How Recyclability Is Assessed: The Article 6 Method

The assessment takes a packaging unit, establishes its complete composition by weight, scores it against the design-for-recycling criteria for its material category, and expresses the result as the percentage of the unit that is recyclable - which sets the grade. The criteria reward mono-material construction, separable components and stream-compatible features, and deduct for the known disruptors: inseparable incompatible materials, problematic inks and coatings, components that defeat sorting.

The manufacturer's assessment, documented in the technical file, is the legally operative act. External recyclability evaluations - association protocols, laboratory testing, certification schemes - are admissible evidence supporting it, and the better the design's borderline, the more the file needs them.

One: freeze the unit's definition - the version as placed, from the component inventory in the formats station. Two: assign the category - the material stream whose criteria govern (rigid plastic, flexible plastic, paper and board, glass, metal, wood, beverage carton and the rest as the acts define them). Three: score feature by feature against the criteria tables, noting every deduction and its basis. Four: compute the recyclable weight share and the grade, and record sensitivity - which single feature change would move the grade, because that sensitivity list is the redesign agenda. Five: file the working with the criteria version used, the assessor's identity and the date, and set the review trigger - any component change, any criteria update.

Steps one and five are where assessments fail in practice: units assessed in a version that was never placed, and workings filed where a change could silently invalidate them.

Self-assessment is the regulation's chosen mechanism because packaging volumes make pre-market approval impossible; it works if the file discipline in step five holds. Its honest limits are designs near thresholds and designs using novel materials or structures the criteria tables address only by analogy. For those, laboratory and protocol testing - sortability trials, reprocessing tests, recyclate quality assessment - converts an argument into evidence, and the cost is modest against a grade dispute on a high-volume line. The desk's rule: self-assess the clear, test the borderline, and never let a commercial deadline grade a design that engineering has not scored.

An assessment is a snapshot of a unit against a criteria version; both move. The change-control gate from the formats station feeds the first kind of movement (any component or supplier change reopens the scoring), and the delegated-act calendar feeds the second (criteria tighten by category as the acts and their successors publish). Programmes should schedule a criteria-version review per category at each act publication, sampling the units whose sensitivity analysis showed them nearest a threshold. Grades are not trophies won once; they are positions held against moving criteria, and the file should show them being held.

A 250 ml PP sauce bottle, PP cap, full-body PET-G shrink sleeve with standard inks, sold as a single unit. Inventory: bottle 22 g, cap 3 g, sleeve 4 g. Category: rigid plastic. The bottle and cap are stream-compatible; the sleeve is the problem the criteria exist to catch - different polymer family, full coverage defeating resin identification, and a share (4 of 29 g, about 14 percent) that comes off the recyclable fraction along with the sorting penalty the category table applies. The unit scores in the mid-80s percent on the material arithmetic alone, but the identification failure can cost the bottle's own recyclability in the table's logic, which is how a 14 percent component produces a failing design. Change the sleeve to a perforated, partial-coverage polyolefin label and the same unit scores comfortably at B, nearing A. One component, honestly scored, told the whole story - and the redesign.