GOLDEN DESIGN RULES

For optimal plastic design, production and recycling

Demonstrating leadership in the progress towards a circular economy, members of the CGF Plastic Waste Coalition of Action have aligned
on Golden Design Rules for packaging design to increase the circularity of their packaging portfolios where appropriate. This set of
voluntary, independent and time-bound commitments which together reach over 90% of plastic packaging available on the market will
create significant value for the industry and wider system. For more information about the Coalition, visit www.tcgfplasticwaste.com.

1
GOLDEN DESIGN RULE
Increase Value in PET Recycling
• Use transparent and uncoloured PET (preferred), or transparent blue or green in all PET bottles1, 2
• Ensure material choice, adhesive choice and size of sleeve or label is not problematic for recycling3, 4, 5

PET is polyethylene terephthalate, one of the most common-

ly used plastic materials. This Golden Design Rule applies to
all PET bottles in food and non-food applications, including
THE SCALE
beverages, home care products, personal care products, and PET bottles represent 13% of plastic packaging
more. Switching from coloured to transparent PET bottles on the market, according to data from Plastics
will positively impact supply of high quality recycled PET, and Europe and Eunomia.
helps ensure only materials that have a viable closed loop
recycling pathway are used.

1) With a minimum L value of 40; 2) Exception: Where barrier protections (for UV light, CO2, or O2) are required for product shelf life and other solutions (e.g., full-body
sleeves) are not possible; 3) Including phase out of PETG and PLA labels/sleeves, non-water soluble/dispersible adhesives and sleeves that cover more than 75% of
bottle (unless proven not to limit the recyclability of the product); 4) Exception: Unless proven not to limit the recyclability of the product (e.g. cPET, sleeves that detach
during recycling processes prior to optical sorting); 5) Exception: Small non-recyclable bottles exempt

2
GOLDEN DESIGN RULE
Remove Problematic Elements from Packaging
a. No undetectable1 carbon black2
b. No PVC or PVDC2, 3
c. No EPS or PS2
d. No PETG in rigid plastic packaging2, 3
e. No oxo-degradable4

Undetectable carbon black is undetectable in the sorting PETG is polyethylene terephthalate, and is a contaminant in
process when using Near Infra-Red (NIR) technology, which the PET recycling stream which lowers the value of recycled
is widely used in plastics recycling systems. As a result, PET materials. It is found in, for example, drinking bottles and
dark-coloured packaging commonly ends up as residue and cooking oil containers. This element applies to all single-use
is disposed of in landfill or incineration. It is commonly used in rigid packaging materials in the consumer goods market.
meat and vegetable trays and bottles. As well as minimising
avoidable environmental impacts, removing carbon black Finally, oxo-degradable plastics contribute to microplastic
would help increase the volume of recycled plastic. pollution and are not suited for long-term reuse, recycling
at scale or composting. Uses include shrink and stretch film,
PVC or PVDC is polyvinylidene chloride or polyvinylidene carrier bags, blister packs, bottles, labels and caps. This ele-
dichloride. It can be problematic if in the recycling stream by ment of Golden Design Rule 2 applies to all oxo-degradable
disrupting the recycling of some other plastics. It is found in plastics as defined by CEN, the European Standards autho-
several types of plastic packaging, including meat trays, plas- rity, unless use is required by law.
tic film around vegetables or blister packs.

EPS or PS is expanded polystyrene or polystyrene. (E)PS

is too uncommon 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
THE SCALE
incinerated or landfilled. Examples of its application are food According to the Ellen MacArthur Foundation,
takeaway containers, yoghurt pots, and cushioning/filler. This
these problematic elements are present in over
element of Golden Design Rule 2 excludes other types of
polystyrene such as SAN or ABS.
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”

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3
GOLDEN DESIGN RULE
Eliminate Excess Headspace
• Eliminate excess headspace for all flexible pack types, such that the maximum headspace is
30% or less across the product categories outlined in the rule.

This Golden Design Rule applies to the following categories: cleaning products, confectionary, dry groceries, frozen foods &
ice-cream, health & wellness, personal & baby care, pet food, produce & fresh food, shelf stable foods, water & beverages. By
eliminating excess headspace in flexible packaging, companies reduce the demand for virgin plastic and reduce the absolute
amount of plastic being placed on to the market.

4
GOLDEN DESIGN RULE
Reduce Plastic Overwraps
• Reduce plastic overwraps by only using them when “necessary” (as defined by the developed
guideline)

This Golden Design Rule applies to the following categories:

• Food: confectionary, crisps and snacks, canned and tinned food, beverages.
• Non-food: home care, personal care, baby care

By removing unnecessary overwraps

overwraps,, companies reduce the demand for virgin plastic and reduce the absolute amount of
plastic being placed on to the market.

5
GOLDEN DESIGN RULE
Increase Recycling Value for PET Thermoformed Trays and Other
PET Thermoformed Packaging
For PET thermoformed trays and other PET thermoformed packaging:
1. Regional design guidelines to fit with existing recycling programs1 shall be met wherever possible.
2. For packaging that is not accepted by existing recycling programmes, and where there is a clear pathway
for a future recycling system by 2025², the following requirements apply:
A Use transparent and uncoloured (preferred), or transparent blue or green PET³
B Ensure material choice, adhesive choice, inks and size of sleeve or label is not problematic for
recycling⁴
C Use only mono-material PET⁵
D Use minimal or moderate direct printing⁶
E Ensure material choice and adhesive choice of lidding films, inserts or other components is not
problematic for recycling⁷

PET trays are not currently recycled at in practice and at

scale but solutions are being scaled-up in Europe and North
America – a rule to increase recyclability would provide a
THE SCALE
boost to emerging recycling infrastructure and increase the If adopted industry-wide, a rule on PET trays and
quantity and availability of rPET which is necessary to meet other thermoformed PET packaging would affect
targets around recycled content³ >3% of the total plastic packaging market.*
This rule is aligned with published retailer guidelines and
third-party guidelines such as APR, RecyClass / PetCore and
WRAP.

1) Recycling programmes are at different stages of development in different regions, so companies are recommended to check regional advice or guidelines such as
those provided by APR in the US. Signatories should use the exceptions reporting process to record cases where they have followed regional design guidelines instead
of the Golden Design Rules. 2) As accepted by industry associations and multi-stakeholder value-chain initiatives such as RecyClass/PetCore and Plastics Pacts and
targeting recycling rates of >30%. 3) With an L-value of 40; Do not use fillers that affect clarity; coatings should not lead to misdetection of the packaging and misdirection
to waste.
4) Including phase out of paper labels and PETG, PVC and PLA labels/sleeves, and non-water soluble/dispersible adhesives. Labels/sleeves should not lead to
misdetection of the packaging and misdirection to waste. 5) Including minimum 95% PET content with an intrinsic viscosity that is suitable for the recycling programme
in region. Do not use materials that have a negative impact on rPET clarity. 6) E.g. production date or expiry date; Where additional printing is necessary, use of labels is
preferred. If this is not possible, use only inks that do not bleed. 7 ) Lidding films, inserts and other components should not lead to the misdetection of the main packaging,
and if using non-PET polymers, density should be <1g/cm3.
*EMF New Plastics Economy Global Commitment Progress Report 2020

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6
GOLDEN DESIGN RULE
Increase Recycling Value in Flexible Consumer Packaging
For flexible consumer packaging made mostly from plastic1:
1. Regional design guidelines to fit with existing recycling programmes2 shall be met wherever
possible.
2. For packaging that is not accepted by existing recycling programs, and where there is a clear
pathway for a future recycling system by 20253, the following requirements apply:
A. Maximise polyolefin content:
B. Preferably >90% mono PE, or >90% mono PP
C. Minimum either >80% mono PE, >80% mono PP or >80% mixed polyolefins
D. Density <1 g/cm3
E. Each barrier layer should not exceed 5% of the total packaging structure weight4
F. No PVC, PVDC, fibres, aluminium foil, PET

Demand for flexible packaging is expected to increase with • ‘Made mostly from plastic’ defined as packaging made
increasing demand for convenience food and online retailing. from >50% plastic (i.e. where plastic is the predominant
material)
Consumer flexible plastic packaging is not currently recycled
in practice and at scale, however there are multiple efforts
underway to improve collection, sorting and recycling
systems to recycle flexible materials.

All consumer flexible packaging made mostly from plastic:

• ‘Consumer’ packaging is packaging likely to end up
THE SCALE
either in the household waste stream or disposed of by Flexible plastic packaging makes up an estimated
consumers during consumption outside the home 51% of the total plastic packaging market.*
• ‘Flexible’ packaging is packaging that does not keep its
shape when moved or emptied.

1 )‘Mostly from plastic’ defined as packaging which is > 50% plastic (based on EU recognised definition of a ‘predominant’ material). This rule does not cover compostable
plastic packaging that meets accepted certification standards for compostability.
2) Recycling programmes are at different stages of development in different regions, so companies are recommended to check regional advice or guidelines such as
those provided by APR in the US. Signatories should use the exceptions reporting process to record cases where they have followed regional design guidelines instead
of the Golden Design Rules.
3) As accepted by industry associations and multi-stakeholder value-chain initiatives such as CEFLEX and Plastics Pacts and targeting recycling rates of > 30%.
4) Only use barrier layers and barrier coatings proven not to limit the recyclability of the packaging. AlOx, SiOx, EVOH and PVOH are recommended. Excess outer me-
tallisation (as a barrier or for decoration) could lead to misdetection of the packaging and misdirection to waste.
*EMF New Plastics Economy Global Commitment Progress Report 2020

7
GOLDEN DESIGN RULE
Increase Recycling Value in Rigid HDPE and PP
For all rigid HDPE and PP packaging:
a. For all labels, ensure material choice, adhesive choice, inks and size is not problematic for recycling1
b. Use minimal or moderate direct printing²
c. For closures, ensure material choice, liners and seals are not problematic for recycling
d. Do not use fillers that increase the density of the packaging to >1g/cm³

The rule applies to all rigid HDPE and PP packaging,

including bottles and squeeze tubes. THE SCALE
Rigid HDPE and PP packaging is recycled in practice and If adopted industry-wide, this rule would affect
at scale in many markets², but there is significant scope for 20% of the total plastic packaging market.*
increasing value in recycling and increasing availability and
quantity of recycled material³

1) Including phase out of paper labels, and PET, PETG, PLA and PVC labels/sleeves; and non-water soluble/dispersible adhesives. Labels/sleeves should not lead to
misdetection of the packaging and misdirection to waste. For in-mould labelling use only polyolefins.
2) E.g. production or expiry date. Where additional printing is necessary, use of labels is preferred. If this is not possible, use only inks that do not bleed or which are
proven not to limit recyclability.
3) Including phase out of silicone valves, and PVC and silicone seals; PS and PVC; and steel and aluminium caps. Closures should not lead to the misdetection of the
packaging and misdirection to waste.
* EMF New Plastics Economy Global Commitment Progress Report 2020

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CEO Co-Sponsors
8
GOLDEN DESIGN RULE
Reduce Virgin Plastic Use in Business-to-Business Plastic Packaging
Reduce the use of virgin plastic in business-business (B2B) plastic packaging¹ in a way that is
environmentally beneficial by:

a. Eliminating unnecessary plastic (defined as unnecessary if it can be removed without compromising

supply chain/operational efficiencies)
b. Using post-consumer recycled content (where plastic is necessary)
c. Switching to reuse models or alternative materials

• This segment of the packaging market generally does packaging that does not reach the consumer (as distinct from
not require food-grade plastics or barrier properties rule 4 on overwraps). This means all packaging that does not
so can be well suited to the use of recycled plastics or end up either in the household waste stream or is disposed
substitute materials of by consumers during consumption outside the home. This
• Reusable alternatives to single-use packaging are could include, but is not limited to:
available (See EMF Upstream Innovation Guide for
examples of reuse models for this packaging segment) • Packaging that is additional to the consumer packaging,
• Reducing the use of virgin plastic through elimination, and that may be used for protection and collation
use of recycled content and reuse models could lead to a of individual units during storage, transport and
lower environmental impact from both a waste and GHG distribution, and to display primary packs on shelf;
emissions perspective if done in an environmentally net • Transportation packaging, including pallets, slip sheets,
beneficial way and stretch wrap used for the shipment and distribution
of goods.
The intended scope of this rule is to cover all plastic

Notes: 1) The intended scope of this rule is to cover all plastic packaging that does not reach the consumer, as distinct from rule 4 on overwraps. This means all packaging
all packaging that does not end up either in the household waste stream or is disposed of by consumers during consumption outside the home

9
GOLDEN DESIGN RULE
Use On-Pack Recycling Instructions
Include recycling or reuse instructions on consumer plastic packaging¹

A high-level rule allows companies to implement the rule a standardised and accurate way of communicating recycling
according to what is possible in different markets. and reuse instructions to consumers in different markets.

Consumers have a key role to play in ensuring packaging The scope: All consumer plastic packaging: ‘Consumer’
is sorted for the appropriate end-of-life solution; clear and packaging is packaging likely to end up either in the
accurate on-pack recycling instructions can increase the household waste stream or disposed of by consumers during
chances that this role is fulfilled. consumption outside the home

There are a growing number of initiatives developing

guidelines for on-pack recycling instructions working towards

Notes: 1) Instructions should reflect the local conditions. Companies should continue to work at the local level to determine the most accurate way to reflect this in
each country

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