On 31 August 2022, the ZSVR (Central Packaging Register Office), in accordance with the German UBA (Federal Environment Agency), has published the annual new edition of the "Minimum Standard for the Assessment of the Recyclability of Packaging subject to System Participation pursuant to Section 21 (3) of the German Packaging Act", in short the "Minimum Standard".
As in previous years, the document has been updated in line with developments in collecting, sorting and recovery technologies.
Among the various innovations, one topic in particular attracted a lot of attention and queries from customers. In Annex 3 on page 32 an exception rule can be found regarding the recycling incompatibility of polyamide (PA) in the fraction "film and LDPE".
PA layers in films cause a category 3 recycling incompatibility. This leads to a recyclability rate of zero percent. The exemption: "polyamide-6 or co-polyamide 6/6.6 in coextruded PE/PA films without EVOH in combination with a MAH-grafted PE as bonding agent in a ratio of at least 0.5 g agent per g PA" explicitly refers to this combination.
(Source: ZSVR Mindeststandard of 31. 08. 2022, page 32)
A possible application for which the exeption rule could apply is, for example, a non-printed vacuum bag. In specific terms, the following ratings result according to the minimum standard:
Applies to co-extruded PA/PE with up to 30 % PA and at least 15 % bonding agent (BA) (Although the foil structure must be recognised as PE by an NIR scanner in a sorting plant. Deviations can occur here depending on the composition.) To achieve a rating of over 70 %, the use of at least 4.5 % of a suitable compatibiliser is also necessary.
Therefore, the following applies to most PA/PE combinations on the market:
Applies to PE-BA-PA-EVOH-PA-BA-PE, coextruded -> Due to the combination of PA and EVOH
Applies to BOPA/PE, laminated -> For the exemption it is absolutely necessary that the coex solutions are not laminated, in which the layer of the bonding agent has a direct contact with the PA. Only then there is a high probability that the MAH will react with the amide groups of the PA.
In the course of a study conducted by the cyclos HTP institute, it has been shown that PA in combination with specially modified PE (MAH-grafted) provides an upgrading to the resulting recyclates during the recycling process. However, this effect only occurs under the conditions mentioned.
Most commercially available PA/PE packaging is still considered non-recyclable. Any application that is laminated with a print carrier film or contains an EVOH barrier does not fall under the exemption of the 2022 Minimum Standard.
Should you be furtherly interested in implementing Design for Recycling solutions of practical relevance, our contact persons for your product markets are at your disposal.