GDR 2: Remove Problematic Elements from Packaging

  1. No undetectable1 carbon black2
  2. No PVC or PVDC2,3
  3. No EPS or PS2
  4. No PETG in rigid plastic packaging2,3
  5. No oxo-degradable4

Undetectable carbon black is undetectable in the sorting process when using Near Infra-Red (NIR) technology, which is widely used in plastics recycling systems. As a result, dark-coloured packaging commonly ends up as residue and is disposed of in landfill or incineration. It is commonly used in meat and vegetable trays and bottles. As well as minimising avoidable environmental impacts, removing carbon black would help increase the volume of recycled plastic.

PVC or PVDC is polyvinylidene chloride or polyvinylidene dichloride. It can be problematic if in the recycling stream by disrupting the recycling of some other plastics. It is found in several types of plastic packaging, including meat trays, plastic film around vegetables or blister packs.

EPS or PS is expanded polystyrene or polystyrene. (E)PS is too uncommon for the packaging materials stream to make recycling economically viable. As a result, it is rarely sorted from household waste and recycled, with the majority of it incinerated or landfilled. Examples of its application are food takeaway containers, yoghurt pots, and cushioning/filler. This element of Golden Design Rule 2 excludes other types of polystyrene such as SAN or ABS.

PETG is polyethylene terephthalate glyco, and is a contaminant in the PET recycling stream which lowers the value of recycled PET materials. It is found in, for example, drinking bottles and cooking oil containers. This element applies to all single-use rigid packaging materials in the consumer goods market.

Finally, oxo-degradable plastics contribute to microplastic pollution and are not suited for long-term reuse, recycling at scale or composting. Uses include shrink and stretch film, carrier bags, blister packs, bottles, labels and caps. This element of Golden Design Rule 2 applies to all oxo-degradable plastics as defined by CEN, the European Standards authority, unless use is required by law.

Read more detail in the Resources section of this website.


According to the Ellen MacArthur Foundation, these problematic elements are present in over 10% of plastic packaging.


1) Undetectable means by commonly used sortation technologies; 2) Exception: This rule does not apply to small non-recyclable packs; 3) Exception: Except in medical applications where there is no alternative; 4) Exception: Except where legally required; “This rule does not apply to oxo-biodegradable plastics”