The phrase “packaging is recyclable” is too general to form the basis of a decision. The result depends on materials, components, joins, labels, product residue and the applicable assessment criteria. A company should first build a controlled description of the design, and only then apply the current methods and classifications.
Describe the packaging as a construction
The name “PET bottle” does not cover the cap, label, adhesive, colourant, barrier and product residue. Each component can influence behaviour in the sorting and recycling process. The record should maintain the hierarchy and relationships between elements.
For a component, it is worth recording the material, mass, share of the whole, colour, separability, method of joining, supplier and specification. Data should have a unit, method and source. A value copied from a message without identification of the packaging version is difficult to use.
Input data
Preparation for the assessment may require:
- a drawing and component list,
- materials and additives,
- masses and tolerances,
- information on adhesives, prints and coatings,
- method of emptying and product residue,
- dimensions and format,
- separability of elements,
- barriers used,
- the market and collection system adopted in the analysis,
- test reports or external assessments.
The scope depends on the construction and the applicable method. The system should not force fictitious values when the data are not yet known. Missing data should be recorded and assigned for completion.
Source and quality of evidence
Not every document has the same value. A material specification, test report, technical data sheet and marketing statement answer different questions. For each piece of evidence, it is necessary to specify what it concerns, who issued it, when, for which sample and what limitations it has.
Receipt of a document does not end the work. The assessor checks the consistency of the model, method, date and scope. The result may be: accepted, partly usable, requires clarification or rejected. The mere status of a file as “added” cannot increase readiness.
Criteria change over time
The PPWR provides for the development of detailed rules. The result should therefore indicate the version of the criteria and the date of assessment. A single value of “recyclable: yes” should not be recorded without a basis.
When a new method or a change of threshold appears, the system should indicate packaging assessed under the previous version. A reassessment creates a new revision and does not remove the previous result.
Design scenarios
If a component lowers the score, the team may create variants: a different label, adhesive, colour, barrier or material. Each variant should have its own component list, parameters, evidence and result. This makes it possible to compare the actual consequences, not only a description of the idea.
The design decision also takes into account the protective function, product safety, durability, production process and supplier availability. Improving one parameter should not worsen other requirements without an informed assessment.
Packaging families
A joint assessment may be considered for packaging with controlled similarities, but the scope of the family must be described. A different colour, label format or barrier thickness may be relevant. Limit parameters and excluded variants should be specified.
The shared evidence should indicate the family, not only an example SKU. Where a new variant falls outside the conditions, the system should require a separate review.
Change of supplier
A material with the same trade name does not always have identical parameters. A change of supplier should trigger a comparison of specifications, additives, colour, mass and documents. The decision to retain the result requires justification.
If packaging is produced at several plants, it is worth maintaining sources for each of them and knowing which batches used a given specification. This facilitates assessment of a problem limited to a specific delivery.
Link to technical documentation
The description of the construction, sources, method and result should be included in controlled documentation. A declaration or statement cannot be detached from the material on which it is based. A change to a significant component triggers a review of related documents.
The history should retain the person performing the assessment, the date, the version of the criteria, assumptions and unresolved questions. This means that the next person does not have to reconstruct the process from file names.
Marketing communication
Environmental claims require separate caution. An internal working result should not automatically appear on a label or website. Before publication, the scope, conditions, currency and wording of the statement must be checked.
The system may store the relationship between the technical assessment and the approved claim. If the basis changes, the statement should receive a status for re-verification.
Most common errors
- describing the whole packaging by the name of the main material,
- missing masses and auxiliary components,
- a value without a method and source,
- accepting a marketing declaration as a technical result,
- a result without a version of the criteria,
- unjustified extension of the assessment to a packaging family,
- no review after a change of supplier,
- automatic use of the result in customer communication.
GPSR / PPWR organises the construction, data, evidence, variants and revisions. It does not automatically confer a recycling class or replace the applicable method. It provides material that can be verified, updated and linked to the design decision.