The measurement gap at Sustainability in Packaging Europe 2026

Recyclability is a promise, recycled is proof

Smithers framed it simply: recyclability is a design promise; recycling is a system outcome. Three pressures push them apart.

1. Consumer expectation. Recyclability depends on local infrastructure, making broad claims risky. Colgate-Palmolive spent five years developing a recyclable HDPE tube, yet faces a class action because local systems cannot process it. The design works, but exposure stems from unobservable recovery systems.

2. Regulation. From 2030, PPWR bans packaging below a 70% recyclability grade. By 2035, formats must be recycled at scale (55% for most materials), shifting the focus from design to system performance.

3. EPR fees. Detailed below.
   

“Recyclability is a promise made about a design, while recycling is an outcome a system delivers.”

What European recovery systems deliver today

EU plastic packaging recycling averages 41.7%, ranging from nearly 60% in Belgium to 25% in France for identical packs, proving collection and sorting drive the variance.

Collection quality also varies. PreZero estimates Germany's yellow bag contains 36% recyclable plastic packaging, 25% other recyclables, 13% non-recyclable plastic packaging, and 26% non-target waste (from mattresses to Christmas trees).

A German Environment Agency (Umweltbundesamt) study noted that metals, beverage cartons, and rigid containers reliably reach sorted streams. Flexibles and PET trays reach them only ~19% of the time due to commercial system design rather than technology limits.

The arithmetic behind recycling at scale

Reaching 55% overall recycling requires collection, sorting, and reprocessing each to run at ~82% (80% across all three yields just 51%). Few national systems hit this consistently.

A CIRPACK study of 13 packaging subcategories across the EU27 found no category on track in every member state. Performance varies wildly by national infrastructure—Belgium recycles 79% of packaging, whereas Romania recycles 37% under the same targets.

Because thresholds are EU averages, materials in larger markets fare better. Flexibles lag as many member states lack separate collection. Brands cannot fix collection schemes alone, making national infrastructure a key portfolio risk.

“No design work by a single brand will change a country's collection scheme.”

Eco-modulation needs evidence, not estimates

Eco-modulation adjusts EPR fees based on recyclability. CIRPACK found structured or format-specific fees boost recycling rates by 7–16.5 percentage points over basic fees, while high-transparency systems outperform low-transparency ones by 13.4 points.

Lack of public reporting on producer fee allocation remains contentious. Mars highlighted that UK flexible packaging fees were paid despite collection delays to 2030, and France spends twice as much per resident as Belgium for half the recycling output.

To simplify compliance, Fost Plus and partners created the 'No Regrets' playbook, aligning CEN standards with RecyClass and CEFLEX guidance. In Belgium, a red-rated pouch design already incurs three times the fee of a green-rated one.

Sorting is changing faster than the rules that describe it

AI sorting now enables separation by end application (e.g., food vs. non-food contact). However, assessments still rely on near-infrared sorting, which limits shrink sleeve coverage—placing ~94% of the shrink sleeve market outside green categories under Fuji Seal's assessment.

The EU Joint Research Centre found some CEN test protocols dilute packaging samples down to 12.5%. While still a useful baseline, designs passing 2026 protocols may perform differently in 2030 plants.

Takeaways for packaging teams

Begin with red categories. Plastic standards are published, others follow soon, and delegated acts arrive in 2028. Reformulating formats takes time, so scoring against current standards and eliminating red-rated designs should begin immediately.

Price the format, not the material. Nestlé found an 88% fibre pack classified as composite in some markets, costing more than a recyclable plastic alternative.

Treat the market as a variable. Recovery, fees, and compliance vary by member state; decisions based solely on EU averages will miscalculate local market risks.

Close the evidence gap. Lab models predict recyclability under ideal conditions but fail to measure real-world sorting performance.

Deepnest addresses this gap using Greyparrot's computer vision AI across 300+ Analyzer units in 20+ countries. It measures real sortability—the exact proportion of packaging properly sorted versus lost to incineration or landfill—giving packaging teams clear visibility in target markets.

With the design rules close to settled, the question for the next four years is whether the industry can see its own systems clearly enough to act on them.

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