Abstract

This document defines specific process and design criteria to evaluate the compatibility with collection, sorting, and recycling process of the part of the rigid packaging unit which comprises the main body and the integrated components predominantly made of biodegradable plastics, as well as of separate components predominantly made of biodegradable plastics. This document is not about the compostability of packaging, i.e. its ability to be organically recovered through composting.

Status
Not Published
Publication Date
09-Dec-2026
Technical Committee
CEN/TC 261 - Packaging
Current Stage
5020 - Submission to Vote - Formal Approval
Start Date
23-Jul-2026
Due Date
28-Dec-2026
Completion Date
23-Jul-2026

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FprCEN/TS 18382 is a CEN draft Technical Specification on design for recycling of rigid packaging made of biodegradable plastics. It gives process and design criteria to judge whether the main body, integrated components, and separate components made predominantly of biodegradable plastics are compatible with collection, sorting, and recycling. The document is for packaging designers, converters, recyclers, and other people who need to assess whether a rigid biodegradable plastic pack fits current recycling systems.

What does FprCEN/TS 18382 specify?

FprCEN/TS 18382 specifies how to evaluate rigid biodegradable plastic packaging for compatibility with collection, sorting, and recycling. It is not about compostability or organic recovery through composting.

The document is organized into:

  • Clause 1 Scope
  • Clause 2 Normative references
  • Clause 3 Terms and definitions
  • Clause 4 Compatibility of biodegradable rigid plastic packaging designs with recycling
    • 4.1 General characteristics
    • 4.2 Sortability
    • 4.3 Biodegradable rigid plastic packaging
    • 4.4 Design guidelines summary table

Clause 4 is the technical core. It ties the design guidance to the recycling routes considered in the document and to the green, yellow, and red compatibility categories used for assessment.

What are the key requirements of FprCEN/TS 18382?

FprCEN/TS 18382 asks the reader to design for recycling using the principles in EN 18120-1 and, where sortability testing is advised, to apply EN 18120-3. In practice, that means the pack design is not judged only on material choice but also on whether the pack can be identified, sorted, and recycled in real systems.

The document also treats biodegradable plastics as a specific packaging family, not as a shortcut to end-of-life recovery by composting. The recyclable design focus is on collection, sorting, and material recycling, including mechanical recycling and, for PLA, chemical recycling by depolymerisation.

A useful way to read the document is by the recycling outlets it considers:

Packaging typeRecycling route consideredOutlet described in the document
Rigid packaging predominantly from PLAMechanical and chemical recyclingRecycled PLA for chemical recycling and for injection-moulded uses after mechanical recycling
Rigid packaging predominantly from PHAMechanical recyclingSheet extrusion, injection moulding, or other uses where material quality is retained
Rigid packaging predominantly from PBS (Co-)polyestersMechanical recyclingInjection moulding or other uses where material quality is retained

The design guidance in Clause 4 then gives separate treatment for PLA, PHA, and PBS. In practice, this means the material family of the rigid pack determines which table to use and which combinations of body material, colourants, additives, barriers, inks, labels, sleeves, closures, seals, and other constituents are acceptable, limited, or disruptive.

The document also gives general design principles that matter before you get to the detailed tables:

  • prefer natural colour packaging where possible
  • minimize adhesives and make them easy to remove and compatible with recycling
  • prefer a single polymer type unless extra materials are technically necessary
  • minimize labels and prefer easy-to-remove labels when labels are unavoidable
  • design the pack to empty easily so residual content is reduced
  • make sure additives and barrier layers do not contaminate or disrupt the intended recycling route

These points matter because a packaging item can be made from a biodegradable plastic and still fail recycling if labels, inks, barriers, or additives interfere with sorting or reprocessing.

Clause 4.2 is especially important for testing and verification. FprCEN/TS 18382 says the guidance considers sortability effects, but it does not define a sortability test method itself. When sortability testing is required, EN 18120-3 is the reference to use, including the effect of residual product content after emptying.

Clause 4.3 makes the end-of-life intention clear. The packaging covered by this document is intended to be compatible with waste collection, sorting, and material recycling, not to be designed for biodegradation at end-of-life. For a buyer or quality manager, that means “biodegradable” in this document is a material property, not a disposal route.

Clause 4.4 contains the detailed design-guideline tables. These tables use green, yellow, and red categories to show full compatibility, limited compatibility, or incompatibility with the relevant collection, sorting, and recycling processes. The document also says these categories reflect current technological conditions, so they should be read as practical guidance for today’s systems rather than as a claim of state-of-the-art performance.

The tables are also explicit about the role of separate components. A separate component can be assessed independently from the main body, so one part of a specification may be recyclable even if another part is not.

What terms does FprCEN/TS 18382 define?

FprCEN/TS 18382 defines the key terms that control how the guidance is read.

  • Biodegradable plastic - a plastic that can biologically decompose; in this document, the term is tied to inherent biodegradability as used in EN 13432.
  • Depolymerisation - the reversion of a polymer to monomers or to a lower-molecular-mass polymer, which is relevant to the chemical recycling route for PLA.
  • Green category - components or constituents that are compatible with collection, sorting, and recycling, or are shown suitable for recycling by technical evaluation.
  • Yellow category - components or constituents with limited compatibility with collection, sorting, and recycling.
  • Red category - components or constituents that are generally rejected or disruptive in sorting or recycling.
  • Oxo(bio)degradable additive, oxo(bio)degradation additive - an additive that causes fragmentation or chemical decomposition through oxidation.
  • PBAT - polybutylene adipate terephthalate, a thermoplastic copolyester used in biodegradable packaging.
  • PLA - polylactic acid, a thermoplastic polyester used as a major packaging material in this document.

Who uses FprCEN/TS 18382?

FprCEN/TS 18382 is used by packaging designers, material suppliers, converters, recyclers, and sorting operators who need to assess rigid biodegradable plastic packaging. It is also useful for quality managers, buyers, and technical teams that specify labels, inks, closures, barriers, adhesives, and additives.

In practice, people use it to choose polymers and components, check whether a design should be treated as green, yellow, or red, and decide whether a pack design can fit existing collection, sorting, and recycling routes in Europe.

Which standards are used with FprCEN/TS 18382?

FprCEN/TS 18382 directly refers to EN 18120-1 and EN 18120-3 for the general principles of design for recycling and for sortability evaluation. It also uses EN 13432:2000 for the biodegradability and ecotoxicity framework applied to constituents.

The document points to the EuPIA Exclusion Policy for Printing Inks and Related Products, 5th Edition, for ink compatibility in the design tables. It also sits within the broader EN 18120 series and is listed alongside FprCEN/TS 18395, the recyclability evaluation process for rigid packaging made of biodegradable plastics.

What does the FprCEN/TS 18382 document contain?

FprCEN/TS 18382 contains a short set of design principles, a recyclability-oriented interpretation of biodegradable rigid packaging, and detailed guidance tables for PLA, PHA, and PBS-based rigid packs. The tables cover body material, colours and pigments, additives and fillers, barriers and coatings, inks, labels, sleeves, closures and openings, seals and valves, tamper evidence, and other constituents.

It also contains a recycling-outlet table that links each main material family to the recycling route and intended recyclate use. The document finishes with constituent-control requirements aligned with EN 13432 and a bibliography that includes the EN 18120 series and related packaging references.

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Frequently Asked Questions

FprCEN/TS 18382 is a draft published by the European Committee for Standardization (CEN). Its full title is "Packaging - Design for recycling for plastic packaging products - Guideline for design for recycling of rigid packaging made of biodegradable plastics". This standard covers: This document defines specific process and design criteria to evaluate the compatibility with collection, sorting, and recycling process of the part of the rigid packaging unit which comprises the main body and the integrated components predominantly made of biodegradable plastics, as well as of separate components predominantly made of biodegradable plastics. This document is not about the compostability of packaging, i.e. its ability to be organically recovered through composting.

This document defines specific process and design criteria to evaluate the compatibility with collection, sorting, and recycling process of the part of the rigid packaging unit which comprises the main body and the integrated components predominantly made of biodegradable plastics, as well as of separate components predominantly made of biodegradable plastics. This document is not about the compostability of packaging, i.e. its ability to be organically recovered through composting.

FprCEN/TS 18382 is classified under the following ICS (International Classification for Standards) categories: 13.030.50 - Recycling; 55.020 - Packaging and distribution of goods in general; 83.080.20 - Thermoplastic materials. The ICS classification helps identify the subject area and facilitates finding related standards.

FprCEN/TS 18382 is available in PDF format for immediate download after purchase. The document can be added to your cart and obtained through the secure checkout process. Digital delivery ensures instant access to the complete standard document.

Standards Content (Sample)


SLOVENSKI STANDARD
01-september-2026
Embalaža - Načrtovanje za recikliranje plastične embalaže - Smernica za
načrtovanje za recikliranje toge embalaže iz biorazgradljiive plastike
Packaging - Design for recycling for plastic packaging products - Guideline for design for
recycling of rigid packaging made of biodegradable plastics
Verpackung - Recyclingorientierte Gestaltung von Kunststoffverpackungsprodukten -
Leitfaden für die recyclingorientierte Gestaltung von starren Verpackungen aus aus
biologisch abbaubaren Kunststoffen
Ta slovenski standard je istoveten z: FprCEN/TS 18382
ICS:
13.030.50 Recikliranje Recycling
55.020 Pakiranje in distribucija blaga Packaging and distribution of
na splošno goods in general
83.080.20 Plastomeri Thermoplastic materials
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

FINAL DRAFT
TECHNICAL SPECIFICATION
SPÉCIFICATION TECHNIQUE
TECHNISCHE SPEZIFIKATION
July 2026
ICS 13.030.50; 55.020; 83.080.20
English Version
Packaging - Design for recycling for plastic packaging
products - Guideline for design for recycling of rigid
packaging made of biodegradable plastics
Verpackung - Recyclingorientierte Gestaltung von
Kunststoffverpackungsprodukten - Leitfaden für die
recyclingorientierte Gestaltung von starren
Verpackungen aus aus biologisch abbaubaren
Kunststoffen
This draft Technical Specification is submitted to CEN members for Vote. It has been drawn up by the Technical Committee
CEN/TC 261.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.

Warning : This document is not a Technical Specification. It is distributed for review and comments. It is subject to change
without notice and shall not be referred to as a Technical Specification.

EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2026 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TS 18382:2026 E
worldwide for CEN national Members.

Contents Page
European foreword . 3
Introduction . 4
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 6
4 Compatibility of biodegradable rigid plastic packaging designs with recycling . 8
4.1 General characteristics . 8
4.2 Sortability . 9
4.3 Biodegradable rigid plastic packaging .10
4.4 Design guidelines summary table.10
Bibliography. 26

European foreword
This document (FprCEN/TS 18382:2026) has been prepared by Technical Committee CEN/TC 261
“Packaging”, the secretariat of which is held by AFNOR.
This document is currently submitted to the Vote on TS.

Introduction
Biodegradable plastics are polymeric materials with the special intrinsic property that is determined by
the composition and structure of a material allowing them to biodegrade under specific environmental
conditions. Biodegradability of polymeric materials is determined by the chemical structure responsible
for functional group stability, reactivity, hydrophilicity and swelling behaviour. The rate and extent of
biodegradation depend on the polymer’s chemical composition, crystallinity, molecular weight, and
environmental parameters such as temperature, moisture, pH, and microbial community composition.
From this perspective, biodegradable plastics are very different from other plastics in that they have
several end-of-life options and should not be treated together with the general group. While
compostability was in the focus for many years, biodegradable plastics are also recyclable as was proven
in numerous studies.
This is especially true for the biodegradable polyesters like PLA, PBAT, PHA, PBS and the like, which
behave similar to PET. However, separate sorting and recycling at scale is still to be still built up and
recycling technologies are not mature yet. Therefore, this Technical Specification (TS) is based on the
best available knowledge and expertise at the time of drafting, including experience from companies
currently engaged in biodegradable plastics recycling and from ongoing European projects related to the
scale up of sorting and recycling procedures for these materials and from other plastics. This document
provides guidance based on current technological capabilities and does not represent state-of-
the-art collection, sorting and recycling as defined in EN 18120. As technical developments progress
and further consensus is achieved the content of this Technical Specification may be subject to
modification, review and revision.
The objective of this TS is to facilitate consistent design for recycling criteria for rigid packaging made
from biodegradable plastics, ensuring that when technologies mature and/or are brought to a larger
scale, these specifications can be smoothly incorporated into the broader standard framework.
This technical specification (TS) intends to follow the philosophy of EN 18120. Given the early market
implementation in Europe of packaging made from biodegradable plastics and the low volumes of such
packaging currently in the waste streams, existing material recycling technologies for packaging waste
made from biodegradable plastics (with levels of maturity varying depending on the polymer type) do
not currently fit into the “state-of-the-art” definition as set in EN 18120. Therefore, these TS are proposed
outside the scope of EN 18120 at this stage, while maintaining its philosophy and structure as closely as
possible. EN 18120 aims via series of guidelines and protocols to establish consistency and improvement
for the Design for recycling for household, industrial and commercial plastic packaging products.
Design for recycling guidelines are a common way of describing compatibility with plastic packaging
collection, sorting and recycling into recycled plastic. They provide guidance on the level compatibility,
defined as:
— Green: Packaging constituents with full compatibility with collection, sorting and recycling;
— Yellow: Packaging constituents with limited compatibility with collection, sorting and recycling;
— Red: Packaging constituents which are not compatible with collection, sorting and recycling.
These categories reflect compatibility under current technological conditions and do not represent state-
of-the-art recycling performance as defined in EN 18120. Recyclability guidelines will require regular
review and improvement to reflect innovations in design, collection, sorting and recycling.
The Design for Recycling Guidelines provided in this series of documents are representative of the
European market and cover all steps from design for recycling, packaging waste collection, sorting,
recycling into recycled plastic and to use in a new application. Compliance with the design guidelines
does not guarantee that the recycled plastic quality will be fit for purpose for a specific targeted end
application or compliant with applicable regulations.
Packaging recyclability is the combination of design for recycling, proven collection, sorting, and
recycling.
1 Scope
This document defines specific process and design criteria to evaluate the compatibility with collection,
sorting, and recycling processes of the part of the rigid packaging unit which comprises the main body
and the integrated components predominantly made of biodegradable plastics, as well as of separate
components predominantly made of biodegradable plastics.
This document is not about the compostability of packaging, i.e. its ability to be organically recovered
through composting.
2 Normative references
The following documents are referred to in the text in such a way their content constitutes requirements
of this document. For dated references, only the edition cited applies. For undated references, the latest
edition of the referenced document (including any amendments) applies.
EN 18120-1:2026, Packaging — Design for recycling of plastic packaging — Part 1: Definitions and
principles for design-for-recycling of plastic packaging
EN 18120-3, Packaging — Design for recycling of plastic packaging — Part 3: Evaluation processes for the
sortability of plastic packaging
EN 13432:2000, Packaging — Requirements for packaging recoverable through composting and
biodegradation — Test scheme and evaluation criteria for the final acceptance of packaging
European Printing Ink Association (EuPIA). EuPIA Exclusion Policy for Printing Inks and Related Products
– 5th Edition (June 2023)
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply. For all other terms and
definitions that are not defined below, please refer to the definitions in EN 18120-1.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp/
— IEC Electropedia: available at https://www.electropedia.org/
3.1
aliphatic-aromatic copolyester
thermoplastic copolyester made by the polycondensation of an aliphatic diol with aliphatic and aromatic
diacids
3.2
biodegradable plastic
plastic capable of undergoing biological decomposition, such that it ultimately decomposes into carbon
dioxide (CO ), biomass and water, and meets the inherent biodegradability requirements of the relevant
composting standards
Note 1 to entry: Biodegradable plastic in the context of this document is characterized only by its inherent
biodegradability as per EN 13432:2000 (and not by other requirements of EN 13432:2000).
3.3
depolymerisation
reversion of a polymer to its monomer(s) or to a polymer of lower relative molecular mass
3.4
green category
category for identifying components or constituents of a plastic packaging that is in the scope of the
design for recycling guidelines of a given packaging type and are recognised as compatible with collection,
sorting and recycling processes or are demonstrated as suitable for recycling through technical
evaluation and can fully meet the quality requirements of secondary raw material in the recycling process
3.5
oxo(bio)degradable additive, oxo(bio)degradation additive
additive which, through oxidation, lead to the fragmentation of the plastic material into micro-fragments
or to chemical decomposition
Note 1 to entry: Definition is based on definition EN 18120-1:2026, 3.92.
Note 2 to entry: Oxo(bio)degradable additive and oxo(bio)degradation additive are used synonymously.
3.6
polybutylene adipate terephthalate
PBAT
thermoplastic copolyester made by the polycondensation of 1,4 butandiol with terephthalic acid and
adipic acid
3.7
polybutylene succinate
PBS
thermoplastic polyester made by the polycondensation of succinic acid and 1,4-butanediol
3.8
polycaprolactone
PCL
thermoplastic polyester made by the ring-opening polymerization of ε-caprolactone
3.9
polyethylene glycol
PEG
thermoplastic polyether made by polymerization of ethylene glycol
3.10
polyethylene wax
low-molecular-weight synthetic polymer of ethylene, characterized by wax-like properties such as low
viscosity, hardness, and high melt point
3.11
polyhydroxyalkanoate
PHA
thermoplastic polyester, predominantly consisting of 3-hydroxybutyrate and/or 4-hydroxybutyrate (e.g.,
PHB, PHBV, PHBH, P3,4HB)
3.12
polylactic acid
PLA
thermoplastic polyester made by the polymerisation of lactic acid or lactide
3.13
polytetramethylene glycol
PTMG
synthetic resin made by the polymerization of tetramethylene glycol
3.14
red category
category for identifying components or constituents of a plastic packaging that is in the scope of the
design for recycling guidelines of a given packaging type and generally leads to rejection of the packaging
item in sorting or recycling processes or are generally recognized as detrimental (disrupting) for
recycling or are demonstrated as disrupting for recycling through technical evaluation or are
demonstrated as unacceptably downgrading the yield or the quality of plastic secondary raw materials
3.15
yellow category
category for identifying components or constituents of a plastic packaging that is in the scope of the
design for recycling guidelines of a given packaging type and are recognized as acceptable with limited
compatibility with collection, sorting and recycling processes, or are demonstrated as having limited
compatibility through technical evaluation or will not meet all the quality requirements for secondary
raw material in the recycling process
4 Compatibility of biodegradable rigid plastic packaging designs with recycling
4.1 General characteristics
Generic aspects for design compatibility with recycling are covered in EN 18120-1.
To determine the recyclability of the design of a biodegradable rigid plastic packaging, the following
guidance tables shall be consulted in conjunction with the definitions provided in EN 18120-1. The tables
provide combined design guidance for all considered material recycling processes. This document
considers mechanical and chemical recycling of rigid packaging made of biodegradable plastics as
recycling technologies. It considers the outlets described in Table 1.
Table 1 — Outlets for recyclates considered in this document
Packaging type Recycling technology Outlet
Rigid packaging made Mechanical and chemical recycling Chemical Recycling: recycled PLA
predominantly from PLA for any application including
packaging
Mechanical Recycling: recycled PLA
for any injection moulded
application including packaging
Rigid packaging made predominantly Mechanical recycling Sheet extrusion, injection moulding,
from PHA for packaging or other applications
where the quality of the recycled
material is retained, where feasible
Rigid packaging made predominantly Mechanical recycling Injection moulding for packaging or
from PBS (Co-)polyesters other applications where the quality
of the recycled material is retained,
where feasible
These current recycling technologies for packaging made from biodegradable plastics, for post-consumer
packaging, are not yet able to conform to the “state-of-the-art” definition in EN 18120. For post-industrial recycling,
however, some technologies already conform to such “state-of-the-art” definition.
The design guidance provided in this document covers:
a) main packaging components which constitute biodegradable rigid plastic packaging, with all their
integrated components and all constituents, including those which are removed during the recycling
process and
b) separate components (of other types of packaging) which are predominantly made from
biodegradable rigid plastic materials, with all their constituents, including those which are removed
during the recycling process.
It does not apply to other types of separate components (which are already separated before and during
the sorting process) as per the definition in EN 18120-1 and as determined in EN 18120-3.
Separate components are to be evaluated separately, as described in EN 18120-1. As such, a separate
component of rigid packaging predominantly made of biodegradable plastics can be fully compatible with
recycling even when an integrated component or a constituent of the same specification would only have
limited or no compatibility with recycling according to the guidance in this document. Equally, separate
components of rigid packaging predominantly made of biodegradable plastics can be incompatible with
recycling even when an integrated component would be compatible.
The following general principles shall be followed when designing rigid packaging made of biodegradable
plastics:
— prefer natural colour packaging where possible, mainly in the main component of the packaging;
— minimize the adhesives used for bonding the different elements of the packaging and ensure they are
easily removable and are compatible with the recycling processes;
— prefer the use of a single polymer type unless additional materials are strictly necessary for technical
reasons; e.g. to avoid product waste (the guidance in the tables of this document shall apply to the
additional materials);
— minimize labels; When unavoidable, prefer the use of easily removable labels;
— design the packaging, where possible and taking into account the filling good, in such a way that it
eases emptying of its content to minimize residual content;
— if the package needs additives or barrier layers, make sure they do not contaminate and/or disrupt
recycling for the intended recycling process and use targeted by the design guidelines.
4.2 Sortability
The design guidance provided by this standard considers effects on the sortability of packaging. It does
however not provide details on established sorting processes or a method for determining sortability.
Where sortability testing is advised in the guidance of this document, the provisions of EN 18120-3 shall
apply. This includes the consideration of the effect of residual product content after emptying on the
sortability.
4.3 Biodegradable rigid plastic packaging
The biodegradable plastic packaging covered in this document is designed to be compatible with waste
collection, sorting, and material recycling processes and it is not intended to undergo a biodegradation at
its end-of-life. Therefore, biodegradable plastic packaging is not a classification based on a specific end-
2)
of-life, but rather on an intrinsic property (inherent biodegradability as per EN 13432:2000 related to
the chemical composition of a plastic material.
The main biodegradable plastics used for packaging production are largely based on polyesters and their
blends with other biodegradable materials (PLA, PHA, PBS, starch-based compounds, PCL, etc.).
4.4 Design guidelines summary table
The design guidelines in the following tables have been established reflecting collection, sorting and
recycling in Europe.
All the below design guidelines have been developed with the objective to be able to produce recyclates
that can be used in the applications indicated in Table 1 of this TS. The process used to produce the
recyclates is also indicated in Table 1 of this document.
The following tables shall be used for the design-for-recycling criteria for rigid packaging made of
biodegradable plastics, with the following specific considerations:
— for rigid packaging made predominantly from PLA, refer to Table 2;
— for rigid packaging made predominantly from PHA, refer to Table 3;
— for rigid packaging made predominantly from PBS, refer to Table 4.
All values using "%" as unit in the Tables 2, 3 and 4 refer to mass fractions of intentionally added
substances and constituents, unless explicitly stated differently.

Biodegradable plastic in the context of this document is characterized only by its inherent biodegradability as per
EN 13432:2000 (and not by other requirements of EN 13432:2000).
Table 2 — Design guidelines for rigid packaging made predominantly from PLA
GREEN CATEGORY YELLOW CATEGORY RED CATEGORY
Full compatibility Limited compatibility Not compatible

Leads to Removed Leads to Removed
recycled and not recycled and not
3 4
material recycled material recycled
PLA  PCL  PVC, PET
Mixtures Ceramic, glass,
< 50 % of the metal
material
composition
with other
biodegradable
aliphatic
polyesters
(such PBS,
Mater
...