Recyclability Minimum Standard 2026: How Packaging Recyclability Is Now Measured as a Percentage

The new 2026 edition of the German recyclability minimum standard has been published. On 31 August 2026, the Zentrale Stelle Verpackungsregister (ZSVR) released the 109-page document in agreement with the German Environment Agency (Umweltbundesamt, UBA). It governs how the recyclability of packaging subject to system participation on the German market must be calculated. The core logic is unchanged: recyclability is neither a label nor a score, but a single percentage figure related to the weight of the packaging. The recyclability minimum standard measures how much of a packaging unit can actually be recovered as valuable material through sorting and recycling, after deducting design-related losses.

Why a German document suddenly matters across Europe

The legal basis is Section 26 of the German Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG), the act implementing Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Under that provision, the dual systems must create incentives through their participation fees for materials and material combinations that can be recycled to the highest possible percentage in actual sorting and recovery practice. The uniform framework for measuring that percentage has to be issued by the ZSVR every year by 1 September, in agreement with the UBA. This obligation stands until the delegated acts under Article 6 of the PPWR become applicable.

That interim period is exactly what gives the document its weight. From 2030, the PPWR makes recyclability a precondition for marketability: packaging may only be placed on the market if it is at least 70 per cent recyclable. Until the European secondary legislation applies, German rules on the ecological modulation of participation fees have to be based on the minimum standard, which therefore takes on a genuine regulatory role for the transition. Gunda Rachut, Chair of the ZSVR, pointed out in the accompanying statement that companies running the calculation today already know whether their packaging clears or misses the 70 per cent European threshold, subject to the European provisions still to be issued, which gives them time to adapt.

The current edition applies to packaging placed on the market in the following calendar year, that is 2027. The text builds on the recommendation of the ZSVR’s third expert circle and was finalised after a public consultation procedure.

The calculation in three steps

Step one is defining the object of measurement. As a rule this is the entire unfilled packaging, including every integrated component: labels, sealing films, lids and closures, adhesive applications and tamper-evident seals. The fact that a component can be separated by hand is not in itself a reason to measure it separately.

There are exceptions. Components must be measured separately where they necessarily and irreversibly have to be detached for use or consumption, such as tear strips, crown caps, champagne corks and wire cages. The same applies to outer wrappings like folding boxes or wrapping films that must be fully removed before use, to unattached components serving transport protection, and to inserts, sorting aids and separating sheets or films that are neither glued nor otherwise mechanically joined.

Separate measurement also applies to components that reliably detach purely through mechanical stress during transport or during preparation for sorting, for example push-on and snap lids and over-caps without an undercut; this exception only covers packaging destined for the mixed lightweight packaging collection. Results for separate components stand on their own and are not weighted into a combined result for the packaging unit.

Step two is category assignment, determined by the dominant material of the main body. Annex 1 contains the binding allocation and decides which recycling pathway forms the basis of the assessment. Following Table 1 of Annex II to the PPWR, Annex 2 sets out separate measurement rules for 22 categories, from glass through liquid cartons and the various PET, PE, PP and PS variants to wood, textile fibres and ceramics.

Step three is the calculation itself. In each category table, every design parameter is classified as “valuable material”, “incompatibility”, “separable or conditionally compatible”, or “requiring examination”. If no parameter is classified as an incompatibility, recyclability is simply the sum of the weight shares of the materials classified as valuable material. Where a parameter requires examination, the user has to determine whether it causes design-related losses of valuable material and deduct them if it does. If even one parameter falls under incompatibilities, the result is zero per cent. The formula divides valuable material content minus design-related losses by the total weight of the object of measurement.

Four criteria decide the outcome

The methodology tests four requirements. First, the packaging must contain no incompatibility capable of preventing recycling in practice. Second, it must be sortable with respect to its valuable material content. Third, after size reduction the materials must be separable, to the extent this is needed to produce secondary raw materials of sufficient quality to replace identical primary materials in typical applications. Fourth, a recycling infrastructure delivering that quality must exist.

Criteria one and four are binary: if either fails, the packaging is not recyclable within the meaning of the standard. Criteria two and three are analogue and reduce the result gradually, through a proportional deduction from the available valuable material content. Sortability criteria derive from magnetic separation (ferromagnetism), eddy current separation (effective electrical conductivity) and NIR sorting (the reflection spectrum of the packaging in the near infrared range).

Screening, air classification and ballistic separation yield no design criteria, because with proper process management these preparatory steps cause no design-related losses. Criteria for separability after size reduction derive from wet mechanical defibration of paper, density separation of plastics, and optical transmission sorting of glass cullet.

One detail is easy to miss: residual product must be taken into account where the construction of the packaging means filling material remains after proper emptying. The standard names silicones, acrylates, polyurethanes and other cross-linking substances, waxes and paraffins, and bituminous masses as relevant cases.

What is new in the 2026 recyclability minimum standard

According to the ZSVR, the methodology itself has not changed. The revisions sit in the detail: the authors added design parameters, differentiated some of them more precisely, and grouped others together where different approaches lead to the same result. The guiding principle is “as simple as possible, as detailed as necessary”, so that companies can assess their own packaging faster and with fewer errors.

In terms of data efficiency, the calculation still requires no complex analyses. The material, the design parameters such as material combinations or barrier coatings, and their weights are enough. Separate examination is needed only for parameters explicitly flagged as requiring it, and that remains the exception rather than the rule.

Equal treatment of materials is the other central principle. All packaging materials are assessed with the same methodology, without flat-rate additions or deductions favouring particular materials or designs. At the same time the door to innovation stays open: the lists of valuable materials and incompatibilities are exhaustive for this edition, but individual evidence can justify a departure. Annex 3.1 requires reliable, accurate and reproducible methods reflecting the state of the art, full documentation of methodology, sample preparation and machine parameters, and, for a general exemption, publication of the study report or its release for the next consultation procedure at the latest.

Concrete examples: glass, PET bottles, paper

For glass packaging the reference application is container glass. Ordinary soda-lime glass including pigmentation counts as valuable material, whereas lead glass, borosilicate glass, glass ceramics, quartz glass and other lead-bearing glasses are incompatibilities and drive the result to zero. Direct printing, foil embossing and varnish are classified as separable or conditionally compatible but trigger an examination requirement. A footnote notes that the list of critical standard glass colours requiring that examination will be added in the coming revision.

For transparent PET-A bottles, PET-A and rPET are valuable materials, while PET-G, EVOH and PA layers, PVOH layers that are not water-soluble in an 80 °C hot wash, and other non-PET polymer layers are incompatibilities. Colouring with carbon-black based pigments requires examination even when used only in inner layers. Direct printing, apart from production codes, best-before dates and UFI codes, counts as an incompatibility. That single line captures the logic of the standard: what matters is not theoretical recyclability but what can actually be recovered from the washed and ground PET stream.

For paper, board and corrugated packaging the reference application is corrugated base paper. Fibre material with the usual paper industry additives, starch-based adhesive and mineral pigment coatings including their binders count as valuable material, provided the coating has no sealing function and does not act as a water vapour, oxygen or grease barrier. Bituminous, oiled and wax or paraffin papers are incompatibilities, as is direct printing using substances covered by the EuPIA charter on raw material selection and exclusion for printing inks.

For adhesives the standard refers to the EPRC scorecard: hot-melt applications meeting its criteria are acceptable, while those that do not require examination. Fully varnished surfaces also require examination, except clear protective varnishes up to 5 micrometres and inside varnishing of bags, pouches and carrier bags where the paper grammage is at least 100 g/m².

When missing infrastructure sets the result to zero

In practice the fourth criterion is the hardest filter. Drawing on a UBA survey, Annex 3.3 sets the thresholds: where the degree of application for a packaging category is below 80 per cent, individual evidence of recycling infrastructure is recommended; where it falls below 20 per cent, such evidence is mandatory for any result above zero per cent.

The list is instructive. Categories with a zero per cent degree of application, and therefore mandatory individual evidence, include flexible PET, XPS, EPS, other rigid plastics such as PVC and PC, other flexible plastics, biodegradable plastics, wood and cork, natural and synthetic textile fibres, and clay, stone, ceramics and porcelain. Mandatory evidence also applies to rigid PET thermoforms and other rigid PET packaging at 13 to 62 per cent. Evidence is recommended for the PolyAl fraction of liquid cartons at 23 to 36 per cent, for predominantly paper-based composites at 52 to 57 per cent, for flexible PE at 50 per cent, flexible PP at 27 per cent and rigid PS at 62 per cent.

The evidence itself is demanding. Companies must show that the recovery route genuinely delivers high-quality recycling in the sense of the standard, and prove with weighbridge tickets that at least the equivalent of their participation volume of system-derived packaging waste was delivered to that route during the reporting year.

In the worked example in the annex, a producer placing 600 tonnes of clear PET-A trays per year on the market must document deliveries of at least 2,000 tonnes under fraction number 328-2, which corresponds to a maximum tray equivalent of 600 tonnes. Systems must document all of this per obligated producer and packaging type, with EAN, GTIN or internal article number level allocation.

What this means beyond Germany

Formally the minimum standard is a German instrument applying to packaging subject to system participation on the German market. Its practical reach is wider. Anyone exporting packaged goods to Germany is already affected through participation fees: the law deliberately prescribes no fixed surcharges or discounts, but the systems have to create incentives within this uniform framework. Anyone preparing for the 2030 PPWR requirement gets a working preview, translated into numbers, of how the “at least 70 per cent recyclable” test is likely to be applied.

Two lessons stand out. First, a zero per cent result is rarely a verdict on a material class; it usually follows from one design decision, such as a PA barrier layer, a non-removable direct print or a lead-bearing glass component. These are typically substitutable, and substitution almost always costs less than losing market access after 2030. Second, the decisive question is settled not at the design desk but in the sorting plant and the recycling line.

The infrastructure list shows precisely which material streams cannot be fixed by good design alone, because the recovery capacity simply is not there. That is a live issue for extended producer responsibility schemes across the EU, which under the PPWR must modulate fees according to recyclability performance: modulation is only as meaningful as the sorting and recycling capacity behind it.

Frequently asked questions about the recyclability minimum standard

What exactly does the minimum standard measure?

It measures the share by weight of a packaging unit that can actually be recovered as valuable material through sorting and recycling. The calculation subtracts design-related losses from the valuable material content and divides the result by the total weight of the object of measurement. The output is a single percentage, not a grade or a score.

When does a packaging unit score zero per cent?

Whenever a single design parameter in its category table is classified as an incompatibility, for example lead-bearing glass, a PA barrier layer or a non-permitted direct print. The result is also zero where the category requires individual evidence of an existing recycling infrastructure and the company cannot provide it.

What data is needed to run the calculation?

No complex laboratory work is required. The material, the design parameters such as material combinations and barrier coatings, and their weights are sufficient. Separate examination applies only to parameters that Annex 2 explicitly flags as requiring it, and those flags are the exception rather than the rule.

How does the minimum standard relate to the PPWR?

From 2030 the PPWR allows packaging on the market only if it is at least 70 per cent recyclable. Until the European delegated acts apply, German rules on the ecological modulation of participation fees must be based on the minimum standard, giving it a genuine regulatory role throughout the transitional period.

Which packaging does the 2026 edition cover?

The edition published on 31 August 2026 applies to packaging subject to system participation that is placed on the German market in the following calendar year, 2027. Under the VerpackDG, the ZSVR must publish a new edition every year by 1 September, in agreement with the Umweltbundesamt.

Why should companies outside Germany care?

Exporters placing packaged goods on the German market feel the result through participation fees, since the systems must create incentives within this uniform framework. Beyond that, the calculation works as an early indicator of whether a packaging design will meet the EU-wide 2030 recyclability requirement.

Source:

The 2026 edition of the minimum standard and the accompanying statement are available on the ZSVR website.