Most businesses think of recyclability as a binary question: is this packaging recyclable, yes or no? In practice, a packaging component can be recyclable in one market and not in another, or score differently depending on which methodology is applied. If you sell into multiple jurisdictions, a single recyclability assessment does not tell you what you need to know.

Different markets, different standards

Recyclability assessment in the packaging industry is not standardised. Each major market uses its own methodology, typically tied to its EPR scheme and the local recycling infrastructure. The results directly affect your EPR fees through eco-modulation - packaging that scores well on recyclability pays lower fees, and packaging that scores poorly pays more.

The major recyclability methodologies in use today are:

  • ZSVR Minimum Standard (Germany) - published by Zentrale Stelle Verpackungsregister and tied to LUCID eco-modulation via the bifa catalogue. Assesses whether packaging is compatible with the German collection and sorting infrastructure
  • COTREP (France, plastics) - the Comite Technique pour le Recyclage des Emballages Plastiques assesses plastic packaging recyclability. Results feed into CITEO eco-modulation bonuses and penalties
  • CEREC (France, paper and card) - the Comite d'Evaluation de la Recyclabilite assesses fibre-based packaging recyclability for the French market
  • KIDV (Netherlands) - the Kennisinstituut Duurzaam Verpakken provides recyclability assessments tied to Afvalfonds/Verpact declarations
  • OPRL RAT and Defra/PackUK RAM v1.1 (UK) - the On-Pack Recycling Label Recyclability Assessment Tool and the Defra Recyclability Assessment Methodology drive pEPR modulated fees from 2026
  • RecycClass (EU-wide) - operated by Plastics Recyclers Europe, covering all material types with a tiered assessment system
  • Fost Plus Design for Recycling guidelines (Belgium)
  • ARA Circular Design (Austria) - developed with OFI and FH Campus Wien
  • CONAI fee bands and ATICELCA 501 for paper (Italy)
  • Ecoembes TheCircularLab (Spain)
  • CEFLEX Design for a Circular Economy guidelines (EU-wide, specifically for flexible packaging)

Why results differ

These methodologies are not interchangeable. They assess against different criteria because local recycling infrastructure and collection systems vary:

A flexible plastic pouch might be assessed as "recyclable" under a methodology that assumes access to chemical recycling or advanced mechanical recycling for flexibles, but "not recyclable" under one that only considers conventional mechanical recycling. A paper cup with a PE lining might score differently in a market with established fibre recovery for liquid packaging board versus one without.

Composite packaging is particularly inconsistent across methodologies. A carton made from paperboard with a thin PE barrier might be classified as recyclable paper packaging in one market (where the fibre is recovered and the PE is separated), but as non-recyclable composite in another (where the local infrastructure cannot process it).

The practical consequence is that a single recyclability score is misleading if you sell into multiple markets. A component might score well under ZSVR but poorly under COTREP, or vice versa.

The fee impact

Recyclability assessment is not academic. In most major EPR schemes, recyclability grade directly modulates your fees. Packaging assessed as highly recyclable gets a fee discount (eco-modulation bonus). Packaging assessed as difficult or impossible to recycle pays a surcharge (eco-modulation malus).

If you are only assessing against one standard and selling into five markets, you have visibility into your fee position in one market and are blind to the other four. A material change that improves your ZSVR score might worsen your COTREP score. Without running the assessment against all relevant methodologies, you cannot make informed design decisions.

The EU-wide framework from 2030

PPWR Annex II introduces EU-wide recyclability performance grades from 2030. Packaging will be graded A (highest), B, or C based on standardised criteria. Grade D packaging will face restrictions, and Grade E packaging will be progressively banned from the market by 2038.

This does not replace national methodologies in the near term. National EPR schemes will continue to use their own recyclability standards for fee modulation. The PPWR grades add an additional EU-level assessment on top of national ones. A component will need to meet both the EU-wide PPWR grade threshold and the national recyclability standard for each market it is sold into.

The multi-methodology approach

Merchant Packaging records a recyclability grade per component, with the basis it rests on - such as RecyClass or the ZSVR minimum standard - the date it was made and when it expires, and applies red, amber or green ratings in UK reports. It does not run the national methodologies itself: the assessment is made against the relevant standard, and the result is held on the component.

This means your recyclability position sits on the same component records as your EPR and PPWR data, rather than in a separate spreadsheet, and an assessment that has expired is visible as such.