Companies that put packaging on the market that disrupts the current sorting and recycling scenarios risk falling under the highest Green Dot rate for obstructive or discouraged packaging. At the start of this year, a second version of the list of obstructive or discouraged packaging was published by the IRPC. Time for an update.
The Green Dot: more than a logo
Companies that put packaged products on the market are obliged to ensure take-back and recycling. Most companies join the Fost Plus collective system, which relieves them of this task. However, they still pay the actual costs linked to the selective collecting, sorting and recycling per material. This is the so-called Green Dot. The more difficult the material or the packaging is to recycle, the higher the rate paid by the company. In other words, the Green Dot directs companies towards packaging that is in line with our sorting and recycling scenarios.
The Green Dot logo on packaging means that the manufacturer in question is affiliated to Fost Plus.
Obstructive or discouraged packaging
Packaging that hampers collection, sorting and/or recycling may be subject to a dissuasive Green Dot rate. The goal is to encourage companies to avoid such packaging as much as possible. However, switching to a different packaging takes time. So the Interregional Packaging Commission (IRPC) approved a temporary exemption for three packaging types as a transitional rule when the first list was published in 2020.
- Plastic bottles at least 70% of which is covered by a sleeve (or 50% for bottles <50cl), if this consists of a different material than the bottle and is not perforated.
- Laminated plastic packaging with aluminium film (for juice pouches, fruit and vegetables, ready meals, hygiene and cleaning products, animal food and wine bags).
- Laminated cardboard packaging for crisps and milk powder with metal or plastic tops or bottoms.
Since the start of this year, however, the companies concerned must be able to prove that they are taking the necessary steps to eliminate the obstructive packaging from their range. Fost Plus follows this process closely with them.
For plastic cans with a metal top or bottom and oxo-degradable packaging, however, the dissuasive rate applies immediately. Moreover, such packaging is banned by the EU and is consequently hardly ever found on the market.
The IRPC published a second list of obstructive or discouraged packaging in February. In addition to laminated aluminium-plastic packaging, which now also includes coffee and breakfast cereals, the following fall under this heading:
- Black plastic packaging coloured with carbon black
- Black glass bottles coloured all through
- Biodegradable and compostable plastic packaging
- Laminated paper bags with an aluminium liner for soups and powdered sauces
- Paper-cardboard packaging with plastic coatings on all sides.
As of 2024 (declaration year 2025), members who put this sort of packaging on the market fall under the rate for obstructive or discouraged packaging, which may be up to 3,000% higher than their current rate. In accordance with its accreditation, Fost Plus can again request a temporary exemption with a view to total regularisation by the end of 2025. Companies must, however, be able to demonstrate their transition plans.
The more difficult a material is to recycle, the higher the rate paid by the company. In other words, the Green Dot directs companies towards packaging that is in line with our sorting and recycling scenarios.
Active cooperation with members
Fost Plus aims to offer a recycling solution for every type of household packaging on the market. Currently, this is not yet the case for around 2% of packaging. Fost Plus is working with these companies to find ways of including the recycling of the packaging right from the design phase. This is known as Design for Recycling. It means, for example, that for complex packaging consisting of several materials, a switch will be made to a mono material or the sleeve around a product will have perforations so that consumers can remove it themselves and sort the two parts properly. This way, we ensure that there is a recycling solution for the last remaining packaging types.
Download the Design for Recycling guidelines
It is advisable for companies that bring new packaging onto the market to check that it is suitable for the recycling process. There are five main issues:
- Give preference to mono materials and single layers.
- Ensure that the material can be properly detected in the sorting centres.
- Avoid a double coating on cardboard packaging because in this case, the paper fibres cannot be recovered.
- Compostable (biodegradable) packaging cannot be put with the PMD or the organic waste.
- Beware of labels and handles and the adhesives and inks that they use.
Would you like to know more? Find out about the Design for Recycling guidelines in detail in this presentation. Do you have any questions or a specific packaging query? Contact our packaging experts.