How far does ‘Design for Recycling’ need to go?
Michael: ‘Design for Recycling’ is key, but it’s not just about easily recognisable design rules. Chemicals, printing inks and protective coatings on labels are also part of the material cycle. Simply stating that a coating is not in direct contact with food therefore falls short. During the recycling process, traces can find their way into the new product. If we want to achieve higher recycled content in food packaging, the requirements must take all design aspects into account. Jana has just provided a real-world example: PVC labels. They impair the recycling process and can lead to unwanted substances entering the recycled material. It makes no sense to justify such solutions on the grounds of design freedom if the consequences are subsequently borne by sorters and recyclers. The industry must decide which materials are acceptable in a high-quality circular economy and which are not.
Jesper: Extended Producer Responsibility (EPR) schemes can translate this decision into economic incentives. Those who meet the ‘design for recycling’ criteria should be rewarded. Those who fail to meet them and impose additional costs on the system should expect to face corresponding eco-modulation. For this to work, the criteria must be technically sound, and their application must have real consequences. Guidance without incentives or sanctions has only a limited impact on the market. The European PET Bottle Platform’s bottle guidance and PETCORE’s TCEP tray guidelines provide technical starting points. Guidance alone will have limited effect unless the resulting grades carry meaningful economic consequences.
Jana: The example of the milk bottle shows that specifications alone are not enough. Even if a brand owner explicitly excludes PVC, a change in the supply chain may go unnoticed. A functioning circular system therefore requires measurement, traceability and direct communication. Then a design problem can not only be identified, but also quickly corrected at its source.
Tania: For machine manufacturers, ‘Design for Recycling’ means understanding the actual properties of the material at an early stage. The more transparent the composition and the more consistent the material flow, the more precisely process windows can be defined. This improves quality and productivity. The best machine operates most efficiently when it has been designed for the circular economy from the outset.
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''The industry must decide which materials are acceptable in a highquality circular economy and which are not.'' - Dr. Michael Heyde
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Where is the greatest value lost in the PET stream/PET cycle today?
Michael: It’s still at the collection stage. In several European countries, collection rates are too low. Material that doesn’t even enter a suitable system cannot be recovered by any downstream technology. That’s why the expansion of the circular economy must begin with reliable collection.
Jesper: As soon as a high-quality PET bottle ends up in the wrong disposal stream, a significant proportion of its value is lost. This shows how closely consumer information, infrastructure and sorting quality are interlinked. Higher recycling targets only help if sufficient suitable material actually enters the correct stream.
Tania: This is precisely where the gap between access and participation lies. A collection bin within easy reach does not in itself guarantee that a bottle will end up there. The industry should therefore communicate more directly with consumers and explain that their decision at the end of a product’s life either enables or prevents the next production cycle.
Jana: After collection, sorting, cleaning and decontamination remain crucial. With each cycle, the colour in particular can change; higher rPET content can lead to a darker or more greyish appearance. A well-controlled material flow limits these effects. At the same time, we should discuss which visual expectations are genuinely technically necessary and which stem from familiar marketing imagery.
Do brands and consumers need to be more accepting of visible differences in rPET?
Tania: Some brands in the US are already pointing out that a bottle appears slightly greyish because it is made from 100 per cent recycled material. I think that’s an important approach. The paper industry has succeeded in establishing small inclusions or a less-than-perfect surface as a visible sign of recycling. A similar shift in perspective would also be possible with PET: a slight colour variation could be viewed positively, rather than automatically being regarded as a quality defect.
Jana: The visual change is real, particularly when material is recycled multiple times. Proper sorting, cleaning and decontamination therefore remain important. But the industry shouldn’t make every deviation from virgin material a criterion for exclusion. If a product is safe and fulfils its function, a visible history of recycling can be part of its quality.
Michael: I’m not sure whether consumers actually have the greatest concerns. It is often the brands’ marketing departments that demand a finish identical to that of virgin material. The industry should examine more closely which expectations come from the market and which it perpetuates itself. Honest communication could create greater scope.
Jesper: Fillers and converters can lead by accepting modest variations in the colour or clarity of rPET packaging, provided that food safety and product performance are maintained in tact. By using more rPET and explaining visible differences to consumers, they can help make rPET a normal choice before higher legal quotas take effect. This would strengthen rPET demand today and demonstrate that circularity can advance ahead of regulation.
Is the European regulatory framework sufficient to stabilise the market?
Jesper: In my view, the EU Packaging Regulation (PPWR) is a groundbreaking piece of legislation. What is crucial now is its proper implementation. The market needs clearly defined responsibilities, effective incentives and equally clear consequences if targets are not met or systems are exploited. This also applies to imports. They should not be blocked, but must meet the same requirements as European recycled materials. European producers face intense price pressure in both virgin and recycled PET (currently under the same taric code). The PPWR can help create a demand for recyclates, provided its targets are consistently enforced and imported materials meet equivalent requirements (in practice not only on paper). A stable market needs competitive European capacity for both vPET and rPET.
Michael: Recycling must not depend solely on whether the price of virgin material is currently high or low. If it rises, interest in recycled material grows; if it falls, demand plummets. A circular economy cannot invest stably under such conditions. We need a social consensus that is translated into binding rules and actually enforced. My greatest concern is that the regulations planned for 2030 will be watered down again before they come into force. Companies are investing today on the basis of these targets. If policymakers later hesitate, these efforts could be undermined. Credibility therefore also means reliably sticking to agreed paths.
Jana: Switzerland demonstrates that a system can achieve high average rPET content even without identical requirements for every bottle, provided that the stakeholders pursue common goals. At European level, however, we are seeing greater fluctuations. Regulation should therefore not merely set quotas, but facilitate stable cooperation and long-term planning.
Tania: The industry must play an active role in shaping these rules. We cannot simply hold governments responsible and then criticise them for failing to take technical realities sufficiently into account. As the saying goes in Washington: ‘If you’re not at the table during political discussions, you’re on the menu.’ At present, the plastics industry often feels more like the subject of the debate than an active partner. We need to change that.