Who takes the lead in shaping Design for Recycling (DfR) standards? Within the European Commission, a political struggle is emerging between two General-Directorates. A pragmatic and a scientifically accurate approach are at odds with each other. A winner is emerging. As a result, you should familiarise yourself with the established standards and the work of CEN/TC 261 Group 10 at an early stage. This will enable you to prepare proactively for the upcoming standards.
Focus on two Directorates General
A political struggle is emerging within the European Commission for leadership in the creation of Design for Recycling (DfR) standards. Two Directorates-General are opposing each other, each with their own approaches:
- DG Grow: The Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs has developed a plastics strategy (KS strategy) based on the Circular Economy Action Plan (CEAP).
- DG Grow focuses on the standardisation process.
- It commissions the European Committee for Standardisation (CEN/TC 261-Group 10) to develop the standards.
- DG Environment: The Directorate-General for the Environment, on the other hand, relies on a science-based approach and works closely with the EU’s Joint Research Centre (JRC).
- DG Environment’s research-based DfR methodology is exemplified by the JRC publication “Technical recommendations on possible elements and parameters of a methodology to assess recyclability of packaging” (2024). Within this framework, existing standards were analysed in a methodologically sound manner and criteria for assessing recyclability were derived with the involvement of stakeholders.
A comparison of strategies: business versus science
- DG Grow uses the KS strategy – even if it is not legally binding – as the basis for a formal standardisation mandate to CEN.
- This pragmatic strategy has the advantage of being quick to implement and fits in well with the EU Commission’s efforts to reduce bureaucracy.
- DG Environment, on the other hand, takes a scientifically accurate approach.
- The aim is to create a fact-based foundation for subsequent legislation or delegated acts.
This parallelism leads to tensions, as the scientific process is more protracted, while the standardisation route delivers results more quickly.
The advantage of standardisation? A race against time
There is evidence to suggest that DG Grow’s pragmatic approach is gaining ground.
- CEN/TC 261-Group 10 has been commissioned to develop a total of 14 standards for KS recycling by November 2025. The following applies:
- RecyClass is currently favoured throughout Europe and is used as a benchmark. In some areas, competing industry standards such as CEFLEX are in the running for flexible packaging.
- However, leading packaging and packaging manufacturing companies that already want to orientate themselves to these standards must live with the fact that they differ from each other in key details.
- The so-called “minimum standard” of the Central Authority does not appear to be officially recognised. However, it remains conceivable that this minimum standard will be considered in the drafting of future delegated acts.
- At the beginning of 2025, CEN received an ad hoc mandate from the EU Commission to extend the existing standard methodology to all other packaging categories by the end of 2025.
Conclusion
The decision in favour of the standardisation route indicates a clear political strategy that focuses on efficiency and feasibility. Standardisation is the political instrument of the EU circular economy. Scientific depth is maintained through parallel processes but not prioritised for the time being.
Consequences and opportunities
For players in the packaging industry, this means that they should familiarise themselves with the standards in progress and the work of CEN/TC 261-Group 10 at an early stage to proactively prepare for the upcoming standards.
We would be happy to support you with an assessment of your packaging portfolio with regard to future compliance with the PPWR regulations. This involves Design for Recycling (DfR) standards, but of course also all other requirements of the PPWR.
