Short answerUnder PPWR, packaging must meet design-for-recycling criteria from 1 January 2030 and reach performance grade A, B or C, meaning at least 70% recyclable by weight. From 2035 it must also be recycled at scale, and from 2038 grade C no longer suffices. Grades depend on material, colour, coatings, adhesives, labels and closures per component.
Key takeaways
- PPWR grades recyclability by weight: grade A means at least 95%, grade B at least 80% and grade C at least 70%; anything below grade C counts as not recyclable from 2030.
- From 1 January 2035, packaging must also be recycled at scale, so a recyclable design without functioning EU collection, sorting and recycling infrastructure still fails.
- Small components such as sleeves, closures, adhesives and barrier coatings often decide the grade, which makes component-level weights and materials the core data requirement.
Recyclability becomes a market access condition
From 1 January 2030, packaging placed on the EU market must be recyclable, and recyclability is measured with a performance grade. Article 6 of Regulation (EU) 2025/40 sets two tests: design for recycling from 2030 and recycled at scale from 2035. The 2030 test applies from 1 January 2030 or 24 months after the grading delegated acts enter into force, whichever is later. Packaging that fails either test loses market access, with limited exemptions for categories such as medical devices, immediate packaging of medicinal products, and certain lightweight sales packaging (Article 6(11)) made of wood, cork, textile, rubber, ceramic, porcelain or wax. Under Article 6(8), grades also drive EPR fees from 18 months after the grading acts enter into force, as explained in the labelling and EPR article.
Grades measure recyclability by weight
The performance grade expresses how much of a packaging unit, by weight, is recyclable under the design-for-recycling criteria. The Commission proposal of 2022 used five grades, A to E. The adopted regulation, in Annex II, keeps three passing grades and classifies everything below them as not recyclable.
| Grade | Recyclability by weight | Status from 2030 | Status from 2038 |
|---|---|---|---|
| A | 95% or more | Compliant | Compliant |
| B | 80% or more | Compliant | Compliant |
| C | 70% or more | Compliant | Not compliant |
| Below C (former D and E band) | Below 70% | Not recyclable | Not recyclable |
The 2035 threshold adds a second condition. Packaging must be recycled at scale, which means that collection, sorting and recycling infrastructure works in practice across the EU for that packaging type, assessed through a Commission methodology. A grade A design in a material with no functioning EU recycling stream still fails from 2035. Delegated acts under Article 6(4) set the detailed criteria per packaging category and material, due by 1 January 2028, so early assessments remain provisional.
The weakest component sets the grade
The central insight for packaging teams is that small components often decide the grade of the whole unit. A PET bottle body can be fully recyclable, while a full-body PVC or PETG sleeve, a closure that sinks with the PET flakes, a carbon black colourant or a permanent adhesive can disrupt sorting or contaminate the recyclate. A paper-based pouch with a heavy plastic barrier layer, or a metallised film, can fall below the 70% line even when paper dominates the visible surface.
Design-for-recycling assessments therefore run at component level and then roll up to the packaging unit. Existing industry protocols such as RecyClass for plastics, 4evergreen for fibre-based packaging and CEFLEVER for flexibles give a reasonable proxy until the delegated acts apply. Each defines problem combinations that typically mirror what the official criteria target: detectability in near-infrared sorting, separability of components, and compatibility of inks, coatings and adhesives with the main material stream.
Data needed per packaging component
A defensible grade needs structured attributes for every component, captured from specifications and supplier declarations. The core set is:
| Component | Attributes to capture |
|---|---|
| Main body | Material and polymer, weight, colour and transparency, mono or multilayer structure, barrier layers |
| Coatings and barriers | Coating type, coat weight, share of total weight, compatibility with the main stream |
| Adhesives | Adhesive type, wash-off or permanent behaviour, application area |
| Labels and sleeves | Material, coverage of the body in percent, density, ink type, metallisation |
| Closures and fittings | Material, density, attachment method, liner material, tethering |
| Inks and decoration | Ink system, coverage, direct print or label, metallic or fluorescent effects |
| Whole unit | Total weight, component weight shares, packaging category, intended sorting stream |
Weights matter as much as materials, because the grade is calculated by weight share. A 2 g sleeve on a 25 g bottle carries different consequences from the same sleeve on a 60 g bottle. The packaging data model shows how to structure components so that grades roll up automatically.
Building a recyclability workflow
Recyclability needs a repeatable workflow, because every supplier change or artwork update can shift the grade. A practical workflow assigns each step to an owner:
- Packaging engineering captures component specifications in the system of record, typically PLM, as described in the PLM vendor overview.
- Procurement collects supplier declarations for materials, inks, adhesives and coatings.
- Sustainability runs the grade assessment and records the result with its method version and date.
- Product data teams publish the grade and material composition downstream to EPR reporting, labels and retail partners.
Flexible multimaterial packaging and dark-coloured plastics usually carry the most exposure, so assessments should start there. A first screening of the portfolio against industry protocols typically takes an estimated 2 to 4 months once component data exists. Starting in 2026 leaves room for redesign before 2030, and the PPWR explainer places recyclability among the other obligation families.
Frequently asked questions
What happened to grades D and E?
The Commission proposal used five grades, A to E. The adopted Regulation (EU) 2025/40 keeps grades A, B and C as passing grades, set at 95%, 80% and 70% recyclability by weight. Packaging below 70%, the former D and E band, is considered not recyclable from 2030.
What does recycled at scale mean?
From 1 January 2035, packaging must be collected, sorted and recycled in practice through existing EU infrastructure, in addition to meeting design-for-recycling criteria. The Commission defines the assessment methodology in secondary legislation. A technically recyclable design without an operating recycling stream fails this test.
Can companies assess recyclability before the delegated acts apply?
Yes. Industry protocols such as RecyClass, 4evergreen and CEFLEVER provide design-for-recycling guidance that serves as a reasonable proxy. Results should be recorded with the method version and treated as provisional, because the official criteria may treat some components or materials differently.