Design for recycling means choosing a material and its additives so the finished article can still be sorted, washed and re-extruded into a usable polymer, and on the additive side the outcome comes down to 6 decisions. The same additive can be rated Design Preferred in one stream and make a package non-recyclable in another, so which decisions actually move the grade?
This page covers additives put into a virgin article and what they do to its recyclability. Additives added to a recyclate, restabilizers, compatibilizers, odour absorbers and chain extenders, are a separate job with different dosages, covered on the recycled-plastics formulation guide, because a restabilizer dose depends on how much antioxidant a bale already lost, not on what a virgin formulation puts in before the part is ever collected.
The 6 decisions are density, colour, degradability, contamination, heat history and restricted status, graded by the Association of Plastic Recyclers, RecyClass and the European PET Bottle Platform today, and by the European Commission from 2028. A master table grades the common additive families, a second gives the numeric criteria per package stream, a third lays out what EU law adds on top of the voluntary schemes, a 7-step sequence checks a formulation before production, and a final table shows how each claim is measured.
What Is Design for Recycling?#
Design for recycling is the practice of specifying a plastic article, including every additive in it, so that it survives collection, sorting, washing and re-extrusion and yields a polymer a converter will buy. Additives touch all four steps: density decides whether a part is kept or lost in sorting, colour decides whether a sorter can identify the polymer, degradable additives decide whether the stream stays usable, and thermal stability decides whether the polymer survives re-extrusion.
Every one of the 43 families of plastic additives touches at least one step, but design for recycling is graded against named schemes, not one global rulebook. The APR Design Guide, RecyClass and the EPBP publish their own per-package criteria, and from 1 January 2028 the European Commission adds a fourth, legally binding layer through PPWR delegated acts, with grades applying from 1 January 2030 at the earliest.
Design for recycling is not the same question as whether a polymer is technically recyclable in a laboratory sense: a polymer can survive ten extrusion cycles and still fail every scheme because its additive package sinks in the float-sink tank or absorbs the light a sorter uses to identify it. The grade tracks the additive package, not the base resin.
Who writes the rules: APR, RecyClass, EPBP and the PPWR#
Four bodies decide whether an additive is acceptable in a recycling stream: the Association of Plastic Recyclers in the United States, RecyClass and the European PET Bottle Platform in Europe, and, from 2028, the European Commission through the delegated acts of the Packaging and Packaging Waste Regulation. Each covers a different territory and grades a different scope, and only two of the four publish numeric thresholds that this page can cite.
- Association of Plastic Recyclers (APR): United States; voluntary Design Guide per package category (PP rigid coloured, PE flexible, PET rigid), with protocols O-S-01, SORT-S-01, PET-CG-01 and PET-P-12; in force today.
- RecyClass: European Union; equivalent guidelines for packaging, automotive and electrical and electronic equipment; in force, but its numeric thresholds are not cited on this page.
- European PET Bottle Platform (EPBP): European Union; design guidelines specific to PET bottles, covering barrier layers, tie layers and oxygen scavengers; in force today.
- European Commission (PPWR): European Union; binding design-for-recycling criteria by delegated act, due 1 January 2028, with grades applying from 1 January 2030 at the earliest.
Why the additive package, not the polymer, usually decides the grade#
A polypropylene tub and a polypropylene tub are the same polymer, but one is rated Design Preferred and the other is not recyclable, and the difference is almost always the additive load. The tub that fails usually carries enough mineral filler or barium sulfate to push its compound density above the APR's 1.0 g/cm3 non-recyclable cut, while a tub loaded with 20 to 40 wt% calcium carbonate, a normal filler loading, stays comfortably inside the Design Preferred band below 0.970 g/cm3.
The same logic applies outside rigid packaging: a halogen-free cable compound loaded with 160 to 185 phr of aluminium trihydrate (ATH) or magnesium hydroxide (MDH), about 60 wt%, can sit in the same non-recyclable density band even though the flame retardant is doing exactly what it was specified to do. The criteria in this guide are always read per stream, never as one global pass or fail.
How Additives Affect Recyclability: The 6 Design Decisions#
Additives affect plastic recyclability through 6 decisions: the density they add, the colour they give, whether they make the polymer degrade, how much non-target material they bring, whether they survive a second heat history, and whether they are restricted by law.
The table below summarises which additive families sit behind each decision, what typically fails, and the grading outcome the schemes attach to it.
| # | Decision | Additive families concerned | What goes wrong | Typical grading outcome |
|---|---|---|---|---|
| 1 | Density | Fillers, reinforcements, mineral flame retardants, barium sulfate | The part sinks in the float-sink step and is lost as waste | Requires Testing, then non-recyclable above the density cut |
| 2 | Colour | Colorants, carbon black, masterbatch | Near-infrared sorters cannot see the part | Fails APR SORT-S-01 below L* 40 |
| 3 | Degradability | Biodegradation and pro-oxidant additives | Fragments contaminate the stream | Renders the package non-recyclable |
| 4 | Contamination | Barrier additives, oxygen scavengers, compatibilizer tie layers | Non-target polymer ends up in the flake | Allowed only up to a stated wt% |
| 5 | Heat history | Antioxidants, pigments, reheat additives | Yellowing, gels and decomposition products in the second pass | Requires Testing |
| 6 | Restricted status | Heat stabilizers, plasticizers, flame retardants | The recyclate breaches a legal limit | The material is excluded from the loop |
Grades follow the APR Design Guide vocabulary; the legal outcomes follow EU law. Neither is a global standard; see the criteria per stream below.
1. Density: fillers and mineral additives against float-sink separation#
Density decides recyclability because polyolefin recycling lines separate material in water: what floats is polyethylene or polypropylene, and what sinks is waste. Fillers, reinforcing fibres, mineral flame retardants and dense colour concentrates push a compound's density toward or past the water line, because each is denser than the base polyolefin it is loaded into.
The APR quantifies the cut for rigid PP: below 0.970 g/cm3 Design Preferred, 0.970 to 1.0 g/cm3 Requires Testing, at or above 1.0 g/cm3 non-recyclable, with a second condition that the package also fails if less than 51 wt% floats under protocol O-S-01. For PE film, the APR tests once density approaches 0.996 g/cm3 and treats anything above 1.00 g/cm3 as material that sinks rather than floats. Ordinary loadings reach these bands: calcium carbonate at 20 to 40 wt% in PP, barium sulfate up to 70 wt% in PP and PS, and ATH or MDH at 160 to 185 phr, about 60 wt%, in halogen-free cable. Loading levels per mineral are compared on fillers for plastics; staying Design Preferred means choosing the lowest loading and the lowest-density mineral that still meets the target.
2. Colour: carbon black, dark pigments and near-infrared sorting#
Colour decides recyclability because sorting lines identify polymers by the near-infrared light they reflect, and carbon black absorbs that light instead of reflecting it. Near-infrared sorting struggles across the board with black and strongly coloured plastics, and clear plastics hold the highest scrap value because a sorter can identify them with the least ambiguity. Carbon black is the worst case: it absorbs near-infrared radiation almost completely, and the grades and particle sizes used in plastics are compared on carbon black in plastics, which prevents an NIR sorter from reading the package at all.
The APR quantifies the cut for rigid PP: Design Preferred if L* is above 40 and average NIR reflectance is above 10 %, and protocol SORT-S-01 fails a black or dark colour once L* drops below 40 or reflectance falls to 10 % or below. Two routes get a black package back into the sortable range: NIR-detectable black masterbatches, such as Ampacet's COTREP-certified REC-NIR-BLACK for PP and HDPE rigid packaging, and infrared-reflective inorganic black pigments that reflect near-infrared light instead of absorbing it. NIR-sortable black colorants are compared in detail on the carbon-black-free alternatives page. Tracer-based sorting, adding a fluorescent or rare-earth marker at about 100 ppm rather than changing the colour, is a separate route some converters use alongside an NIR-detectable black.
3. Degradable additives: the one class that disqualifies a package outright#
A degradable additive decides recyclability on its own: it is the only additive class the APR rates as rendering a polypropylene or polyethylene package non-recyclable, whatever the dosage. The APR extends the same non-recyclable rating to PLA, PHA, starch and natural fibres alongside biodegradation and pro-oxidant additives, because every one of them introduces material into the stream that does not behave like the target polymer once it degrades or fragments.
EU law goes further than a design guide for one specific mechanism: products made from oxo-degradable plastic have been banned in the EU since 3 July 2021 under Article 5 of Directive (EU) 2019/904, which defines oxo-degradable plastic in Article 3(3) as "plastic materials that include additives which, through oxidation, lead to the fragmentation of the plastic material into micro-fragments or to chemical decomposition." The ban covers all such products, not only single-use items. For packaging that is deliberately biodegradable rather than oxo-degradable, the Packaging and Packaging Waste Regulation adds a separate requirement under Article 9(3): it must itself be designed for material recycling by 12 February 2028. The evidence behind both routes is set out on biodegradation additives for plastics.
4. Barriers, scavengers and tie layers: the contamination budget#
Barrier additives decide recyclability because every gram of non-target polymer in the package becomes a contaminant in the flake, and the recycler bodies publish exactly how much of it they will accept. The families concerned are the barrier types compared on barrier additives for plastic packaging: EVOH, PA-MXD6, tie layers and passive mineral barriers, plus the oxygen scavengers that protect the product inside a PET bottle.
The published caps vary by structure. The APR allows EVOH at or below 10 wt% in PE film co-extruded with a PE-g-MAH tie layer above 0.1 wt% maleic anhydride, against a tighter 5 wt% cap for adhesive lamination. The EPBP caps PA-MXD6 at 5 wt% in clear PET bottles and 6 wt% in coloured or opaque ones (3-layer, no tie layers), and EVOH at 3 wt% in coloured bottles only, since EVOH is incompatible with clear PET recycling. A clear-PET oxygen scavenger must stay thermally stable for 5 loops with less than 0.1 % non-PET content under the EPBP guideline, and under the APR it must separately pass protocol PET-CG-01 after ageing per PET-P-12. The scavenger systems that meet these conditions are compared on oxygen scavengers for plastic packaging. Cross-polymer contamination carries a real cost: 5 % PP in recycled HDPE can cut slow-crack-growth resistance by up to 40 %.
5. Heat history: which additives survive the next extrusion#
Heat history decides recyclability because the additive package in a virgin article has to survive a second and a third extrusion, and most recyclate is never topped up with fresh stabilizer. Post-consumer and post-industrial recycled polyolefins are generally not re-dosed with antioxidant before reprocessing, so whatever stabilizer package the antioxidants for plastics grade of the virgin resin contains is what protects every pass after the first.
Two pigment findings and one antioxidant study set the numeric picture. The APR rates reheat additives in PET as Requires Testing because they can turn flake dark or yellow. Diarylide pigments decompose into monoazo species above about 200 °C, with a first thermogravimetric peak at 162 °C (Science Advances, 2025); all three pigments tested, plus 4 of 13 printed foils, were positive in miniaturised Ames tests after 30 minutes at 240 °C, with 2 positives confirmed in the full OECD 471 tests (Materials, 2025, Fraunhofer IVV and OFI). On the stabilizer side, Knoben, Vanhouttem, Wypkema and Subramanian (Materials 18:1640, 2025) dosed closed-loop recycled PP with 500 ppm primary and 1,000 ppm secondary antioxidant per cycle: Irgafos 168 rose from about 650 ppm at cycle 1 to more than 1,200 ppm at cycle 5, and the oxidative induction temperature at cycle 5 reached 257 °C with the antioxidant against 198 °C without it. The full set of yellowing and decomposition causes is set out on why plastics turn yellow or pink.
6. Restricted and legacy additives: the legal ceiling on the next loop#
A restricted additive decides recyclability twice: it limits what the article may contain today, and it sets the ceiling on what the recyclate made from that article may contain tomorrow. Lead stabilizers illustrate the pattern directly: REACH Annex XVII entry 63, introduced by Regulation (EU) 2023/923, sets lead in PVC articles below 0.1 % w/w from 29 November 2024, though recovered rigid PVC may still contain up to 1.5 % w/w in listed uses until 28 May 2033, and the parallel derogation that covered flexible PVC ended on 28 May 2025.
A similar dual ceiling applies to phthalate plasticizers: Annex XVII entry 51 limits DEHP, DBP, BBP and DIBP to 0.1 % in all articles since 7 July 2020, and the same limit governs what a recyclate made from an older, unrestricted article may legally contain. Wiesinger and colleagues at ETH Zurich (Environmental Science and Technology, 2024) tested 151 new PVC floorings on the Swiss market and found regulated chemicals above 0.1 wt%, mainly lead and DEHP, in 16 %, a pattern linked to the use of recycled PVC, while 29 % contained other ortho-phthalates above 0.1 wt%. The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 defines a "substance of concern" in Article 2(27) as one that negatively affects reuse and recycling, a definition the PPWR reuses.
Which Additives Are Design Preferred, Which Require Testing and Which Are Not Recyclable#
The APR Design Guide rates most workhorse additives as Design Preferred, puts a small group into Requires Testing and names only degradable additives as rendering a package non-recyclable. The Design Preferred lists are published per package category, PP rigid coloured, PE flexible film and PET rigid, not as one global list, so the table below states the category behind every rating rather than merging them into a single verdict.
| Additive family | Canonical group | APR or EPBP category | Grade | Condition that changes the grade | Decision |
|---|---|---|---|---|---|
| Impact modifiers | Modifiers, fillers and flame retardants | APR PP rigid | Design Preferred | At normal loading | 1 |
| Fillers | Modifiers, fillers and flame retardants | APR PP rigid; APR PE film | Design Preferred | Requires Testing from 0.970 g/cm3; non-recyclable at or above 1.0 g/cm3 (PP), above 0.996 g/cm3 (film) | 1 |
| Reinforcing fibers for plastics | Modifiers, fillers and flame retardants | Not rated by APR or EPBP | Not rated; judged by decision 1 | Loading pushes compound density toward the float-sink cut | 1 |
| Mineral flame retardants (ATH and MDH) | Modifiers, fillers and flame retardants | APR PP rigid (density mechanism) | Design Preferred at normal loading | Non-recyclable once loading (160-185 phr) pushes density to or above 1.0 g/cm3 | 1 |
| Blowing agents | Modifiers, fillers and flame retardants | APR PP rigid | Design Preferred | At normal loading | 1 |
| Biodegradation additives | Specialty and barrier additives | APR PP and PE | Renders the package non-recyclable | At any dosage | 3 |
| Barrier additives | Specialty and barrier additives | APR PE film | Design Preferred (conditional) | EVOH at or below 10 wt% with PE-g-MAH tie layer above 0.1 wt% MAH (co-extrusion); 5 wt% (adhesive lamination) | 4 |
| Oxygen scavengers | Specialty and barrier additives | APR PET | Requires Testing | Must pass protocol PET-CG-01 after ageing per PET-P-12 | 4 |
| IR absorbers and reheat additives | Specialty and barrier additives | APR PET | Requires Testing | Can turn flake dark or yellow | 5 |
| Tracer additives | Specialty and barrier additives | Not rated by APR or EPBP | Not rated; used to improve sortability | At about 100 ppm | 2 |
| PVC heat stabilizers | Stabilizers | Not rated by APR or EPBP | Not rated; governed by the legal limit | Lead capped below 0.1 % w/w since 29 Nov 2024 | 6 |
| UV stabilizers for plastics | Stabilizers | APR PP rigid; APR PE film | Design Preferred | At normal loading | 5 |
| Nucleating agents | Colorants and processing modifiers | APR PP rigid; APR PE film | Design Preferred | At normal loading | 5 |
| Colorants for plastics | Colorants and processing modifiers | APR PP rigid | Design Preferred (conditional) | Fails SORT-S-01 if L* below 40 or NIR reflectance at or below 10 % | 2 |
| Masterbatch | Colorants and processing modifiers | Not rated separately | Graded by its carrier pigment or filler | See decisions 1 and 2 | 1, 2 |
| Processing lubricants for plastics | Processing aids | APR PP rigid; APR PE film | Design Preferred | At normal loading | 5 |
| Polymer processing aids | Processing aids | APR PE film | Design Preferred | "Should be minimized" per APR | 5 |
| Slip additives for plastic film | Processing aids | APR PE film | Design Preferred | At normal loading | 5 |
| Antiblock additives | Processing aids | APR PE film | Design Preferred | At normal loading | 5 |
| Antistatic agents for plastics | Processing aids | APR PP rigid; APR PE film | Design Preferred | At normal loading | 5 |
| Antifog additives | Processing aids | APR PE film | Design Preferred | At normal loading | 5 |
| Compatibilizers for recycled plastics | Recycling-specific additives | Not rated by APR or EPBP | Not rated; becomes a legacy additive | In the next recycling loop | 6 |
A Design Preferred rating applies at normal loadings, and the same family fails once it crosses the density, colour or contamination threshold described in the 6 decisions above.
Design-for-Recycling Criteria by Package Stream#
The thresholds are set per stream, not per polymer family, because the sorting and washing equipment differs: rigid polypropylene, flexible polyethylene film and PET bottles each have their own density, colour and contamination limits. The table gathers every numeric criterion from the 6 decisions into one comparison, organised the way a converter checks a formulation, stream by stream.
| Stream | Body | Density criterion | Colour criterion | Contamination criterion | Additive class that fails it |
|---|---|---|---|---|---|
| PP rigid | APR | Below 0.970 g/cm3 Design Preferred; 0.970-1.0 g/cm3 Requires Testing; at or above 1.0 g/cm3 non-recyclable; also non-recyclable below 51 wt% float (O-S-01) | L* above 40 and NIR reflectance above 10 % Design Preferred; fails SORT-S-01 below L* 40 or reflectance at or below 10 % | Not published in this scheme for PP rigid | Fillers and mineral flame retardants above the density cut; carbon black and dark colorants; degradable additives |
| PE flexible film | APR | Testing required approaching 0.996 g/cm3; above 1.00 g/cm3 sinks and becomes waste | Not published as a separate PE film threshold | EVOH at or below 10 wt% with PE-g-MAH tie layer above 0.1 wt% MAH (co-extrusion); at or below 5 wt% (adhesive lamination) | Barrier layers above the cap; degradable additives |
| PET rigid | APR | Not published for PET rigid density in this scheme | Not published for PET rigid colour in this scheme | Oxygen scavengers must pass PET-CG-01 after ageing per PET-P-12; reheat additives Requires Testing | Unvalidated oxygen scavengers; reheat additives that yellow the flake |
| PET bottle | EPBP | Not applicable; EPBP criteria are compositional, not density-based | Not applicable; EPBP criteria are compositional, not colour-based | PA-MXD6 at most 5 wt% clear, 6 wt% coloured or opaque (3-layer, no tie layers); EVOH at most 3 wt% coloured only; oxygen scavenger stable 5 loops with under 0.1 % non-PET content | PA-MXD6 or EVOH above the cap |
| PVC, styrenics and non-packaging | None | No equivalent additive-level scheme in our source library | No equivalent additive-level scheme in our source library | No equivalent additive-level scheme in our source library | Governed by the legal limits below and by product standards |
Rigid polypropylene#
Rigid polypropylene is graded on density first: below 0.970 g/cm3 the package is Design Preferred, from 0.970 to 1.0 g/cm3 it Requires Testing, and at or above 1.0 g/cm3 the APR rates it non-recyclable. The 20 to 40 wt% calcium carbonate loading common in filled PP compounds sits close enough to the 0.970 g/cm3 band that the exact loading, not just the choice of filler, decides which side of the line a formulation lands on.
A second, independent test applies alongside density: under protocol O-S-01 the package is also non-recyclable if less than 51 wt% of the PP blend floats, which catches formulations where a dense minority component drags the average down even though the bulk resin is unfilled. The full PP package, including which fillers, stabilizers and colorants stay inside the Design Preferred band, is on additives for polypropylene.
Flexible polyethylene film#
Flexible polyethylene film follows the same float-sink logic with a tighter margin: the APR asks for testing once film density approaches 0.996 g/cm3 and treats anything above 1.00 g/cm3 as waste. That margin is narrower than rigid PP's because film gauges are thin enough that a barrier layer or tie layer occupies a proportionally larger share of the structure's total mass.
Barrier content is the additive class most likely to push film density into the Requires Testing range: EVOH at or below 10 wt% with a PE-g-MAH tie layer above 0.1 wt% maleic anhydride stays Design Preferred in co-extrusion, while the same EVOH applied by adhesive lamination is capped at 5 wt%. The film additive package, including slip, antiblock and antifog choices that keep density low, is on additives for packaging film.
PET bottles#
PET bottles are graded on contamination and colour rather than density: the European PET Bottle Platform caps PA-MXD6 at 5 wt% in clear bottles and 6 wt% in coloured or opaque ones, and allows EVOH at 3 wt% in coloured bottles only. An oxygen scavenger used in a clear bottle carries its own separate condition: it must stay thermally stable for 5 recycling loops while keeping non-PET content under 0.1 %.
The APR adds a testing requirement on top of the EPBP's compositional caps: an oxygen scavenger must pass protocol PET-CG-01 after ageing per PET-P-12, and reheat additives are rated Requires Testing because they can darken or yellow the flake during reprocessing. The bottle, fibre and film grades that fit inside these limits are on additives for PET resin.
PVC, styrenics and non-packaging streams#
Outside packaging there is no equivalent additive-level design scheme in our source library, so the constraints come from the law and from product standards. Recovered rigid PVC is the clearest example of a legal, rather than a scheme, ceiling: it may contain up to 1.5 % w/w lead in listed uses under a derogation that runs until 28 May 2033. The complete PVC formulation, including which stabilizer systems stay inside that derogation, is on additives for PVC.
VinylPlus reported 568,695 tonnes of recycled PVC in 2016, 739,525 tonnes in 2018 and 731,461 tonnes in 2020, evidence that PVC recycling runs at real volume without an APR- or EPBP-style scorecard. Product standards fill the gap: EN 13476-3 Annex D lists the items to agree for PP recyclate in multilayer pipe (OIT, ash, foreign polymers, impurities, pigments and additives, volatiles, tensile properties and origin), and recyclate is not permitted in pressurised gas or drinking-water pipe systems. The derogation and restabilization route for this stream are on recycled PVC.
What the Law Adds: PPWR, POPs Limits and Recycled Content#
Voluntary design guides decide whether a recycler wants the package; EU law decides whether the recyclate may legally be used, and it adds 3 layers: heavy-metal and PFAS limits in packaging, trace limits for persistent organic pollutants, and the food-contact rules for recycled plastics. Every one of the 13 legal limits below carries the instrument that sets it and the date it applies from, and the full compliance picture beyond design for recycling is on plastic additive regulations.
| Instrument | What it limits | Value | Applies from | Status |
|---|---|---|---|---|
| Regulation (EU) 2025/40 (PPWR) Art. 5(4) | Sum of Pb, Cd, Hg and Cr(VI) in packaging | 100 mg/kg | 12 Aug 2026 | In force |
| PPWR Art. 5(5) | PFAS in food-contact packaging | 25 ppb any targeted PFAS; 250 ppb sum of targeted PFAS; 50 ppm total PFAS | 12 Aug 2026 | In force |
| PPWR Art. 6 | Design-for-recycling criteria | Set by delegated acts | Due 1 Jan 2028; grades apply from 1 Jan 2030 at the earliest | Not adopted |
| PPWR Art. 7 | Minimum post-consumer recycled content | 30 % contact-sensitive PET, 10 % other contact-sensitive, 30 % single-use plastic beverage bottles, 35 % other plastic packaging (2040: 50, 25, 65, 65 %) | 1 Jan 2030, or 3 years after the implementing act, whichever is later | In force (dated obligation) |
| PPWR Art. 9(3) | Other biodegradable packaging must be designed for material recycling | n/a | 12 Feb 2028 | In force (dated obligation) |
| Delegated Reg. (EU) 2025/1482 (POPs) | PBDEs | 10 mg/kg sum; 350 mg/kg in recovered-material articles from 30 Dec 2025, 200 mg/kg from 30 Dec 2027; 10 mg/kg in toys and childcare articles with recovered material from 17 May 2027 | As dated | In force |
| Regulation (EU) 2019/1021 | HBCDD | 100 mg/kg | In force | In force |
| Delegated Reg. (EU) 2025/1930 | Dechlorane Plus | 1,000 mg/kg until 15 Apr 2028, then 1 mg/kg | As dated | In force |
| Delegated Reg. (EU) 2025/843 | UV-328 | 100 mg/kg from 4 Aug 2025; 10 mg/kg from 4 Aug 2027; 1 mg/kg from 4 Aug 2029 | As dated | In force |
| Commission Delegated Reg. C(2026) 6262 | MCCP | 0.1 % w/w, with 2 % for two years for plastic recovered from cable metal recycling in listed uses | 16 Dec 2026 | Adopted by the Commission, not yet published in the Official Journal |
| REACH Annex XVII entry 63 (Reg. (EU) 2023/923) | Lead in PVC articles | Below 0.1 % w/w; recovered rigid PVC up to 1.5 % in listed uses until 28 May 2033 | 29 Nov 2024 | In force |
| REACH Annex XVII entry 51 | DEHP, DBP, BBP, DIBP in all articles | 0.1 % | 7 Jul 2020 | In force |
| Regulation (EU) 2022/1616 | Recycled plastics for food contact | Suitable technologies only | 10 Oct 2022 | In force |
PPWR: heavy metals now, design-for-recycling criteria later#
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026, but the part of it that will grade recyclability is not written yet. The operative parts today are the heavy-metal ceiling on cadmium, lead, mercury and hexavalent chromium, the PFAS limits for food-contact packaging, and the recycled-content targets that phase in from 2030.
Article 6 design-for-recycling criteria are due by delegated act on 1 January 2028, with recyclability grades applying from 1 January 2030 at the earliest, so the PPWR does not yet set numeric design rules of its own; it adopts them once the delegated acts are published. The article-by-article detail beyond design for recycling is on the EU Packaging and Packaging Waste Regulation (PPWR) page.
Legacy limits a design decision passes to the next loop#
Persistent organic pollutant limits are written as unintentional trace contaminant values, which means they apply to the recyclate whether or not the recycler put the substance there. Every listing and its trace limit is on POPs in plastics: UV-328 steps down from 100 mg/kg (4 August 2025) to 10 mg/kg (2027) and 1 mg/kg (2029), Dechlorane Plus drops from 1,000 mg/kg to 1 mg/kg on 15 April 2028, and HBCDD sits at a flat 100 mg/kg. MCCP is adopted by the Commission but not yet published in the Official Journal, so it is not yet in force in the EU.
These limits exist because a design decision made today becomes a legacy constraint tomorrow. Brominated flame retardants are the clearest case: a formulation that used one when it was legal can still turn up in a recyclate stream decades later at a level the POPs Regulation now caps. Compatibilizers show the same pattern: once used to blend an immiscible polymer fraction, a compatibilizer becomes one of the legacy additives in recycled plastic that the next loop has to account for.
Recycled plastics in food contact#
Recycled plastic may enter food contact in the EU only through a recycling technology recognised under Regulation (EU) 2022/1616, which has been in force since 10 October 2022. The technologies and register are on recycled plastics regulations. The regulation recognises exactly two routes: post-consumer mechanical PET recycling, where at most 5 % of input may come from non-food applications and output may not go into ovens, and recycling from product loops in a closed and controlled chain, with a public register of qualifying recyclers, installations and processes.
In the United States, the FDA works from a negligible dietary concentration of 0.5 ppb, and tertiary recycling of PET and PEN needs no individual evaluation before the FDA issues a no-objection letter, never an approval. The food-contact additive package recycled resin must still meet is on additives for food packaging.
How to Check a Formulation for Recyclability: 7 Steps#
Check a formulation for recyclability in 7 steps: name the stream, calculate the density, measure the colour, remove the degradable additives, add up the contamination, screen the restrictions, and confirm the second heat history.
- Name the target stream and the scheme that governs it: APR, EPBP, RecyClass, or none.
- Calculate the compound density from the filler and mineral loading and compare it with the stream's float-sink band.
- Measure or predict L* and near-infrared reflectance for the colour package.
- Remove any degradable or pro-oxidant additive; there is no dosage at which it passes.
- Add up every gram of non-target polymer, barrier layer, tie layer and scavenger as a percentage of the package and compare it with the published cap.
- Screen every additive against the restriction and POPs trace limits that will apply to the recyclate, not only to the article.
- Confirm that the stabilizer package still protects a second extrusion, because the recyclate will probably not be re-stabilized; topping the package up afterward is a separate job, covered on additives for recycled plastics.
Recyclability is one input into how to select plastic additives, alongside mechanical performance and cost.
The antioxidant a formulation carried through its first life sets how much reprocessing it can survive before restabilization of recycled plastics becomes necessary.
How Recyclability Is Tested and Verified#
Recyclability is verified by measurement, not by declaration: density against the float-sink band, L and near-infrared reflectance against the sorting protocol, and the stability of the polymer through a simulated second life.* The method index for every one of these tests, with the full standard numbers, is on testing plastic additives.
| What is verified | Method or protocol | Source of the criterion | Target |
|---|---|---|---|
| Float-sink behaviour | APR O-S-01 | APR PP rigid | At least 51 wt% of the blend floats |
| Compound density | Density measurement | APR | Below 0.970 g/cm3 (PP rigid); below 0.996 g/cm3 (PE film) |
| Sortability | APR SORT-S-01, L* and NIR reflectance (color measurement and matching of plastics) | APR | L* above 40 and NIR reflectance above 10 % |
| Oxygen-scavenger stability in PET | PET-CG-01 after ageing per PET-P-12 | APR PET | Pass |
| Barrier content | Package composition calculation | EPBP | PA-MXD6 at most 5 wt% clear, 6 wt% coloured |
| Residual stabilization | Oxidative induction time (OIT), ISO 11357-6 or ASTM D3895 | Our sources | Per grade |
| Melt stability across passes | Melt flow rate (MFR), ISO 1133 or ASTM D1238 | Our sources | Per grade |
| Recyclate acceptance for pipe | EN 13476-3 Annex D item list | Product standard | Agreed between the parties |
No APR protocol identifier exists beyond O-S-01, SORT-S-01, PET-CG-01 and PET-P-12 in this reference, so no other protocol number is cited on this page.
What Additive Design Means for the Circular Economy#
Additive design decides both how much material reaches a recycler and what that material is worth once it gets there, which is why the same decisions turn up in the EU circular-economy rules and in the price a recycler pays for a bale. A package that fails one of the 6 decisions above is diverted out of the recycling stream entirely, the mechanical link between a compounding-stage choice and the volumes that show up in circular-economy statistics. This page is one of the decisions that make up plastic formulation; the policy view of that link is on plastic additives in a circular economy.
How much plastic is actually recycled?#
About 9 % of all plastic waste made up to 2015 was recycled and roughly 1 % was recycled more than once, and the Lancet Countdown put the current global figure below 10 %. Those two figures measure different things and are never merged into one number: the 9 % figure covers cumulative plastic waste generated up to 2015, while the Lancet Countdown's under-10 % figure is a more recent global estimate.
The European Union's own plastics production data give a narrower, regional picture: 14.5 % of EU plastics production is mechanically recycled, 1.1 % is bio-based and 0.2 % is chemically recycled. None of these figures is the widely repeated claim that 91 % of plastic is never recycled; that number does not appear in verified sources and is not stated as fact on this page.
Do additives make recycled plastic unsafe?#
Some can: Wiesinger and colleagues at ETH Zurich found regulated chemicals above 0.1 wt%, mainly lead and DEHP, in 16 % of 151 new PVC floorings on the Swiss market, linked to the use of recycled PVC. Hahladakis, Velis, Weber, Iacovidou and Purnell at the University of Leeds (Journal of Hazardous Materials 344, 2018) documented the broader mechanism: additives can be released during recycling and recovery processes and from products made from recyclates, not only from the original article.
The legal limits described above exist to control this risk: the 0.1 % w/w REACH ceilings on lead and on DEHP, DBP, BBP and DIBP apply to what a recyclate may contain regardless of origin. The Swiss flooring finding does not generalise to all recyclate; it documents one product category made partly from recycled PVC. How these substances leave a polymer is covered on additive migration in plastics.
What this guide does not cover#
This guide covers the additives put into a new article; the additives added to a recyclate are a different job with different dosages.
- Additives added to a recyclate. Restabilizers, compatibilizers, odour absorbers and chain extenders are dosed at the regranulation stage, not the virgin-article stage, and are covered on the recycled-plastics formulation guide and on the restabilization page.
- Chemical recycling. The fate of additives during pyrolysis or solvolysis is not established in our source library and is not covered here.
- Consumer recycling questions. Resin identification codes and kerbside collection rules are outside this site's scope; this guide covers the additive decisions that determine recyclability, not how a household sorts its bin.