Below Grade C: Technically Non-Recyclable Packaging and the End of the Line

Packaging whose assessed recyclability falls below 70 percent is, in the regulation's language, technically non-recyclable, and from the grading date it may not be placed on the market. The population below the line is predictable: inseparable multi-material laminates with no credited stream, very small formats that sorting cannot capture whatever their material, units combining materials in ways that contaminate each other's streams, and designs carrying multiple disruptor features at once. For most of them the finding is not a surprise awaiting discovery; it is a known property that the grading system now prices with the market itself.

The obligation this creates in the present tense is assessment honesty: know which lines are below the line while redesign, reformulation or exit are still choices.

Below-C lines divide into two kinds. The redesign kind: the product can be carried by a different structure - a mono-material pouch, a separable format, a different barrier technology - and the work is engineering and validation, typically with shelf-life and performance testing as the long pole. The business-model kind: the product's economics depend on the format (certain portion, convenience and composite-heavy formats), and no compliant structure carries it at a viable price. The two kinds need different rooms: the first belongs to packaging engineering with a deadline; the second belongs to portfolio strategy, where the options are price restructuring, format migration of the brand's offer, or managed exit from the line. Confusing them - sending a business-model problem to engineering, or a redesign problem to strategy - wastes the runway both need.

Small formats deserve separate mention because their failure is geometric, not chemical: below certain dimensions, sorting equipment loses items to the fines fraction regardless of material virtue. Sachets, miniature portions, small caps and seals live here - several also appear in the Annex V restriction lists, where the legislator reached the same conclusion by a different route. Design responses are format-level: attaching small components to the main unit so they travel with it, consolidating portions, or migrating the offer to a format above the capture threshold. A material change alone, however virtuous, does not cure a geometry failure, and assessments should say so in those words.

The prohibition attaches to placing from the grading date, so the transition logic of the timeline station applies: stock lawfully placed before the date is not recalled by it, and unplaced stock of a below-C line at the date is a stranded asset. Production planning for a line without a compliant successor should therefore run the stock curve against the date explicitly - last production, last placing, channel sell-through - rather than discovering the stranding in the warehouse. Where a redesign is in flight, the same curve sets its real deadline: not the legal date, but the last date a compliant unit can be in the channel before the old stock must stop being placed.

The years to 2030 are the innovation window the prohibition deliberately creates: barrier coatings that release, mono-material high-barrier films, fibre-based structures with functional layers thin enough for the paper stream, and chemical recycling routes whose outputs the criteria may credit for otherwise unrecyclable structures. None of these should be planned as certainties; the assessment must be run on the design as it will be placed, under the criteria as adopted. But research portfolios aimed at below-C lines are rational in a way they were not before the regulation, because the prohibition gives a successful redesign a guaranteed market: every competitor with the same problem becomes a customer or a licence opportunity. The end of the line for some formats is, for the industry, a starting line.