Design for recycling: monomaterial, glue, colour and labelling

The part of the regulation that sits closest to the craft. Material choice, glue, printed surface, and a label that has to fit in the artwork.

Of everything in the EU’s new packaging regulation, this is the part that sits closest to the craft. Article 6 says that all packaging placed on the market shall be recyclable, and the definition has two halves with a date each.

From 1 January 2030 the packaging has to be designed for material recycling, so that what comes out is of high enough quality to substitute primary raw material.

From 1 January 2035 it also has to be collected separately, sorted into a specific waste stream without wrecking the recyclability of other streams, and recycled at scale.

The second half is the one that catches people out. A packaging can be recyclable in theory and still fail, because no facility actually sorts it out in practice.

A bag, a ribbon, a sticker and a hang tag. Four materials, one packaging. That is where recyclability is decided.

Monomaterial is the only decision that really counts

Sorting facilities sort by material. A packaging made of a single material lands in the right pile. A packaging made of two materials stuck together lands either in the wrong pile or in residual waste.

That sounds simple and is not, because laminates exist for a reason. A carton with a thin plastic layer keeps grease and moisture out. A pouch with a metallised layer keeps oxygen out. You do not switch to a monomaterial for free, you switch to a different problem: shorter shelf life, a weaker barrier, or a more expensive material.

That design decision is real and it is a trade off. The point is that it now has a date on it.

Three things that can usually be done without losing anything:

The label in the same material as the packaging. A paper label on a plastic bottle is a material mix. A label in the same plastic as the bottle is not.

The window. A plastic window in a carton is often the only thing that turns the packaging into a mix. Sometimes it is needed. Often it is there because somebody thought it looked nice to see the product.

The insert. A folded insert in the same board as the box replaces both the plastic tray and the filling material, and makes the carton smaller while it is at it. That helps the empty space ratio in the same move.

The adhesive, which nobody thinks about

Glue is the most common way to ruin an otherwise clean packaging. A strong adhesive that does not release in a water bath follows the pulp through the process and turns into stickies, contamination that lowers the quality of the whole batch.

The question to ask the supplier is not which glue do you use. It is whether the glue releases in the recycling process for this material. That is a question with a yes or a no, and it is rarely asked.

The same goes for labels that sit too firmly. A label that cannot be separated from the packaging is a material mix no matter what it is made of.

Colour is a recycling problem, not only an expression

This is the part that hurts for a designer, because it goes straight into the identity.

Full coverage dark colour on plastic makes the material harder to sort optically. Carbon black is the classic example: sorting equipment that reads reflected light sees nothing at all, and the material goes to residual waste even though it is a clean polymer.

Heavy ink coverage on paper follows the pulp and lowers the quality of what comes out. Metallised layers and certain varnishes do the same.

None of this means packaging should be unbranded and beige. It means the printed surface is a material choice and not only an aesthetic one, and that an identity that only works with full coverage print is worse equipped than one carried by form, typography and contrast.

There is a real design question hiding in here, and it is more interesting than it sounds: how much of a brand actually sits in the printed surface? Usually considerably less than you would think. A shape, a proportion and a typeface carry a brand a long way without covering the material.

Recycled plastic does not look like virgin plastic

Article 7 requires a minimum share of recycled content in every plastic part from 2030, between 10 and 35 per cent depending on the type, and between 25 and 65 per cent from 2040.

The consequence for design is easy to describe and uncomfortable to accept. Recycled plastic is rarely as clear, as white or as colour stable as virgin material. Batch variation is larger.

A design that leans on a crystal clear substrate or an exact colour match on plastic is going to be harder to hold, and it is better to know while you are drawing than when the proofs arrive.

Recyclability becomes a grade, and the grade has a price

The part that turns all of this from a principle into a budget line is the grading. Recyclability is not a yes or a no. It is expressed in performance grades A, B and C, set from 2030 on design for recycling criteria and from 2035 on both design for recycling and recycled at scale criteria, per packaging category.

Packaging below grade C counts as technically non recyclable and its placing on the market is restricted. From 1 January 2038 packaging has to be at least grade B.

The commercial edge is in Article 6. Once the relevant acts have been in force for 18 months, the fees producers pay under extended producer responsibility are modulated according to the recyclability grade. Better grade, lower fee. That turns a plastic window and a full coverage varnish from an aesthetic preference into a recurring cost, which tends to be the argument that actually moves a decision.

The label has to fit

From 12 August 2028, or 24 months after the implementing acts if that falls later, packaging has to carry a harmonised label with information on its material composition, based on pictograms and readable for people with disabilities.

Harmonised means it looks the same across the union. So not the symbol you drew yourself, and not at whatever size happens to be left over.

In practice this is a layout requirement. The label has to sit somewhere, be legible, and not look like an afterthought. Artwork drawn now should leave room for it, because that is cheaper than opening the file again in 2028.

All of this ends up in a document, so write it down as you go

Compliance with the recyclability requirements has to be demonstrated in technical documentation for the packaging. That document is assembled by someone at some point, and it is assembled from exactly the information that was in the room when the material decisions were made.

In practice it is almost always reconstructed afterwards by a person who was not there, from emails and a supplier who has since changed their spec. Keeping a plain list of what the packaging consists of, updated when a decision changes it, is half an hour of work spread over a project and days of work saved at the other end. It is the same habit as keeping a design system honest while you build, rather than documenting it once the site has shipped.

The order I would work in

1. Map what the packaging is made of, layer by layer, including adhesive, varnish, label and ink. The answer often lives with the supplier rather than with you.
2. Look for the mixes. Windows, labels in another material, metallised layers, a plastic tray inside a carton.
3. Ask the supplier whether the glue releases in the recycling process.
4. Check whether what you have chosen is sorted in practice where your customers live, not only on paper.
5. Leave room for the label in the artwork.

None of these needs a lawyer. All five are design decisions, and most of them are cheap to make now and expensive to make twice.

The series starts with a walk through the regulation and its dates, and part two is about the empty space ratio. Packaging design, print artwork and material choice are part of what I work with, see what I do.