CELAB-Europe Regulatory Summary 2023
This summary document has been put together by the Regulatory Workstream consisting of dedicated CELAB-Europe members with long-term expertise in the self-adhesive label value chain. CELAB-Europe is working on monitoring the relevant regulatory landscape in Europe while also talking to representatives at the EU level to generate awareness and understanding of the feasibility of Label Liner and Matrix recycling. A document covering these topics in a greater level of detail is available to CELAB-Europe members.
CELAB-Europe has made reasonable efforts to ensure the accuracy and reliability of the information stated in this document, however, please note the information is provided on an “as is” basis without a warranty of any kind. CELAB-Europe does not accept any responsibility or liability for the accuracy, content, completeness, legality, or reliability of the information contained. We believe that in its generality the information might be of use for the readership. The information is however not intended to substitute for professional legal advice combined with due diligence to ensure compliance with your individual situation.
Some of you might have already been confronted with these topics in your daily business for quite some time now. In addition, due to the dynamics of the regulatory developments, any feedback, comments, or additional information will be welcome. For additional input please contact us at: email@example.com referencing the “CELAB-Europe Regulatory Summary Document”.
This guidance is aimed at the complete packaging value chain, and particularly to all economic actors supplying to, producing, using, or interested in using self-adhesive labels, as well as those handling their waste. For example:
- Raw material suppliers for self-adhesive labels
- Manufacturers of self-adhesive labels or their components, including label converters
- Packaging designers
- Label users: brand owners, retailers, logistics and transport companies
- Waste management companies: waste collectors, sorters, recyclers
The regional scope is limited to Europe, more explicitly EEA (EU-27 + Norway, Lichtenstein, Iceland), the UK, and Switzerland.
Self-adhesive labels are most typically a combination of a self-adhesive label material laminated against a “silicone release liner” (Figure 1). They are produced by taking a paper or film liner onto which a silicone release coating is applied as a very thin layer, followed by a self-adhesive layer, and finally a paper or film label ‘face’ material. This combination of siliconized release liner + adhesive + face material is referred to as “self-adhesive laminate”, and it forms the starting material for most labels production.
Figure 1. Schematic of self-adhesive laminate. Image courtesy of The Label Academy
To transform this “laminate” into the final self-adhesive labels, it passes through a number of different production steps: printing, decoration (e.g. metal foil, embossing, holograms), varnishing, and die-cutting into the label shape. The small amount of unused material (consisting of face material + adhesive), which is not part of the label is then typically peeled away and is called “matrix” and collected on a separate roll. The remaining laminate consists of individual self-adhesive labels left attached to the continuous-release liner and these labels are ready to be applied to the final surface.
When the labels are applied onto a product or container, they are peeled off the surface of the release liner. This leaves behind the release liner which is then available to be recycled.
(More detailed technical information can be found in the “White Paper” documentation on paper-based and filmic-based release liner recycling).
Matrix waste & spent release liner in the value chain
Figure 2. Schematic of the economic actors involved in the supply chain of self-adhesive labels, indicating where the waste is generated.
- Matrix waste is generated at the label converters & printers, where the labels are produced (i.e., printed and die-cut)
- The spent release liner is generated where the labels are used or applied: at the brand owners’ packing sites, retailers, logistics companies, etc.
Different pieces of legislation affect the processing and ultimate fate of matrix waste and spent release liner within Europe. Some of these are EU-wide (Regulations and Directives) and some are country-specific (National legislation, case law).
The Waste Framework Directive (WFD EC/98/2008) is the EU-wide legislation covering the handling of waste. It defines what is and is not waste and how it should be handled, transported, and processed. It sets minimum requirements that the national legislation must follow. It also introduces the concepts of “production residues” as well as “by-products”. Our best understanding is that matrix waste and spent release liner can both be considered “production residues”, but neither can be considered a “by-product” and so must be handled as waste.
The WFD is in the process of being updated (2023 target).
The Packaging and Packaging Waste Directive (PPWD 94/62/EC) covers the criteria for packaging placed on the EU market, including requirements on waste management. The definition of packaging within the PPWD is extremely broad and includes labels as part of packaging. Release liner is not explicitly defined as being a part of packaging under the PPWD. We consider that spent release liner and matrix waste are production residues of the manufacturing of packaging, therefore the PPWD requirements for packaging waste do not apply to either material.
The PPWD is also undergoing a revision (expected 2023).
The Waste Shipment Regulation (EC/1013/2006) covers the shipment of waste within the EU and includes specific waste codes that must be used for the shipment of waste materials. CELAB has identified which codes best suit spent paper-based and filmic-based release liners when they are to be shipped within the EU.
Several countries established EPR fees for label and label waste materials in their national legislation; this includes the UK, NL, AT, and IT. In these countries, release liner is considered as part of packaging (for the self-adhesive labels) and is covered under the respective national EPR-fee scheme.
CELAB-Europe Regulatory Framework Reference Document
A comprehensive document covering these topics in more detail and other relevant topics (e.g. plastic packaging taxes) is available to CELAB-Europe members.