What PPWR changes for a transparent barrier pack
PPWR moves recyclability from a claim to a design requirement, and the assessment is made on the pack as it is placed on the EU market. For a clear barrier structure, the decision starts one step earlier — at the film.
Regulation · PPWR · 2 November 2026 · 6 min read
The short version
This note covers one obligation — design for recycling — and what it means for a converter building a transparent barrier pack. It is not legal advice: the annexes decide most structures, and the consolidated text counts.
1. What PPWR changes
PPWR is the EU regulation on packaging and packaging waste. It replaces Directive 94/62/EC and applies to packaging placed on the EU market. Being a regulation and not a directive, it applies directly in every member state: the same requirement is meant to reach the same pack.
The requirement to plan for now is design for recycling, applying from 2030. Check the consolidated text for the conditions, the phase-in and the annexes. A summary helps you budget time; it does not defend a claim.
Recyclability is a property of the pack, not of a material. A structure can be made entirely of recyclable polymers and still fail as a design, if the layers cannot be separated again at a recycler. The requirement asks about the finished structure — polymers, bonding, stream.
So we cannot give you a recyclable pack. We can give you a film with a known polymer stream, a known coating, and a document that states both. You choose the structure, and the structure is assessed. Reuse, producer fees and other design features are outside this note.
2. Why a transparent barrier pack is exposed
A transparent barrier pack carries its barrier in a very thin layer: AlOx on BOPP or PET, or a metallized layer on PE. Measured in nanometres, the layer is a fraction of the gauge. The polymer decides the stream. The layer decides whether the pack can stay in it.
The useful question is not "is this film recyclable?" but what the pack becomes at a sorting line. A mono-material polyolefin structure usually passes — that is what it is designed for. A multi-polymer structure depends on its layers, and no film choice repairs it later.
Our three films sit in different places, and we state them plainly:
- ALOX BOPP — AlOx-coated BOPP, 18 µm, two grades: A prints and laminates, B laminates only. The polymer is PP; the pack is a PP structure.
- Metallized PE — VMCPE, a sealant grade metallized on one face, and VMNCPE, a barrier core without a seal layer. The polymer is PE; the pack is a PE structure.
- ALOX PET — AlOx-coated PET, 12.0–12.5 µm, ten grades. PET is a different stream. We do not present it as a mono-material polyolefin film, because it is not one.
A clear pack adds one pressure: the product sells itself, so a brand owner will not add an opaque layer to settle a recyclability question. The load moves to the barrier layer, the adhesive and the sealant.
3. The three documents to have ready
Before a brand owner agrees a structure, three documents are asked for: the technical data sheet, the food-contact position and a recyclability statement. None of them says a pack is recyclable.
Technical data sheet. Grade, gauge, construction, test methods and conditions, conversion notes. Ours is per grade, with method and condition beside each figure. A barrier number without its condition cannot be compared.
Food-contact position. FDA compliance for the grade, and a migration test report to EU 10/2011 on request. This is a film-level document: it describes the film as supplied, not the finished pack. If the pack is placed on the market, the compliance file is yours — adhesive, ink and sealant included.
Recyclability statement. The polymer stream the film is designed for, what the coating is, how much of the gauge it accounts for, and what a converter has to keep out of the structure for the statement to hold. A converter's input, not a clearance for a pack.
What is not on the list: a certificate that a pack is recyclable. That is written for a structure, by whoever assesses it, against the criteria in force at the time — and the criteria are still moving.
4. Claims to stop making
Stop making any recyclability claim that does not name the stream, the market and the assessment behind it. "100% recyclable" goes first: it is a statement about collection and reprocessing as much as about material.
- "100% recyclable" or a recycling logo on a pack that has not been assessed for the market where it sells.
- "Mono-material" for a structure with two polymers in it. PET film plus a PE sealant is not mono-material, and the word invites a question you cannot answer.
- "PPWR compliant" on a film data sheet. Compliance is assessed on the pack, against the criteria and the dates that apply to it.
- A sentence copied from a supplier's statement into your packaging specification. The sentence changes owner when you copy it.
- Recycling percentages with no measurement behind them. If it is a target, write "target".
What to write instead: the polymer stream the pack is designed for, the layer that carries the barrier, and the statement behind the film. A short claim with a document survives procurement review. And infrastructure counts: a structure designed for a stream your customer's country does not collect is not recyclable in practice.
5. What to ask your film supplier
Ask five questions before the structure is frozen. The answers decide whether the barrier layer is a detail or a problem.
- Which polymer stream is this film designed for — and what would take the pack out of it? Ours: PP for ALOX BOPP, PE for metallized PE, PET for ALOX PET. Inks, adhesives and sealants of another polymer are where a structure leaves the stream.
- What is the coating, and how much of the gauge is it? AlOx is an oxide layer on one face; the metallized layer is metal on one face. Neither is a second film.
- Which documents ship per lot, and which are per grade? The lot certificate belongs to the roll that ships. The data sheet, food-contact position and recyclability statement belong to the grade.
- What has to stay off the structure for that statement to hold? Adhesive, ink coverage, sealant polymer, and whether the barrier face is printed.
- What width and length can you ship, so the trial uses production material? We slit to requested width up to 3,000 mm, roll OD up to 440 mm, on Ø76 or Ø152 mm cores. Standard lengths: 6,000 m ALOX BOPP, 8,000 m ALOX PET, 3,700 m VMPE. Minimum order: one roll for AlOx film, one pallet for VMPE; A4 samples free.
Key facts
- PPWR is the EU regulation on packaging and packaging waste. It replaces Directive 94/62/EC and applies to packaging placed on the EU market.
- The recyclability design requirement applies from 2030. The consolidated text and its annexes decide how a structure is judged.
- Recyclability is assessed on the finished pack, not on the film.
- A transparent barrier film keeps its barrier in a nanometre-scale AlOx or metal layer on a polymer web. The polymer decides the stream.
- ALOX PET is a PET film. We do not present it as a mono-material polyolefin structure.
- The documents that answer the question: data sheet, food-contact position, recyclability statement, lot certificate.
Read next, or ask the question
If you are choosing a barrier film for a pack that has to survive a recyclability review, start with the structure. We will tell you what our film does and does not settle.