Recyclability by Design 2026: what RECOUP’s updated guide tells packaging designers – and the rest of us

On 3 November 2026, the UK’s RECOUP published Recyclability by Design 2026 (version 12.0), a guide that has been one of the most widely cited design manuals on plastic packaging recyclability for twenty years. The new edition does not overturn earlier rules, but it places them in a new context: in the United Kingdom, from 2026 the recyclability of packaging directly affects the fees producers pay. In this analysis we look at what the document says, where it could still be sharpened, and what it means for the Hungarian and EU markets.

In short: Recyclability by Design 2026 is RECOUP’s updated, practical design guide for PET, HDPE and PP packaging, setting out material by material which colours, labels, closures, seals and barrier layers are compatible with today’s mechanical recycling. The key message of the new edition is that even in the era of the UK RAM assessment and modulated fees, design guidelines remain the starting point.

Twenty years, twelfth edition: what is the RECOUP guide?

RECOUP (RECycling Of Used Plastics) is a UK charity founded in 1990 that brings together the whole plastics recycling value chain, from collection through sorting to reprocessing. Its Recyclability by Design publication has been updated regularly for two decades; the 2026 release is the twelfth version.

The guide is aimed primarily at packaging designers and specifiers, but it is equally relevant to buyers, brand owners and retailers. The document stresses that it covers design for mechanical recycling only, not a full sustainability assessment of packaging. The guiding principle is “fitness for purpose”: improving recyclability must not compromise product safety, functionality or consumer acceptance.

The structure is easy to follow. General guidelines (colour, labels, adhesives, closures, residues, material identification) are followed by material-specific chapters on PET, HDPE and PP, each with a three-column matrix: compatible for recycling in most applications, may be suitable in some applications, and not suitable for recycling. Where general and material-specific guidance appear to conflict, the material-specific rule takes precedence.

RAM and modulated fees: the new context of Recyclability by Design 2026

The most significant new element of the 2026 edition is not a single material rule but its account of the regulatory landscape. The UK’s Recyclability Assessment Methodology (RAM) assesses packaging placed on the market in 2025 and reported as household waste, and modulated fees are applied accordingly from 2026. Packaging is rated green, amber or red: green indicates a recognised route through collection, sorting and recycling, and therefore attracts lower fees.

RECOUP draws a clear line between the two tools. It describes the RAM as an instrument for charging fees – important, but at this stage far from a complete and definitive guide to recycling. Recyclability by Design, by contrast, is built on feedback from recyclers and end markets, and describes what works today with widely available technology – not what might be possible with emerging, state-of-the-art equipment.

This distinction matters. Fee modulation inevitably simplifies, sorting packaging into categories where reality is a gradient. A design guide shows why a pack ends up in the red category and what needs to change to move it to green. RECOUP’s message to producers is clear: those who design to existing guidelines start from a stronger position in the fee system.

The fundamentals: density, colour, labels, closures

The general guidelines start from the physical reality of sorting and reprocessing. Four areas stand out.

Density. A key step in mechanical reprocessing is sink/float separation, where materials lighter than water float and heavier ones sink. If a pack combines several polymers, they need different densities. For PET bottles, non-PET components (closures, labels) should therefore be below 1 g/cm³, while for HDPE and PP packaging incompatible components should be above 1 g/cm³. According to the appendix, a difference of at least about 0.05 g/cm³ from water is needed for reliable sink/float behaviour, and just 4% pigment can raise a polymer’s density by around 0.03 g/cm³.

Colour. Unpigmented polymer has the highest value and the widest range of end uses. Dark, heavily pigmented plastic – especially plastic coloured with carbon black – is also “invisible” to near-infrared (NIR) sensors, which identify polymers from reflected radiation. Carbon black body colour is therefore listed as not suitable in all three material matrices.

Labels and adhesives. A sleeve made from a different polymer should cover no more than 40% of a bottle’s surface, and on pots, tubs and trays a label should cover no more than 60% of the surface presented for sorting – otherwise the machine “sees” the label rather than the pack. Preferred adhesives release in water at 60–80°C or can be removed in alkaline washing. Paper labels are not ideal, as fibres can carry over into the recyclate and cause surface defects and pinholes in blow moulding; metallised and foil labels should be avoided.

Closures. Metal caps can trigger metal detectors on sorting lines, catalyse oxidation and block injection nozzles in reprocessing, and in caustic washing aluminium residues turn into aluminium hydroxide, which remains as a contaminant in the recyclate. Crown caps are acceptable if they detach completely on opening and cannot be pushed back into the container.

The guide also gives indicative residue targets for non-viscous (water-like) products: below 10% for 50–99 ml packs, below 5% for 100–499 ml and below 2% above 500 ml. This is notable because it treats emptiability as a design issue: wide necks, packs that can stand inverted, non-stick additives.

On material identification codes, the guide takes a pragmatic line: they are voluntary in Europe; if used, Commission Decision 97/129/EC should be followed and the code moulded into the base rather than printed on a label. With automated sorting, however, the code has become less important to recyclers – while consumer confusion persists, as we showed in our article on the packaging messaging crisis.

PET: the most sensitive stream, from PVC to EVOH

PET is the most valuable and the most sensitive plastic stream, and the guide gives it the most detailed chapter. The biggest enemy is PVC: its density overlaps with PET, so it cannot be removed by flotation, and at PET’s processing temperature of 250–260°C it decomposes and releases hydrochloric acid. Even 50–200 ppm of PVC measurably degrades the chemical and physical properties of recycled PET and can render large batches useless. PVC closures, liners, labels, sleeves and safety seals should therefore be avoided entirely on PET packaging.

PLA is similarly problematic: it is also heavier than water, causes haze in PET even at low levels, and melts in the dryer. EVOH barriers cause haze, discolouration and loss of mechanical properties at residual levels of 500 ppm and above, so the guide does not currently recommend EVOH with PET. Titanium dioxide (TiO₂) opacifier causes breakages in fibre production – and a large share of recycled PET goes into fibre.

The PET bottle matrix lists clear, light blue and light tints as compatible, dark blue, dark green and brown as may be suitable, and opaque or solid colours as not suitable. PP and HDPE caps are compatible; steel, aluminium, PS, PVC and thermoset caps are not. Silicone valves get special attention: conventional silicone above 1 g/cm³ cannot be separated from PET, so manufacturers have developed lower-density versions. The guide openly notes that this may shift the problem from the PET stream to the polyolefin stream.

Given demand for rPET, none of this is theoretical: as we saw with Asahi Beverages’ switch to 100% rPET bottles, major beverage companies rely on food-grade recycled feedstock, which can only be produced from clean, well-designed input.

PET trays have their own matrix. Clear, uncoloured bodies are compatible, NIR-detectable colours may be suitable, carbon black is not. Trays with PE seal layers, EVOH or PA barriers are not suitable. A footnote sets out an important principle: no additive or process should generate non-intentionally added substances (NIAS), which would contaminate food-grade recycled content.

HDPE and PP: two floating polymers sharing a stream

HDPE and PP are both lighter than water, so flotation cannot separate them. The guide therefore recommends a 5% limit in both directions: no more than 5% PP in the HDPE stream and no more than 5% PE in the PP stream. The reasoning is material science: PP melts at 160–170°C, higher than HDPE at around 130°C, so it does not disperse well in HDPE recyclate and pushes it towards lower-value applications. The PP blend is somewhat more tolerant the other way round.

The HDPE chapter also contains several lesser-known but practically important rules:

• HDPE density, including fillers such as calcium carbonate or talc, should stay at or below 0.995 g/cm³, otherwise the pack sinks in the float tank;
• EVOH barriers are tolerated at low levels, PA (including MXD6) may be suitable, PVDC is not suitable;
• HDPE containers for mineral-oil-based products (such as motor oil) are generally not mechanically recyclable, because the oil migrates into the plastic and is not removed by washing;
• odour issues from milk bottles can be managed with a hot wash stage;
• PP or LDPE attachments (handles, spouts) should ideally stay below 5% of total bottle weight.

The PP chapter follows the same logic: unpigmented PP is more valuable, clarified PP is acceptable where compatible with recyclate end uses, and PVC components cause discolouration and odour.

Trays, tubs and films: where uncertainty is greatest

The chapter on packaging beyond bottles contains several points that directly affect day-to-day sorting operations. Injection-moulded HDPE tubs have different flow properties from blow-moulded bottles, so the two should not be mixed, as this reduces the value of the blend. Peel-off aluminium lids are acceptable in principle on PE and PP tubs, provided the adhesive stays with the lid. Product residue in yoghurt pots, meanwhile, can weigh as much as the pot itself, hurting both washing and yield.

Multilayer PET/PE trays (for example for processed meat) are one of the main problems in the PET tray stream. RECOUP steers producers towards mono-material PET trays, while fairly acknowledging that the longer shelf life of multilayer structures may in some cases offer a greater environmental benefit than recyclability.

For films, the guide refers to European RecyClass and CEFLEX guidelines and notes that mandatory kerbside collection of plastic films and flexible packaging in England under Simpler Recycling, originally planned for March 2027, has been deferred to April 2030. We covered the challenges of flexible plastics recycling in detail in our article on the InFACT project.

According to data in the document, UK household plastic packaging collection grew from a low base in 2003 and has hovered around 600,000 tonnes a year since 2021, dominated by bottles, followed by pots, tubs and trays, with film still a small share. From October 2027, the UK Deposit Return Scheme (DRS) will move in-scope PET drinks bottles out of conventional household collections.

Where the guide could still be sharpened

The strength of Recyclability by Design is that it is built on recyclers’ experience and does not promise more than today’s technology delivers. In a few places, however, it is worth reading critically.

Sleeve thresholds are not uniform. The general guidelines set a 40% maximum for a different-polymer sleeve on bottles, whereas the PET bottle matrix treats PE, PP, OPP and foamed PET sleeves as compatible up to 60% coverage and may be suitable above 60%. Since the material-specific rule takes precedence, the practical reading is more lenient – but in a fee-modulation environment this dual standard could cause confusion.

Solutions can shift problems. The low-density silicone valve is a good example of how improving one stream can harm another. The guide says so openly, which is to its credit, but offers no concrete recommendation on how the polyolefin stream should handle the silicone that ends up there.

Mechanical recycling only. The document deliberately does not cover chemical recycling. This is consistent with its “widely available technology today” principle, but it means questions about the future of multilayer films and trays must be answered elsewhere.

UK focus. Some rules are tailored to the UK market; for example, LDPE caps on PET bottles appear in the compatible column with a “Europe only” note. The design principles largely align with European RecyClass and North American APR guidelines – the latter now supported by APR’s new digital assessment platform – but an EU producer should follow all three in parallel.

What does this mean for Hungary?

Although RECOUP’s guide is a UK document, it carries direct messages for the Hungarian market.

PPWR pushes in the same direction. Under the EU Packaging and Packaging Waste Regulation (PPWR), from 2030 all packaging placed on the market must meet Design for Recycling criteria, and recyclability performance grades will also underpin the modulation of producer responsibility fees. The UK RAM is therefore a preview of what happens when design decisions become directly measurable in money.

The yellow bin now holds trays and non-beverage bottles. Since 2024 most single-use PET drinks bottles in Hungary have been collected through the deposit return system, so the PET fraction in separate household collection has shifted towards trays, pots and household or cosmetic bottles – exactly the packaging covered by RECOUP’s PET tray matrix: carbon black, PE seal layers, non-removable labels.

A black tray stays black in the sorting plant. NIR-based optical sorters in Hungarian sorting plants also struggle with carbon black pigment: such packaging typically does not reach the polymer fractions and is handled with sorting residues instead. On the design side, this is a problem that a single pigment change can solve.

Material choice is not everything – consumers matter too. RECOUP also sets out what consumers should do: remove film, paper and foil lids and empty the pack. This is worth reading alongside our recent analysis of lightweight packaging, which found that consumers are more likely to put thin, light packaging in mixed waste – meaning even the best design only pays off if the pack actually reaches the sorting line.

Professional summary

Recyclability by Design 2026 is not a revolutionary document, nor does it try to be. Its strength lies in having said the same thing consistently for two decades: packaging recyclability is decided at the design stage, and decisions must be grounded in the physical reality of the sorting line, the float tank and the extruder. The added value of the new edition is that it ties this knowledge to the fee system: producers now have a financial as well as an environmental reason to align closures, labels and colours with recyclers.

For Hungarian and EU stakeholders, the guide can also serve as a practical checklist for PPWR preparation. Those who review their packaging portfolio against RECOUP’s matrices today will, in 2030, be looking back on their own earlier decisions rather than on the regulation.

Recyclability by Design 2026 – frequently asked questions

What is Recyclability by Design 2026?

Recyclability by Design 2026 is the updated version 12.0 of RECOUP’s design guide on the recyclability of plastic packaging. Material by material – PET, HDPE and PP – it shows which colours, labels, closures, lidding films, barrier layers and adhesives are compatible with today’s mechanical recycling, and which cause serious problems in sorting or reprocessing.

What is the difference between the UK RAM and the RECOUP guide?

The RAM is a fee-setting tool, while the RECOUP guide is a design resource. The UK Recyclability Assessment Methodology rates packaging green, amber or red, and from 2026 this affects the modulated fees producers pay. RECOUP stresses that the RAM does not replace design guidelines, which are based on recyclers’ practice and widely available technology.

Why is carbon black plastic packaging a problem?

Because optical sorting machines cannot detect it. NIR sensors identify polymers from reflected near-infrared radiation, but carbon black pigment absorbs that radiation. The guide therefore lists carbon black body colour as not suitable in the PET, HDPE and PP matrices, and for PET trays accepts only colours that NIR equipment can detect.

How much label coverage does the guide accept?

On bottles, the general guidance says a sleeve made from a different polymer should cover no more than 40% of the surface, while on pots, tubs and trays a label should cover no more than 60% of the surface presented for sorting. The aim is for sorting equipment to identify the pack’s actual material rather than the label, avoiding misdirection to the wrong fraction.

What does the guide mean for EU and Hungarian producers?

It is a useful preparation tool for PPWR requirements. From 2030 the EU regulation requires all packaging to be designed for recycling, and recyclability performance grades will also underpin the modulation of producer responsibility fees. RECOUP’s material matrices already show which closure, label and colour choices cause problems, making them a solid starting point for a packaging portfolio review.

🔗 Official sources and references: 👉

• RECOUP (3 November 2026): RECOUP Launches Recyclability by Design 2026 – https://www.recoup.org/2026/11/03/recoup-launches-recyclability-by-design-2026/
• RECOUP: Recyclability by Design 2026 (v12.0) – download: https://www.recoup.org/research-and-reports/recoup-recyclability-by-design-2026/
• RecyClass – Design for Recycling Guidelines: https://recyclass.eu/recyclability/design-for-recycling-guidelines/

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