliminate many of the problems associated with multi-material packaging. But "mono-material" is not, by itself, a guarantee of recyclability.

Even predominantly mono-material packaging still needs to be correctly identified and sorted, while its components must remain compatible with the relevant recycling process and with the production of recyclate of suitable quality. Depending on the packaging configuration, factors such as pigmentation, labels, adhesives or other components may require evaluation. These examples illustrate possible technical issues; they should not be read as a universal list of normative EN 18120 requirements.

This is where the distinction between guideline and protocol becomes valuable again: getting the design right on paper matters, but technical evaluation provides the additional level of verification.

Where does PPWR fit into this picture?

Regulation (EU) 2025/40 builds recyclability around two cumulative dimensions. The first is Design for Recycling: packaging must be designed for material recycling so that the resulting secondary materials are of sufficient quality to substitute primary raw materials. The second is "recycled at scale": packaging must be capable of being separately collected, sorted and recycled at scale under the conditions established by the Regulation.

The timetable, however, needs to be read carefully. The Design for Recycling requirement under Article 6 applies from 1 January 2030 or 24 months after the entry into force of the relevant delegated acts, whichever is later. The Commission must adopt, by 1 January 2028, the delegated acts establishing the Design for Recycling criteria and recyclability performance classes.

For the "recycled at scale" component, the Commission must establish the methodology through implementing acts by 1 January 2030. The requirement applies from 1 January 2035 or five years after the entry into force of the relevant implementing acts, whichever is later. From 1 January 2038, the threshold becomes stricter, with packaging required to achieve at least Grade B under the conditions established by PPWR.

The fact that PPWR generally applies from 12 August 2026 does not mean that the 2030 recyclability methodology or the A/B/C performance grid is already operational. Those criteria and methodologies still have to be completed through the measures provided for in the Regulation.

Is EN 18120 mandatory?

EN 18120 should not currently be presented as a legal obligation automatically imposed by PPWR. It is a family of European technical standards developed in the context of European standardisation work on plastics recycling and Design for Recycling.

At the date of this article, the series should not be presented as an OJEU-cited harmonised standard automatically providing a presumption of conformity with Article 6 PPWR. The PPWR legal architecture for recyclability continues to depend on the delegated and implementing acts that the Commission is required to adopt.

A useful distinction is therefore: PPWR establishes the legal outcome to be achieved. EN 18120 gives industry a common technical framework for addressing and evaluating Design for Recycling. Future Commission acts will establish the legal criteria and methodologies applicable under PPWR. The exact relationship between those criteria and EN 18120 will depend on the content of the acts still to be adopted.

It is therefore not accurate to say that following EN 18120 automatically means PPWR compliance, that the standard already determines Grades A/B/C, or that it currently constitutes the legal methodology under Article 6.

What does this mean for industry?

For packaging manufacturers and converters, EN 18120 provides a common technical language for discussing recyclability with customers and developing internal specifications. For suppliers of polymers, compounds, masterbatches, adhesives, inks, coatings, labels and sleeves, compatibility with recycling streams may increasingly become an important criterion in product development and supplier selection.

For brand owners and fillers, the value lies in moving from broad claims towards a stronger technical basis for evaluating the complete packaging system. For sorting operators and recyclers, the series creates a shared vocabulary with upstream actors and can bring recycling-plant experience much earlier into the packaging-design process.

Ultimately, one of the important changes brought by Design for Recycling is precisely this: decisions made at the design table can influence what happens much later at the sorting or recycling plant.

What can a company do now?

• map its packaging portfolio against the relevant EN 18120 stream — PET bottles, other rigid PET, rigid PE/PP, flexible PE/PP, rigid PS/XPS or EPS;
• identify, for each packaging item, the main body and relevant components — closures, labels, sleeves, barriers, inks and adhesives;
• identify the relevant Design for Recycling guideline and compare existing specifications against it;
• identify the applicable evaluation protocol and consider testing for critical parts of the portfolio;
• open discussions with suppliers, sorting operators and recyclers on sortability and compatibility with existing processes;
• collect and organise available technical evidence;
• introduce change control and document packaging versions;
• involve recyclers earlier in packaging development rather than only after the design has been finalised.

These are technical preparation actions and good practices. They should not be confused with legal obligations directly imposed on companies by EN 18120.

What shouldn't we assume yet?

• that following EN 18120 automatically means compliance with PPWR;
• that "mono-material" automatically means "recyclable";
• that a recyclable polymer automatically makes the complete packaging recyclable;
• that packaging can already be assigned a PPWR Grade A, B or C solely on the basis of EN 18120;
• that all future Commission methodologies are already known in detail;
• that Design for Recycling work can be postponed until close to 2030.

Conclusion

EN 18120 does not, by itself, resolve PPWR's legal obligations and should not be presented as if it did. What it does provide to the plastic packaging industry is a common, verifiable technical language for a question that has too often received a merely declarative answer: not simply "is this material recyclable in principle?", but "can we demonstrate that the complete packaging is compatible with the relevant sorting and recycling processes and that those processes can produce usable recycled material?".

For companies, the distinction between guideline and protocol, between design and evidence, may be the most important lesson of EN 18120. PPWR's final legal criteria are still being developed, but technical preparation does not need to wait until 2030.

SOURCES

• Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste — EUR-Lex
• CEN-CENELEC — EN 18120: Europe sets a new benchmark for recyclable plastic packaging, 24 June 2026
• ASRO — announcement on the 15 standards in the SR EN 18120:2026 series
• European Commission — official documents concerning implementation of Regulation (EU) 2025/40

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