PET Tray Recycling: 824,000 Tonnes of Waste, 18% Recycled – and a 454,000-Tonne Capacity Gap

PET trays are everywhere in the chilled aisle: cold cuts, cheese, minced meat, cherry tomatoes, ready meals. The material sounds reassuring, because the PET bottle is one of Europe’s best-recovered packaging formats. The tray is a different story. According to a newly published German–European study, PET tray recycling currently works at roughly a third of the rate achieved by plastic packaging overall — even though the technology to fix it already exists and is running commercially. The gap is not in the lab. It is in the sorting plants, in the contracts, and in packaging design.

Here is what the study measured, where the chain breaks, and what it means for anyone who designs, produces, collects or recycles packaging.

What is this study, and who produced it?

The research was initiated by Germany’s Forum Rezyklat, with the participation of IK Industrievereinigung Kunststoffverpackungen, the German plastics packaging industry association. Three organisations carried out the work: the cyclos–HTP Institute, packaging market researcher GVM, and the Fraunhofer Institute for Building Physics (IBP). The final report is titled “PET-Schalenrecycling: Status quo, Herausforderungen und Zukunftsszenarien – Phase 1” — PET tray recycling: status quo, challenges and future scenarios, Phase 1. It was completed in July 2026 and published on 9 September 2026. It is available free of charge among Forum Rezyklat’s technical publications.

Phase 1 deliberately avoids prescribing solutions. It takes stock instead: how much PET tray material arises, where it goes, what technology is available, and how wide the gap is between regulatory expectation and industrial reality. Phase 2 has already been commissioned — more on that at the end.

824,000 tonnes a year across the EU

According to GVM’s market research, 823.9 kt of semi-rigid PET packaging was placed on the EU-27 market in 2024:

• Germany: 144.0 kt — Europe’s largest single market
• Italy: 121.6 kt
• France: 116.7 kt
• Spain: 96.2 kt
• Poland: 60.3 kt
• Netherlands: 36.5 kt
• Remaining EU member states combined: 248.6 kt (about 30% of the total)

Average EU consumption is 1.84 kg per capita per year. Italy tops the list at 2.06 kg, followed by the Netherlands at 2.04 kg; Poland is lowest at 1.64 kg. Germany leads on absolute volume but sits below the EU average per person at 1.73 kg.

The vast majority is food-related: roughly 730 kt across the EU and 121 kt in Germany. Within the German market, 71% is food trays, 13% is cups and other semi-rigid food packaging, and 16% is non-food — typically blisters for household goods, toys and electronics.

There is one genuinely encouraging trend in the numbers. Layer structures are moving in the right direction: about two-thirds of trays are now monolayer PET, with only around a third being multilayer composites. That matters, because mechanical recycling of a monolayer tray is significantly more straightforward.

Why only 18% gets recycled

This is the study’s most uncomfortable figure. In Germany, 66.3% of household-generated PET trays do reach separate collection — the yellow bag or yellow bin. That is a reasonable capture rate. What happens next is not: 73.6% of collected trays are rejected during sorting and typically sent to energy recovery, which means incineration.

The end result is a material recycling rate of 17.5% for PET trays (the press release rounds this to 18%). For comparison, plastic packaging overall achieved 52.2% in 2023. The tray is not lost because citizens fail to sort it. It is lost because the chain after collection was never built for it.

The study identifies three causes:

1. The system was built around bottles. Sorting fractions and recycling plants specialise in PET bottles. Trays are treated as a residue of bottle sorting — screened out negatively rather than recovered through targeted, positive sorting.
2. Multilayer structures. 34.3% of German trays are multilayer, which are hard or impossible to process mechanically.
3. The volume is too small. PET trays account for only around 5% of total plastic packaging volume. Few operators will reconfigure an entire process line for that share, so the commercial incentive is missing.

Worth adding: flexible PET (films and pouches) fares even worse and is essentially all incinerated in Germany. The study notes that 41.5% of PET films could technically be recycled together with trays — they simply are not sorted that way.

The technology exists — it just isn’t installed

One of the study’s central findings is that no technological breakthrough is being waited on. Mechanical PET recycling sits at TRL 9: mature, industrial technology.

The bottleneck is sorting. Conventional near-infrared (NIR) detection cannot reliably separate a PET bottle from a PET tray on its own — the material is identical and the reference spectra are similar. Some cases are particularly awkward, such as a transparent PET tray with a polyolefin lidding film in its closed state: the sensor reads something misleading from both the top and the bottom.

The answer is imaging sensor technology with AI-based object recognition, supplemented by 3D geometry detection. This now qualifies as best available technique and is already running in some sorting plants specifically to separate PET trays from PET bottles. Its uptake, however, remains limited.

This is where the study makes its sharpest point: without reliable offtake routes and a genuine economic advantage from better sorting, there is no investment incentive and the required capacity does not get built. Retrofitting an existing plant is technically feasible, but always demands a case-by-case techno-economic assessment, because the necessary space was often not reserved in the original design. For that reason the study concludes that secondary sorting plants will remain indispensable in the medium term — they are the bridge between conventional sorting and tray-to-tray recycling.

Where the chain breaks: two different specifications for the same material

This is the study’s real discovery, and the part almost nobody outside the industry sees.

System-level sorting specifications — set by producer responsibility organisations — typically require 75–90% PET tray content in the relevant fraction. Recycling plants’ intake specifications, by contrast, demand 85% to 95% or higher. And more pointedly: none of the plants interviewed accepts PET bottles at all — they are removed during pre-sorting.

So the sorter can meet its contract while the material still bounces at the recycler’s gate. This is not an individual failure but a structural gap at the interface between sorting and recycling. The study therefore recommends harmonising specifications across Europe, and separating PET food packaging from PET non-food packaging into distinct sorting fractions.

Four plants in Europe — and a 454,000-tonne hole

The research examined four tray-to-tray operations in detail:

• CIRREC (Duiven, Netherlands) — operating since 2018, around 60,000 t/year, producing rPET pellets for high-grade applications
• Sulayr (Spain) — active since 2009, two plants with a combined 45,000–60,000 t/year, designed for multilayer PET with integrated delamination; yields rLDPE alongside rPET
• REPETCO (Albacete, Spain) — operating since 2023, around 100,000 t/year, delaminating multilayer PET/PE food packaging into rPET pellets and rPE
• Veolia UK (near Shrewsbury, England) — under construction, around 80,000 t/year planned, of which a limited share is expected for trays; not counted in the assessment

Total European capacity available today comes to 235,000–250,000 tonnes per year.

Now the arithmetic. Under Article 3(39) of the PPWR, the EU packaging regulation, “recycled at scale” (RaS) requires that at least 55% of a given packaging category is genuinely recycled. For PET thermoforms viewed in isolation, that means producing 452 kt of rPET flakes. At an ambitious average yield of 65%, this requires 697 kt of PET tray input per year.

697 kt needed, 242.5 kt available. Put differently: if PET tray recycling ran at full tilt from tomorrow, Europe’s existing plants could handle barely a third of the material the regulation implies. The shortfall is 454.5 kt per year — roughly 65% of what is required, and equivalent to the throughput of about six to eight large-scale plants, according to the press release. The deadline is 2035.

The PPWR sets two separate conditions, and they are easy to conflate

An important clarification from the study, because these two are routinely blurred in practice:

Recyclability (Design for Recycling) is a design question. Under the PPWR it will determine whether a pack may be placed on the market at all, and how high the producer responsibility fee will be. The milestones are 2030 and 2038.

Recycling at Scale is an infrastructure question: whether enough industrial capacity exists to actually process the material. From 2035 it becomes an additional condition in assessing recyclability.

The two are met — or missed — independently of each other. A pack can be flawlessly recyclable on paper while lacking sufficient industrial capacity behind it, and vice versa. Minimum recycled content requirements (PPWR Article 7) run to their own timetable, with 2030 and 2040 targets.

The study identifies the absence of European harmonisation as the biggest deficit in the DfR field: a single EU-wide standard is needed, built on objective criteria and best available technique. As a steering instrument it names eco-modulation — linking producer responsibility fees to recyclability, sortability and recycled content use.

What packaging designers can act on today

The researchers asked three PET tray recyclers which packaging attributes degrade recyclate quality. Some answers are surprising and diverge from what the guidelines imply:

• Problematic: PET-G components, direct printing on the tray, and bleeding inks. One interviewee noted that bleeding inks appear more often on trays than on bottles and raise process costs through the additional water treatment required.
• Less problematic than assumed: two of the three recyclers did not consider EVOH and PA barrier layers disruptive, even though guidelines generally classify them as incompatible. Slip agents and clarifiers were likewise judged harmless — which matters, since GVM’s market research indicates around 70% of trays contain a slip agent.
• Laminated or coextruded? All three recyclers rated adhesive-laminated PET/PE trays as unproblematic, while coextruded PET/PE structures are less favoured for processing reasons. Peel layers were also judged harmless.

From this the study derives so-called no-regret recommendations — measures that cannot turn out to be the wrong call:

• avoid direct printing on the tray
• use polyolefin-based sealing and lidding films
• use small-area wash-off labels

Two concrete reference designs are presented. The first: a transparent PET tray with a printed PE-based lidding film and a printed PE-based back label. The second: a transparent PET tray with an unprinted PET lidding film, with the graphics moved onto a banderole that the consumer must remove to use the product — making it a separate component.

On lidding film material the authors take a clear position: they prefer polyolefin films, because their lower density allows easy separation from PET flakes by float-sink processing, and the recovered PO fraction can itself be recycled.

The study is also honest about a limit. Mono-material design hits a wall in certain applications where high oxygen, moisture or aroma barrier performance is required. Delamination is a solution in principle, but is not fully efficient in practice, adds a process step, and recyclate from multilayer trays typically falls short of monolayer quality.

Chemical recycling: a complement, not a replacement

Fraunhofer IBP reviewed alternative processes separately, and the conclusion is level-headed: these will not replace mechanical recycling but complement it in targeted ways.

The logic is simple. For clean, homogeneous, single-polymer streams, mechanical recycling remains the first choice because it is both economically and energetically more favourable. Chemical routes earn their place where streams are contaminated or complex.

The study also draws a sharp terminological line. PET depolymerisation — hydrolysis, enzymatic hydrolysis, solvolysis — recovers monomers such as terephthalic acid and ethylene glycol, and belongs in a different category from pyrolysis or gasification. Pyrolysis plants are already running commercially, but PET is a poor input because of its heteroatoms and typically yields oils rather than high-value monomers. Most depolymerisation plants are not yet commercial, though they sit at high TRL levels in demonstration and pilot stages, with both start-ups and major players investing: LyondellBasell, BASF, Eastman and SK Chemicals.

The main barriers to scaling: the low price of virgin PET, regulatory uncertainty — particularly around food contact — and integration into existing value chains, such as connecting recovered monomers to a nearby PET polymerisation plant.

What this means for the Hungarian market

The study places Hungary in its “rest of EU” category and reports no country-specific Hungarian figures. Its logic, however, transfers directly.

Hungary’s system was also built around bottles: the deposit return scheme targets PET bottles, while trays end up in separate waste collection and then move through the same sorting chain that is optimised primarily for bottles. The PPWR is not national legislation, though — recyclability requirements, mandatory recycled content and Recycling at Scale will apply identically in every member state. And tray-to-tray capacity today sits in the Netherlands, in Spain, and soon in the UK, not in Central Europe.

Two practical consequences follow. Anyone designing or placing food packaging on the Hungarian market should treat the no-regret recommendations — dropping direct printing, switching to PO lidding film, using small wash-off labels — as rational moves right now, because they will not be the wrong decision under any future regulatory scenario. And for anyone working in collection or sorting, AI-based object recognition and the separation of PET food and non-food fractions are not a 2035 topic: plant design and investment decisions take years of lead time, which is precisely what the study flags as the critical path.

What comes in Phase 2?

Forum Rezyklat has already commissioned the second phase. It will develop technology scenarios for 2030 and 2040 in conceptual simulations, factoring in the Recycling at Scale requirement. Each scenario will come with material balances and robust cost estimates: investment costs, operating costs, potential revenue from secondary raw materials, and — most notably — the cost of non-compliance if regulatory requirements are missed.

The aim is to make the economic viability of different implementation strategies comparable, and to derive concrete measure packages: DfR requirements, a reorganisation of sorting specifications (particularly for category 8 under the PPWR), contracting recommendations between system operators, recyclers and converters, and finally the investment needs of each actor.

The core message of Phase 1 is already clear, and worth quoting almost verbatim: establishing a functioning PET tray-to-tray loop is less a question of basic technical feasibility than of the interplay between regulatory impulse, economic incentive and technological refinement. The technology is there. The system is not.

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PET Tray Recycling – Frequently Asked Questions

What is the current recycling rate for PET trays?

Germany reaches 17.5%, which the press release rounds to 18%. That falls far short of the 52.2% average for plastic packaging in 2023. Collection is not the bottleneck: 66.3% of household trays enter separate collection, but 73.6% of the collected volume is rejected during sorting and typically incinerated.

Why are PET trays harder to recycle than PET bottles?

Because the system was built around bottles. Sorting plants and recyclers specialise in bottles and treat trays as a residue of bottle sorting. Near-infrared detection alone cannot reliably separate the two, since the material is identical. Add the multilayer structures that make up 34.3% of German trays, plus a small market volume.

How much capacity is Europe missing by 2035?

Roughly 454,500 tonnes per year, equivalent to six to eight large-scale plants. The PPWR’s Recycling at Scale requirement demands at least 55% recycling, which needs 697,000 tonnes of annual input capacity. Only 235,000 to 250,000 tonnes are available in Europe today, largely in Dutch and Spanish plants.

What are the key packaging design recommendations?

Three so-called no-regret measures: drop direct printing on the tray, use polyolefin-based sealing or lidding films, and use small-area wash-off labels. The recyclers interviewed rated PET-G components and bleeding inks as most problematic, while all three judged adhesive-laminated PET/PE trays to be unproblematic.

Will chemical recycling solve the problem?

It will not replace mechanical recycling but complement it in targeted ways. For clean, homogeneous streams the mechanical route remains the first choice, being more favourable both economically and energetically. Most depolymerisation plants are not yet commercial. The main scaling barriers are cheap virgin PET and regulatory uncertainty around food contact.

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Sources:

Forum Rezyklat press release (9 September 2026) and the final report “PET-Schalenrecycling: Status quo, Herausforderungen und Zukunftsszenarien – Phase 1” (cyclos–HTP, GVM, Fraunhofer IBP, 17 July 2026). The full study is available free of charge among Forum Rezyklat’s technical publications.