EU PPWR FAQs Updated August 2026 - Flipbook - Page 65
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RETURN AND COLLECTION SYSTEMS
1) How will priority access for recycled materials work in practice?
Collection systems and recycling facilities may provide priority access to recycled materials for
use in applications where the distinct quality of the recycled material is preserved or recovered in
such a way that it can be recycled further and used in the same way and for a similar application
with minimal loss of quantity, quality or function (Article 48(2) PPWR).
The objective of this provision is to help economic operators comply with their recycled content
requirements for plastic packaging under the PPWR. Therefore, Member States may establish such
systems with regards to plastic packaging.
If such systems are established, priority access to the plastic recycled materials should be granted
at market prices. The quantity of recyclates to which priority access is given should correspond to
the quantity of packaging made available on the territory of the Member State by the economic
operator within a specified timeframe. It is Member States who decide to establish such priority
access systems must ensure that these conditions are complied with and monitored and shall notify
such systems via TRIS.
2) What does it mean that packaging is separately collected?
Separate collection is defined in the WFD as 8the collection where a waste stream is kept separately
by type and nature so as to facilitate a specific treatment9. Member States must ensure that systems
and infrastructure are set up to provide for the separate collection of packaging waste in accordance
with the waste hierarchy, and to facilitate its preparation for re-use and high-quality recycling. More
generally, Member States must ensure that the collection of the packaging materials is sufficient to
achieve the recycling targets laid down in Article 52 and they must establish mandatory collection
objectives for this purpose.
The requirements for separate collection vary. For example, separate collection of single-use
beverage packaging of plastic and aluminium in Article 50 refers to collection in a deposit and
return system.
Calculation and reporting requirements for separate collection for the purpose of complying with
the separate collection requirement under Article 50(1), and for the purpose of establishing the 8at
scale9 methodology, will be specified in an implementing act to be adopted by 12 February 2027
under Article 56(7).
3) How is composite packaging accounted for in the calculation of recycling targets?
According to Article 53(3), Member States must calculate recycling targets for composite
packaging based on all materials contained in the packaging unit. Pursuant to Article 53(4),
Member States may derogate from this requirement where a given material constitutes an
insignificant part of the packaging unit, and in no case more than 5% of the total mass of the
packaging unit. The 5 % threshold applies to the total mass of the packaging unit.
4) Are the terms 8ferrous metal9, 8ferrous metal (including tinplate)9 and 8steel9 all
synonymous for 8ferrous metal including tinplate9?
The terms 8ferrous metal (including tinplate)9 is used in the PPWR only in the context of Member
States9 reporting on reusable packaging. It is also referred in Table 1 of Annex II regarding materials
and formats for which DfR criteria will be established.
In the interest of coherence, the terms 8steel9 in Table 3 of Annex XII and the term 8ferrous metals9
used in Article 52(1)(b) and (d), and in Table 1 of Annex XII, also include tinplate.
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