RFID tags and packaging recyclability (RecyClass and PPWR)

Under the PPWR, any RFID tag on or inside packaging counts toward the pack's recyclability grade. From 2030, packs below grade C cannot be sold. RecyClass approval, which so far covers one tag construction on PET bottles, is voluntary evidence that a tag will not spoil recycling, and brand owners remain responsible for the whole pack.

The PPWR treats an RFID tag on or inside a pack as part of the packaging, so the tag's construction counts toward the pack's recyclability grade. That makes it a question for tag makers as well as for the brand owners who remain responsible for the whole pack.

The first RecyClass Technology Approval for an RFID tag went to Avery Dennison's AD CleanFlake on 16 July 2026, covering one construction on PET bottles. RFID News reported that the UHF tag is designed to separate cleanly from PET during washing and flotation. For paper and board, an opinion piece we published in September 2026, by the founder of a supplier of paper-recyclable labels, argued that etched aluminium antennas can disrupt paper recycling.

The dates to watch are 1 January 2028, the deadline for the Commission's design-for-recycling criteria and grades, and 1 January 2030, after which only packaging graded A to C may be placed on the EU market.