Under Article 3(24) PPWR, packaging is considered composite when it contains at least two different materials that cannot be separated by hand and form one inseparable unit. This classification is especially relevant for recycling and sustainability endeavours.
This means that the following do not automatically make packaging composite:
- Adhesives
- Labels
- Paints and printing inks
- Varnishes and coatings
The key factor remains the structural materials that make up the packaging itself. Companies should therefore continue to assess their packaging carefully, but the Commission’s clarification provides greater certainty when applying the PPWR.
Do you have questions about your packaging or recycling obligations? Our trade-e-bility advisory team will be happy to provide you with a suitable quote.
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