Clear limits are not just hurdles. They also convey a certain sense of security. Unconsciously, everyone assumes that "they" will have thought of something, and the willingness to scrutinise limit values is generally not particularly high. It goes without saying that the five per cent limit for foreign substances in waste paper was not created on a whim. However, the fact that it is so rarely scrutinised is astonishing.
Plastic can actually be a problem when recycling paper
First of all: limiting the proportion of foreign materials in the recycling of PPK fractions (paper, cardboard, carton) is not fundamentally wrong. And for several good reasons:
Recycling quality: Too much foreign matter reduces the quality of the recyclate and the efficiency of recycling.
Economy: Less foreign matter also means less effort is required to remove it. This reduces the costs for waste recyclers and at best even leads to lower disposal fees.
Technology: Too many foreign substances and also the wrong additives, adhesives and coatings can cause wear on pumps, sorting systems and other infrastructure in the recycling process; in the worst case, blockages can bring entire systems to a standstill.
Ecology: The lower the (visible) proportion of foreign matter, the more willing consumers are to throw PPK packaging in the blue bin. And higher recycling rates definitely help to protect the climate and conserve resources.
However, where the limit for the permitted proportion of foreign materials should lie is not set in stone. At least that is the hope.
The 5% limit is based on a "wish list" from the international Confederation of European Paper Industries (CEPI), which specifies how the recycling of fibre materials should be assessed in order to prove their recyclability. This also includes the upper limit for foreign materials, which was set at 5% years ago. The idea behind this: the less foreign matter, the better the output quality. However, this does not mean that the fibres cannot be recycled very well even with a higher proportion of foreign materials. For example, even with an 80-20 ratio with a thin film, the fibre can be recycled - i.e. recovered - very well. Conversely, a 98-2 ratio can make the fibre virtually non-recyclable if the 2% prevents the fibre from separating in water. This CEPI method is currently being updated and also distinguishes quite logically between different types and also between the technological status of different recycling plants. This is because not every recycler uses the same technology and therefore cannot map the same process steps.
Recycling packaging also has psychological components
It's certainly not down to the recycling technology, says Peter Désilets, Managing Director of Pacoon, an agency specialising in sustainable packaging concepts: "The technology for paper recycling has evolved in recent years because the waste paper streams have changed. Many new barriers are coming onto the market, some of which are very thin, water-soluble or contain other additives and colours." And they all have different effects on the recovered fibre: while the purity for office paper (graphic paper) should be very high so that no discolouration or "specks" (colour stains) can be seen in the paper, the quality requirement for corrugated cardboard is rather low. "It is therefore right that recyclability also adapts to the many new aspects," emphasises Désilets.
In fact, he believes that, paradoxically, a higher proportion of foreign materials could even promote the recycling of fibres: Films would be easier to separate from the paper content, which in turn would make it easier for recyclers to recycle accordingly. The current regulation, on the other hand, means that packaging engineers assume that the packaging must not end up in the blue bin if it contains the smallest amount of plastic because it cannot be recycled. This is why such packaging is often avoided. Similarly, German legislation via the Dual System stipulates that fibre packaging containing more than 5% must be disposed of in the "Yellow Bag" - where it is almost 100% likely to be incinerated. Beverage cartons are sorted and recycled separately from lightweight packaging due to their large quantities and special recycling processes.
A flaw in the system? Recyclability is not taken into account
Peter Désillet's conclusion: the five per cent figure is per se completely meaningless and arbitrary, as it is not based on the aspect of recyclability, but on the revenue side. As a result, paper-plastic composites are penalised in terms of costs in Germany's dual system: "This is a real flaw in the system. Composites with a higher proportion than five per cent are charged like pure plastic packaging. However, disposal via the waste paper cycle would offer significantly better recycling opportunities and also a much higher collection rate - as virtually every household has a waste paper bin at home. The dual system does not reward recyclability, but is busy financing itself."
This is another reason why it would make sense to move fibre composites in the direction of paper recycling: The corresponding collection infrastructure is much better developed than that for plastics, both in Germany and in many other countries in Europe. Even if the recycling technologies differ from country to country: The most common recycling plants for waste paper are available, and so are the bins.
What is recyclable? European patchwork in paper recycling
A look beyond Germany's borders also shows that the five per cent is anything but a natural constant. Very different limits apply in Europe. In Austria, for example, composites containing up to 20 per cent foreign matter are accepted as a PPK fraction and therefore approved for paper recycling. In other countries, the values are even higher, with France going as high as 49%. The technical infrastructure has survived in all these countries.
New paths to sustainable waste paper
Limit values for the proportion of foreign substances - whether five per cent or more - also have one major disadvantage: they do not take into account what exactly these substances actually are and therefore make it difficult to react quickly and flexibly to technological developments. And there are a lot of them.
Not every foreign substance is "plastic", not every barrier is harmful to recycling. There have long been environmentally friendly alternatives. Packaging and paper giant Sappi, for example, has put a new type of barrier coating system into operation on which different coating technologies can be used. New alternatives to non-recyclable packaging are also to be developed for the market together with customers.
Koehler Paper also invested hundreds of millions of euros years ago in a new paper plant for coated paper for food contact. The delfortgroup has developed many new solutions for food contact with fossil barriers, but is also conducting extensive research into bio-based barriers. The Minden-based Follmann Group has developed water-based coatings specifically for paper and cardboard packaging that form a barrier against oils, fats and water. The barriers are already being used in recyclable salad bowls.
Fraunhofer has also been working on this topic for a long time. The Fraunhofer Institute for Process Engineering and Packaging, for example, has used nanotechnologies to develop high-performance and cost-effective barrier films with a low carbon footprint for flexible packaging and encapsulation based on a single material. A research project is currently underway using bio-based coatings made from oak and beech cork, which aims to close a particular gap: While the available bio-based solutions are effective against water vapour or against oxygen, for example, a new biomaterial should cover all the necessary properties that food packaging requires.
There are already solutions for paper coffee cups that have a barrier of less than 5% and are over 90% recyclable. The same material could also be used for food packaging. But this is where the collection system in many European countries suffers. There are far too few paper bins in public areas, so the easily recyclable disposable cups end up in the residual waste and therefore in incineration. A good example of this is Sweden, where there are entire "batteries" of collection bins in Stockholm: for metals, aluminium, glass, paper, plastics and residual waste. The local authorities therefore also play a part in the fact that the circular economy only looks good on paper in Germany, but does not play a major role in everyday life.
Deutsche Bahn is actually playing a small pioneering role here. There are already separate collection bins for paper, residual waste and "packaging" in railway stations and trains. Separating at the source of the waste offers the basis for returning more packaging to the cycle and promoting recycling with just a small hurdle.
Which lower limits make sense
Until this changes with reusable containers and a widely established return and cleaning system, the current situation should be improved with simple adjustments. Peter Désilets also points out: "The PPWR, the Packaging and Packaging Waste Regulation, stipulates a recyclability of 70% for fibre-based packaging in most cases from 2030. From 2038, this will increase to 80%. These could also be the lower limits with which fibre-based packaging would have to prove its recyclability. Below this level, marketing would no longer be permitted in the EU from 2030."
Recycling, but the right way: Exciting discussions at Fachpack
However, the discussion about the 95-5 rule is now intensifying, and this, says Peter Désilets, is exactly what "we expressly welcome and have been calling for for years. This would also counteract the myth that fibre packaging with more than 5% or with film is not recyclable. The goal must be tested recyclability, and that is what the PPWR requires anyway. As recyclability decreases, the eco fee could also be adjusted to encourage the trend towards more recycled fibres."
A tool that the dual system in Germany has unfortunately been unable to get to grips with for decades because the system itself still prevents it. Here, too, an algorithm could help to make poorly recyclable plastics significantly more expensive and better packaging cheaper. But that's a topic for a separate blog. Here, the waste paper stream has the advantage that collection is controlled by the local authorities and they receive a levy from the dual system. A high recyclability of over 70% or 80% would already be standard for registration.
At FACHPACK 2025, Pacoon will once again be organising its SOLPACK 6.0 in cooperation with the trade fair at the Alternative Packaging Solutions Pavilion. On the stage in the centre of the special pavilion area, PSC will host a varied programme on all three days with the most important trend topics in the packaging industry. In 2024, over 2,000 participants listened to the presentations. The event will also address and present fibre-based packaging with new solutions and the discussion of the 95-5 rule.
"It's time we cut off a few old habits if we are serious about the circular economy. These include the lack of an eco-fee system for plastics and the 95-5 rule for fibre-based packaging," says Peter Désilets.