---
title: EU's Draft Waste Export List Puts Design for Recycling on the Procurement Checklist
lang: en
source: https://mindsprt.dev/en/knowledge/eu-waste-export-recycling/
---

# EU's Draft Waste Export List Puts Design for Recycling on the Procurement Checklist

*Industry Insights · 4 min read · 2026-10-10*

> The EU is drafting a new waste export list, while TOMRA has publicly called for more investment in recycling. Taiwanese brands can start by reviewing materials, inks, adhesive structures, and supplier records, then make design for recycling part of prototyping and procurement checks

**Quick answer:** The EU's draft waste export list and TOMRA's call for more recycling investment remind brands to include materials, inks, and adhesive structures in procurement checks. MINDS (MS) recommends confirming the recycling route before prototyping

## What do the EU draft list and TOMRA's call mean?

These two signals turn packaging procurement's attention to where waste goes and how much is invested in recycling. The list is still being drafted, so it should not be treated as a ban already in force. The European Union (EU, a regional bloc whose member states jointly set some policies) is working on a new waste export list. TOMRA, the company calling for more recycling investment in this report, is also urging greater investment. [Packaging Insights: EU drafts waste export list and calls for recycling investment](https://www.packaginginsights.com/news/eu-waste-exports-recycling-investment.html)

My view is that tighter management of cross-border waste flows will change the questions brands ask when buying packaging: What is each layer made of? Can the layers be separated? Which recycling process will handle them? Printers in Taiwan do not need to turn this news into an immediate equipment-buying plan. Get the material and supplier records in order first, so you are not scrambling for answers when a client sends over specifications.

## Where should you start with Design for Recycling?

Design for Recycling (DfR) means checking, as part of packaging design, whether the materials, inks, and adhesive structure can be sorted, taken apart, and processed for recycling. Do this before the dieline and artwork are finalized. Change the structure after printing, and another proof round and client approval will follow.

The EU and TOMRA discussions point to single-material packaging, inks that are easy to separate, and recyclable materials. Take packaging with a base material, label, and adhesive layer as an example. Mark each layer on the design file, then check whether the ink and adhesive can be separated and whether the actual recycling process accepts that combination. A supplier's "recyclable" label is not enough to settle the question.

## What should brands ask their printer first?

Brands should turn recycling requirements into specifications their printer can answer item by item, then check the materials and print conditions before the artwork is finalized.

・List the main material, coating, window, and label separately. Do not use "box" or "plastic bag" to describe the whole structure.

・Ask whether the ink, adhesive, and lamination can be separated, and confirm which combinations the intended recycling process accepts.

・Request material specifications and supplier information that match the actual packaging version. Do not use a general catalog in place of project-specific records.

These questions do not dictate the brand's visual design. They help identify which parts of the structure may need adjustment. When updating packaging specifications, brands can discuss paper, printing, and structural requirements with MINDS during prototyping, while there is still time to confirm the materials before artwork sign-off.

## Should small and midsize printers invest in equipment first?

Small and midsize printers should first improve material identification, proof review, and recordkeeping, then assess equipment investments against actual orders. TOMRA has called for more investment in recycling, but has not named any equipment printers should buy. Jumping straight from that signal to a purchase mixes the needs of the recycling sector with a printer's own operating needs.

・Improve material records first.

・When preparing quotes, list any unresolved questions about materials, inks, and adhesives.

・After proofing, keep samples with records of the material version they represent.

・Then calculate what the equipment would be used for.

If brand orders keep requiring design for recycling, printers can estimate equipment and training costs based on material availability, testing needs, and the order pipeline. A clear need gives the investment a specific job and a customer to serve.

## How can brands back up their recycling claims?

A brand's recycling claims should match the actual packaging and where it will go for recycling. The words "recyclable" alone are not enough. Single-material packaging is one design direction, but brands also need to explain how each layer can be separated and whether the intended recycling process can handle it.

When fulfilling overseas orders, Taiwanese brands can keep packaging specifications, approved samples, and supplier records together in one version log, and make only claims they have confirmed. Procurement and customer service can then refer to the same information when responding to consumers. When the packaging changes, the record also shows which materials or print conditions need to be checked again.

## Key takeaways

・The EU's new list is still being drafted. Brands can start by taking stock of their packaging structures.

・Design for Recycling means checking materials, inks, and adhesive structures together.

・Printers should prepare material and supplier records before assessing equipment investments.

・A brand's recycling commitments should be supported by the actual packaging and its recycling destination.

## Further thoughts

Manufacturers can record materials, inks, adhesives, and laminations in packaging specifications, then have the design team check the actual version during artwork review. SaaS (Software as a Service, software delivered and maintained online) can store specifications and supplier documents. AI can help spot missing fields and compare revisions, but recyclability still has to be checked against the actual materials and recycling process. Brands that want to turn these requirements into procurement questions can discuss their internal specifications with the [Mai Strategy Knowledge Academy consulting team](https://mindsprt.dev).

## Further reading

・[Packaging Insights: EU drafts waste export list and calls for recycling investment](https://www.packaginginsights.com/news/eu-waste-exports-recycling-investment.html)

## FAQ

### Is the EU's new waste export list already in force?

What we can confirm so far is that the EU is drafting a new list. The draft should not be treated as a ban already in force. Brands can review their packaging structures now and check the requirements once the final rules are clear.

### What is Design for Recycling?

Design for Recycling means checking during the packaging design stage whether the materials, inks, and adhesive structure can be sorted, taken apart, and processed for recycling.

### Is TOMRA calling on printers to buy recycling equipment?

The report says TOMRA called for more investment in recycling, but it does not specify what equipment printers should buy. Printers can organize their material, ink, and supplier records first, then assess equipment needs against their actual orders.

### How can brands include design for recycling in procurement specifications?

Brands can require a list of the materials in each packaging layer, check whether the ink and adhesive structure can be separated, and request supplier records that match the actual version.


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