FAQ's Recycle Checks
What is the Recycle Check?
The Recycle Check helps companies assess how recyclable a packaging design is within the current Dutch collection, sorting and recycling system. From 2027 onwards, Recycle Checks will only be available for rigid and flexible plastic packaging.
What can I use the Recycle Check for?
You can use the Recycle Check 2027 to determine whether a rigid or flexible plastic packaging qualifies for a discount on the Waste Management Contribution (Fee Modulation). The Recycle Check provides insight into the recyclability of a packaging within the Dutch system.
Is the Recycle Check a legal assessment?
No. The Recycle Check is a practical assessment tool. However, it can be used to support recyclability claims in a packaging file as part of the Essential Requirements. Please note that Recycle Checks only apply to the year for which they were developed and may not reflect the state of the art in other years. Therefore, do not use an older Recycle Check to assess the recyclability of a packaging in 2027. For transparency reasons, Recycle Checks from previous years will remain available.
Why has the Recycle Check been revised?
With the introduction of the PPWR (Packaging and Packaging Waste Regulation), Europe is moving towards a single framework for assessing packaging recyclability, with the same requirements applying across all member states. For this reason, no new Recycle Checks will be published, except for rigid and flexible plastics.
Read more about the changes here.
What are the main changes in the Recycle Check 2027?
The most important changes are:
- The definition of recyclability aligns more closely with the PPWR.
- The criterion of "recycling at industrial scale" is no longer taken into account for the time being.
- The colours used for the assessment outcomes have been updated.
- A PFAS-related design tip has been added.
- For rigid plastics, greater attention is paid to substances that may lead to the formation of hazardous substances such as benzene, formaldehyde and BPA.
- For flexible plastics, PP, SiOx/AlOx barriers and EVOH can receive higher scores under certain conditions.
Why do some packaging formats receive a higher score than before?
Because the criterion "recycling at industrial scale" is no longer taken into account for the time being, packaging that is technically highly recyclable may receive a higher rating than before. This particularly applies to flexible PP packaging.
Does a higher rating mean that a packaging is actually being recycled more?
Not necessarily. The rating indicates how recyclable a packaging is according to the Recycle Check methodology. It does not guarantee that the packaging is actually collected, sorted and recycled.
What do the ratings mean?
The Recycle Check has four possible outcomes:
- Highly recyclable
- Reasonably recyclable
- Limited recyclability
- Not recyclable
The first three categories all indicate that a packaging is recyclable; the difference lies in the degree of recyclability.
Read more about the ratings.
Why were the colours changed?
User feedback showed that it was not always clear that "highly recyclable", "reasonably recyclable" and "limited recyclability" all refer to packaging that is recyclable. The new colour scheme makes this distinction clearer.
Can packaging rated as "limited recyclability" still be recyclable?
Yes. A rating of "limited recyclability" means that the packaging is recyclable, but there are limitations that affect the quality or efficiency of recycling. To qualify for a Fee Modulation discount, a plastic packaging must be rated as highly recyclable.
Does the Recycle Check affect the discount I can receive through Fee Modulation?
Yes. For rigid and flexible plastic packaging, a rating of "highly recyclable" can be used when applying for a discount on the Waste Management Contribution through Fee Modulation.
Does a higher rating automatically change my fee?
Not automatically. Fee Modulation has its own conditions and procedures. The Recycle Check is one of the determining elements.
Is the Recycle Check the same as the future PPWR assessment?
No. In early 2028, the European Commission will publish the final European Design for Recycling guidelines for packaging. From 2030 onwards, a European classification system will determine how recyclable packaging is under the PPWR. For now, the Recycle Check remains based on the Dutch situation.
If my packaging scores well in the Recycle Check, can I assume it will comply with the PPWR?
Not automatically. However, packaging that scores well in the Recycle Check 2027 is often already well prepared for future European requirements. Ultimately, compliance will be determined based on the final European guidelines.
What is the difference between the Recycle Check and the No Regrets Playbook?
The Recycle Check assesses recyclability within today's Dutch recycling system. The No Regrets Playbook looks ahead and focuses on future European Design for Recycling principles under the PPWR.
Which tool should I use?
That depends on your objective:
- Do you want to apply for a Fee Modulation discount? Use the Recycle Check.
- Do you want to know which packaging design choices are likely to be future-proof under the PPWR? Use the No Regrets Playbook.
Together, both tools provide insight into both the current and future situation.
Are the recommendations in the No Regrets Playbook aligned with the Recycle Check?
For design choices identified as "no regret", it can be assumed that they are not inconsistent with the current principles of the Recycle Check.
How is the Recycle Check developed?
Each year, information is collected from across the value chain, including input from sorters, recyclers, producers, retailers, monitoring data and practical studies. Proposed changes are then reviewed by experts, the Independent Expert Committee and the Verpact Board.
Why can the Recycle Check change from year to year?
The packaging value chain is constantly evolving. New recycling technologies, changing market conditions, monitoring results and legislation may lead to updates in the assessment criteria.
I disagree with a rating. What can I do?
Consult the background information and protocols that accompany the relevant Recycle Check. These explain the rationale behind the assessment. If you still disagree, please contact Verpact via the contact form.
Where can I find more information?
More information is available through the Recycle Check documentation, protocols, glossary, Verpact’s PPWR page and the No Regrets Playbook.
New Role of the Recycle Check 2027
Why is Verpact discontinuing some Recycle Checks?
With the introduction of the PPWR, Europe is moving towards a harmonised framework for assessing packaging recyclability. Therefore, no new Recycle Checks will be published except for rigid and flexible plastics. The Recycle Check 2027 can only be used to determine eligibility for a Fee Modulation discount in 2027. For other materials, the knowledge remains available.
Why do the plastic Recycle Checks remain available?
Because they are used to determine eligibility for Fee Modulation discounts and therefore have a direct implementation function.
Why are the Recycle Checks for glass, metal, paper and beverage cartons being discontinued?
Because these materials are not directly linked to Fee Modulation discounts. The knowledge built up over the years will be retained and actively contributed to European discussions. As more clarity emerges from Europe, new support tools will be developed accordingly.
Does this mean these materials are no longer recyclable?
No. The knowledge built up over the years remains available and continues to support recyclability assessments and packaging innovation.
Will the knowledge from the Recycle Checks disappear?
No. The knowledge we have built up, and continue to build, is actively contributed to European discussions. As greater clarity emerges from Europe, we will provide support that aligns with those developments. We ensure that our tools always reflect the latest European legislation and regulations.
How can producers assess their packaging now?
Other organisations also offer tools that can help assess packaging recyclability. In addition, Verpact provides several tools that help assess packaging performance in other areas.
Will previous Recycle Checks remain available?
Yes. For transparency reasons, previously published Recycle Checks will remain available. Please note that Recycle Checks only apply to the year for which they were developed and may not reflect the state of the art in 2027. Therefore, older Recycle Checks should not be used to assess recyclability in 2027.
Why can I not use an older Recycle Check for 2027?
A Recycle Check is based on the knowledge available at the time it was developed. Insights, market conditions, recycling technologies and legislation continue to evolve. As a result, older Recycle Checks may no longer reflect the state of the art in 2027.