A conversation with Fiona Durie, CEFLEX Advocacy Consultant

What does the latest CEFLEX analysis tell us about the scale of demand needed to meet Packaging and Packaging Waste Regulation (PPWR) recycled content targets?

Recent CEFLEX analysis shows that by 2030, polyolefin-based flexible packaging will need around 2.5 million tonnes of PCR to meet PPWR recycled content targets of 35 percent for non-contact sensitive applications and 10 percent for contact-sensitive uses.

That increase from current levels – conservatively estimated at around 1.5 million tonnes – is the immediate priority for the value chain. Packaging that does not meet these thresholds cannot be placed on the EU market from 2030.

What the analysis shows is that achieving these 2.5 million tonnes is not simply a question of collecting and recycling more material. It depends on whether that material can be separately collected, sorted and recycled to produce PCR at the right quality and consistently integrated into real packaging applications.

Alongside this, there is a wider set of established markets that already use – and is expected to absorb additional volumes of – recycled material. This takes the total potential demand for polyolefin-based flexible packaging derived PCR to around 4.3 million tonnes in 2030. These include non-packaging and rigid applications that already use recycled plastics today.

However, unlike packaging, these potential markets are not driven by legislation. They respond to price, quality and availability. If recycled material does not meet those conditions, they will revert to virgin material.

This underlines a key point if we want to maintain and develop a system of circular materials. The 2.5 million tonnes required for PPWR compliance must be delivered first, but the overall system depends on producing recycled material that is competitive and usable in both regulated and non-regulated secondary applications.

The report highlights how recycled content and recycling rate targets create two distinct dynamics to how materials flow through the system. Why is this important for decision-makers?

I think how the analysis shows the implications of recycled content and recycling rate targets are particularly revealing for policy makers and industry – illustrating just how recycled content and recycling rate targets interact.

The first dynamic is a direct pull from recycled content targets in 2030. This creates an immediate demand for PCR within packaging and effectively guarantees a baseline level of uptake.

The second dynamic is a system-level push from the 55% ‘recycled at scale’ recycling rate target for all plastic packaging formats including flexible packaging in 2035. This drives significantly higher volumes of material through collection, sorting and recycling systems – effectively making it a requirement to find meaningful secondary applications 5.9 million tonnes of recycled material in 2035.

To meet both, but even more so the latter, packaging alone cannot absorb the volumes of PCR required to meet the higher recycling rates. Even under favourable assumptions, in 2030, recycling flexible packaging back into flexible packaging delivers around 25 percent recycling rates, increasing to around 42 percent when ‘open loop’ – such as rigid and non-packaging – secondary applications are included.

If those non-flexible packaging applications are not developed, higher recycling rates will generate increasing volumes of recycled material without any demand for it. An unattractive proposition for recyclers, Extended Producer Responsibility (EPR) schemes – and the environment.

To avoid it, recycled content targets and recycling rate targets must be aligned with realistic and functioning secondary application markets – and that demand develops from all potential recycled content users, not only in packaging. If they do not, then recycling rate targets will not be achieved.

What are the most critical factors that will determine whether this demand can be met in practice?

The ‘Secondary Applications for Recycled Content’ analysis points to where demand is concentrated, and whether the quality of recycled material meets those application’s needs.

Around 80 percent of mechanical PCR demand in 2030 is concentrated in a relatively small number of high-volume applications, particularly polyethylene film uses such as stretch film, shrink film, refuse sacks and heavy-duty bags. These applications will therefore be key to whether recycled content ambitions succeed or not.

At the same time, increasing PCR volumes alone is not enough. The material produced must be fit for purpose. If the quality is not there, recycled content will not replace virgin material, regardless of how much is collected, sorted and recycled.

This brings the focus onto infrastructure. It is not only about scaling what exists today. It is about the collection, sorting and recycling system we need for tomorrow: so that the right quality, for the right secondary applications – and in the right quantities – is produced.

“CEFLEX analysis shows that PPWR recycled content targets required producing 2.5 million tonnes of flexible packaging derived PCR in 2030 at the right qualities to be used again in a range of secondary applications.

What is even more revealing however, is that the 55% ‘recycled at scale’ recycling rate target in 2035, effectively raises this to 5.9 million tonnes in 2035 – simply by increasing the amount of material flowing through the system. This shows the different dynamics of the two different targets on recycled materials and the scale of the challenge”.

Fiona Durie

Fiona Durie, CEFLEX Advocacy Consultant