Minimum Standard 2026: What Changes in Packaging Assessment

How effectively can packaging actually be recycled? To provide a consistent basis for answering this question, the Central Agency Packaging Register (ZSVR) and the German Environment Agency (UBA) publish the minimum standard. It considers how packaging is designed and the proportion of valuable material that can be recovered through sorting and recovery processes. The minimum standard is updated annually, and the latest revision was published recently.

According to the ZSVR, the new edition of the minimum standard is primarily intended to make packaging recyclability easier to determine. “In 2026, we wanted to further develop the technical content of the minimum standard and simplify its application for companies,” emphasises Dr Bettina Sunderdiek, Head of Communications and Press at the ZSVR. While the methodology remains unchanged, design parameters have been added or differentiated more precisely, provisions producing the same assessment result have been consolidated, and practical experience from the expert panel and various stakeholders has been incorporated.

“The more substantial structural revision in preparation for the European Packaging and Packaging Waste Regulation, the PPWR, took place last year. The latest changes include an adjustment to the definition of composite packaging and a more consistent distinction between the three categories of paper packaging, liquid packaging cartons and predominantly paper-based composite packaging,” adds Julian Thielen of Innoform Coaching, a training provider specialising in packaging. “The annexes list fibre components individually and describe various packaging characteristics in greater detail. This makes it easier to assign a specific item of packaging to the appropriate category.”

Practical Experience Informs the Revision

The minimum standard underwent a fundamental revision in 2025, with the aim of making it more relevant to manufacturers and the packaging industry. “This increased the demands on how the rules were presented and understood, as well as on their practical application. In the 2026 revision, we therefore focused particularly on the experience and feedback of these new users,” says Sunderdiek.

According to Sunderdiek, Forum Rezyklat provided important technical input. Its preparatory work and experience of the requirements of manufacturers and the packaging industry supported several aspects of the revision. “Through the established expert panel and additional working groups, we were able to bring together different perspectives and reconcile technical requirements with users’ practical needs. The result is more precise and understandable provisions that are easier to apply in practice,” says Sunderdiek.

The packaging and recycling industries also submitted editorial comments and suggestions for additions to the annexes during the 2026 consultation process. “We carefully examined every comment and took it into account where it made the minimum standard clearer and easier to apply,” Sunderdiek explains.

Dr Joachim Christiani of the cyclos-htp Institute also highlights the data underpinning the requirements: “From the outset, the minimum standard was guided by sorting and recovery practices, as required by the Packaging Act, and the UBA now collects quantitative data on their status annually.” The capabilities and limitations of recycling in practice are taken into account when formulating packaging design requirements.

Christiani highlights the simplified assessment of hot-melt adhesives: “In addition, advances in knowledge have enabled the assessment rules for hot-melt applications in paper packaging to be significantly simplified.”

The procedure for testing the light transmission of glass packaging has also changed. Christiani explains: “Another important technical change concerns the DfR criterion ‘optical transmission’ for glass packaging; the absolute threshold has been removed and the method changed to a comparative measurement.”

According to Thielen, further distinctions concern, for example, PVOH coatings on certain PET packaging. “The specific packaging structure therefore remains decisive,” says Thielen.

Recyclability: The Recoverable Material Content Is Decisive

According to the minimum standard, packaging recyclability is determined not by what appears theoretically recyclable, but by the proportion that can actually be recovered as valuable material during recycling. “The paper or plastic content alone does not provide a complete result. What matters is the proportion of valuable material that can be recovered through the respective recycling route and any losses or incompatibilities that occur,” Thielen explains. Equally important is the question of what exactly is being assessed. As a general rule, the minimum standard considers the entire packaging, including its integrated components. “The fact that a component can be removed by hand is not sufficient on its own to justify a separate assessment,” says Thielen. The current revision also requires a clear understanding of the yellow category: “conditionally compatible” does not automatically mean “countable as valuable material”.

As the ZSVR emphasises, the uniform assessment method is intended to prevent individual materials from being favoured or disadvantaged.

Differences between materials are taken into account through the respective design parameters and actual sorting and recovery practices, Sunderdiek explains. The method also accommodates new materials and material combinations, provided their recyclability is demonstrated accordingly.

PPWR: Clarity Needed on the Assessment of Recycling Infrastructure

Christiani also sees the minimum standard as a tool for improving packaging design: the assessment method reveals the causes of qualitative and quantitative shortcomings. He therefore sees the main need for further action in the economic framework: “There is therefore no need for revised or additional standards, but simply for the implementation of effective, competitively neutral economic incentive schemes to initiate or accelerate the transition to recycling-friendly packaging solutions.”

For the next revision, Thielen primarily wants early clarity on how existing recycling infrastructure will be assessed at European level. This particularly concerns “recyclability at scale”, for example for small-format PP films and PET trays.

These types of packaging are already well covered by the minimum standard. However, their future assessment at European level remains insufficiently clear. “The minimum standard and the requirements of the PPWR should be aligned as early as possible,” Thielen urges.

For companies, this is a matter of planning certainty: “Companies are making decisions about packaging structures and investing in their development today. To do so, they need reliable guidance on how existing sorting and recycling infrastructure will be taken into account in future and what this means for their packaging.”

Christiani is also looking ahead to the European requirements: “Next year, the draft delegated act under Article 6 of the PPWR will be at the centre of technical and political discussions.” When the minimum standard is updated in 2027, its categories for recycling-friendly packaging design may need to be adapted to the future European method for determining recyclability performance grades. According to Christiani, this is also about “representing the interests of those companies that have already optimised their packaging according to objective criteria”.