The European Aluminium Foil Association (EAFA), together with partner associations (European Aluminium, Aluminium Closures Group, Metal Packaging Europe, etma and AEROBAL) involved in aluminium packaging, has published a new framework for packaging design: the Design for Recyclability Guidelines and Recyclability Assessment for Packaging containing Aluminium. The aim is to ensure that packaging design facilitates efficient recycling at the end of the life cycle.

The guidelines are addressed first to packaging designers, but also to legislators and technical experts involved in the discussions on establishing appropriate methodologies for assessing packaging recyclability. The EU Packaging and Packaging Waste Regulation (PPWR) requires that by 2030 all packaging placed on the European market must be recyclable.

In this context, the Design for Recyclability Guidelines and Recyclability Assessment for Packaging containing Aluminium provide a scientifically sound approach for evaluating the recyclability of packaging predominantly made of aluminium. Furthermore, these guidelines render relevant information on the recyclability of packaging which contain aluminium as a minor material share.

“The PPWR sets ambitious objectives on packaging recyclability – we want to help ensure that the related provisions are implemented on a reliable and practice-oriented basis. Our guidelines provide a comprehensive overview and understanding of the factors having an impact on the recyclability of packaging containing aluminium, creating transparency for designers, regulators and the recycling industry,” stresses Jean-Paul Duquet, Director Sustainability at EAFA.

Technical background

Aluminium as a packaging material is characterised by properties that make it suitable for a wide range of applications. These include formats made predominantly of aluminium – such as semi-rigid foil containers, pet food trays, coffee capsules, alu/alu blister packs or foils for chocolate and cheese. They also include formats where aluminium is present in smaller shares but adds crucial functional properties – for example, aluminium as an essential barrier layer in pouches or beverage cartons.

Aluminium as a material is generally regarded as highly recyclable. However, when it comes to the recyclability of aluminium-containing packaging, there is room for improvement, and enhancement in both packaging design and recycling infrastructure can help.

As a benchmark, the guidelines apply state-of-the-art collection, sorting, reprocessing and recycling infrastructure, which has reached the highest Technology Readiness Level (TRL 9) and is available in Europe.

They have been developed in close alignment with the current provisions and terminology of the PPWR.

Practical recommendations for different packaging formats

Concrete design recommendations are included for a range of selected aluminium packaging formats in order to help designers improve their packaging recyclability.

“With the Design for Recyclability Guidelines and Recyclability Assessment for Packaging containing Aluminium, we have developed a practical tool that supports all stakeholders along the value chain – from packaging designers and brand owners to policymakers. This will help ensure that aluminium packaging is even better integrated into the circular economy in the future,” explains Sandra Beckamp, Managing Director at Institut cyclos-HTP, who acted as project manager.

With these new guidelines, the aluminium packaging industry is making an important contribution to a European circular economy. They provide orientation for all stakeholders and support the shared goal of designing packaging that is not only recyclable but also resource-efficient and functional. This achievement has been made possible through the close cooperation of numerous associations and experts along the entire value chain – a clear signal that the industry is ready to tackle the PPWR requirements jointly and constructively.

The Design for Recyclability Guidelines and Recyclability Assessment for Packaging containing Aluminium are now available for download at D4R.alufoil.org.

• The new EU Packaging and Packaging Waste Regulation (PPWR) will come into effect in August 2026, requiring companies to adopt more sustainable practices, particularly by reducing packaging waste and promoting reusable packaging.
• EOL Group, a specialist in end-of-line packaging machines and automation solutions, develops customised packaging concepts to help businesses efficiently future-proof their compliance with PPWR requirements.
• Working closely with its customers, EOL Group crafts tailored strategies to implement the PPWR in a practical, cost-effective, and sustainable way.

The EU Packaging and Packaging Waste Regulation (PPWR) was passed on February 11, 2025, and will be legally binding across all EU member states starting August 12, 2026. The regulation aims to significantly reduce packaging waste, promote the reuse and recycling of packaging, and strengthen the circular economy. A particular emphasis is placed on encouraging reusable solutions and designing recyclable packaging. The PPWR sets clear guidelines on reusability, the use of recycled materials, and the elimination of unnecessary packaging, marking an important step toward sustainable, resource-efficient packaging systems.

As a specialist in customised end-of-line packaging machines and automation solutions, EOL Group supports companies in putting the PPWR requirements into practice efficiently and effectively. Thanks to its comprehensive interface expertise, EOL delivers streamlined, integrated solutions that ensure smooth operations that can be flexibly adapted to individual needs. The focus is on simple, clear, and efficient processes – driven by agility, open communication, and a spirit of partnership. The goal is to work together with customers to create economically viable and legally compliant packaging strategies.

“The PPWR isn’t an obstacle – it’s an opportunity for sustainable innovation, greater circularity, and future-ready business models. Together with our customers, we’re developing solutions that already meet tomorrow’s demands today,” explains Sebastian Jost, CEO of EOL Group.

By Peter Harding, President of UNESDA Soft Drinks Europe and CEO of Suntory Beverage & Food Europe

The EU is set to move towards a circular economy for beverage packaging. In just a couple of weeks, Members of the Environment Committee in the European Parliament will vote on their amendments to the EU Packaging and Packaging Waste Regulation (PPWR). In parallel, EU Member States are working towards adopting their position on this file by the end of the year. Among the key areas of attention in the PPWR is reuse and refill. It is absolutely critical that MEPs and Member States support sound measures that ensure that recycling, reuse and refill are complementary solutions, and reject proposals to increase the reuse and refill targets without further assessment of their environmental, economic and social impacts.

The EU is taking a leadership role in driving circularity and the PPWR is among the most ambitious EU policies in this regard. The European soft drinks sector, represented by UNESDA Soft Drinks Europe, supports the goals to better reduce, collect, recycle and reuse beverage packaging. We have already shown that we take bold voluntary actions to contribute to accelerating the green transition in Europe through our commitment to making our soft drinks packaging fully circular by 2030.

Our sector also supports reuse and refill systems as part of the solution to reduce packaging and packaging waste. We are already investing in these systems as a complementary action to our ongoing efforts to reduce and recycle our packaging.

It is fundamental that recycling and reusable systems are complementary solutions and MEPs and Member States should enshrine this in the PPWR. How?

Key ask 1 – Do not increase the reuse and refill targets (Art. 26) without further impact assessment

The European Commission’s impact assessment has been heavily criticised by many stakeholders, including our sector, over the last 9 months. The lack of a proper environmental and economic assessment of the implications of the reuse and refill targets proposed by the European Commission in the PPWR is worrying as legislation should always be developed on the basis of clear and granular data on the costs and benefits of the measures being proposed. So, first things first: the only way to assess the real impact of scaling up reusable systems across the EU is to thoroughly analyse the costs and benefits of setting up these systems in different Member States, different sectors and different distribution channels. As an example, the shift to 10% refillable PET as of 2030 in the EU is estimated to cost more than €16 billion, according to a PwC study.

It is very concerning to see proposals for increased reuse and refill targets for 2030 and 2040 that are not based on any further impact assessment that justifies them. Why forcing beverage manufacturers, of which a majority are SMEs, to make huge investments in reuse and refill systems in geographies or channels where existing well-functioning single-use systems make more sense from an environmental and economic perspective?

In our view, the proposed targets are already extremely challenging and therefore the focus now has to be on providing manufacturers with the necessary enablers and the flexibility to invest in the best packaging mix.

Key ask 2 – Maintain systems enabling refill in the reuse and refill targets (Art. 26)

We are all familiar with the traditional returnable refillable bottle, whereby the consumer buys a beverage bottle in a store and brings it back to the retailer for it to be refilled. This is not, however, the only system to reuse and refill – and it is not always the best solution from an environmental perspective. Asking beverage manufacturers to focus all their investment and innovation only in reuse on traditional returnable refillable bottles takes no account of consumer patterns of shopping and consuming beverages, and stifles the innovative solutions that open up possibilities to match consumers to more sustainable purchasing habits.

Today, there are several innovative reusable solutions that are convenient for consumers, are responding to new consumption habits and are helping reduce packaging as they use little to no packaging, such as home soda dispensers and refill stations in stores and horeca. Why, then, aren’t these at-home and on-the-go solutions, which are recognised by the Ellen MacArthur Foundation as reuse models, counting towards the achievement of the reuse and refill targets? It makes all sense to consider them for the attainment of the reuse and refill targets. The PPWR should secure a future for these innovative refill solutions and the EU co-legislators should therefore support a broad definition of reuse and refill that includes the whole spectrum of available reusable and refill models.

Key ask 3 – Create well-designed exemptions to ensure reusable packaging is only used where and when it makes the most sense

It is essential to make sure that reusable packaging is only introduced where it makes sense from an environmental, economic and consumer perspective. To enable it, the PPWR should provide a form of exemption if certain environmental criteria are met in order to avoid unintended adverse effects of the reuse and refill targets.

Some amendments tabled in the different European Parliament’s committees involved on this file can serve as a positive source of inspiration as they recognise the role of existing well-functioning circular systems. For example, many countries are investing in achieving 90% collection of PET bottles and aluminium cans through the introduction of Deposit and Return Systems (DRS). Let’s encourage these investments!

Now is the moment for the European Parliament and EU Member States to make the PPWR more supportive and more realistic. Our sector will remain constructive and engaged with all stakeholders to help create a stable and enabling policy environment.