General recyclability requirement
The PPWR generally applies, including the principle in Article 6(1) that packaging placed on the market must be recyclable. Detailed assessment criteria follow in stages.
BuVNK · PPWR · Packaging design · Updated 13 October 2026
PPWR recyclability: Design for Recycling and packaging design
What makes packaging recyclable under EU law? Understand the requirements, performance grades and timelines – and how businesses can prepare materials, labels and closures today.
Design for RecyclingGrades A / B / C2030 · 2035 · 2038
Key distinction: Article 6(1) establishes a general recyclability requirement applicable since 12 August 2026. The detailed grading and “recycled at scale” provisions apply in stages, subject to the relevant delegated or implementing acts. This is not a confirmation that a given pack meets the law.
01 / Timeline12 August 2026 2030 – or later 2035 – or later From 2038
The PPWR timeline for recyclability
The European Packaging and Packaging Waste Regulation (EU) 2025/40 introduces a common framework. A transition date must not be read as blanket approval of every current packaging design.
Design-for-Recycling grades
The specific graded design criteria apply from 1 January 2030 or 24 months after entry into force of the relevant delegated acts, whichever is later (subject to exceptions).
Recycled at scale
The actual collection, sorting and recycling-at-scale assessment is phased in from 2035 or later, depending on the applicable implementing acts.
Tighter grade requirement
Subject to the Article 6 exceptions, packaging must meet grade A or B; grade C will no longer suffice.
02 / Grades
What do grades A, B and C mean?
Annex II, Table 3, sets the framework. These are weighted recyclability performance grades – not claims about the share of recycled material already contained in the packaging.
| Grade | Design-for-Recycling performance | Interpretation |
|---|---|---|
| A | ≥ 95% | Highest performance class |
| B | ≥ 80% and < 95% | Compliant grade under the relevant stages |
| C | ≥ 70% and < 80% | Transitional grade; no longer sufficient from 2038 |
| Below C | < 70% | Technically non-recyclable under the grading framework |
The precise scoring methodology depends on EU delegated acts. The percentages above must not be treated as a self-calculated recycling rate or recycled-content share.
03 / Packaging design
Packaging design: what should you check?
Materials alone are not enough: a practical review covers the whole packaging unit and its sorting and recycling route.
Material and layers
Review base material, composites, barriers, laminates and compatibility with the target recycling stream.
Labels, inks and adhesives
Assess sleeves, labels, colour, printing inks and adhesives for their effect on identification, sorting and recycling.
Caps and components
Check caps, pumps, closures and other components for separability and compatibility with the main packaging body.
Collection and sorting
Consider how the package is collected, recognised and sorted in practice; technical recyclability and recycling at scale are not identical.
04 / Preparation01 02 03 04 05 06
Six-step preparation check for businesses
These steps help structure a packaging inventory. They are not a certification or an official compliance grade.
Record packaging formats
List products, packaging units, materials, layers and components by market and country.
Identify responsibilities
Record the manufacturer, supplier and responsible roles and who holds the required technical information.
Obtain supplier evidence
Request specifications, material data, test results and any available sorting or recyclability assessments.
Identify design risks
Flag composites, hard-to-separate components, sleeves, inks and adhesives that may obstruct recycling.
Build a conversion plan
Prioritise high-volume formats and allow time for redesign, testing and supplier changes.
Review the EU acts
Recheck the delegated Design-for-Recycling criteria and implementing methodology once applicable.
06 / Primary sources
Official EU sources
Use primary legal texts and Commission guidance for decisions; check the current version of delegated and implementing acts.
07 / FAQ
Questions about recyclability
Must every package meet grade A already in 2026?
No. The general requirement of recyclability applies from 12 August 2026. The specific grade-based Design-for-Recycling requirements apply from 2030 or later, depending on the applicable delegated acts and transitions.
What is the difference between Design for Recycling and recycled at scale?
Design for Recycling examines the suitability of the packaging design for material recycling. Recycled at scale also considers whether the packaging category is actually recycled in sufficient amounts under the EU methodology.
Is a grade equivalent to a recycled-content percentage?
No. Grades A, B and C are recyclability performance grades under Annex II. Minimum recycled-content requirements for certain plastic packaging are separately regulated under Article 7.
Are there exceptions?
Yes. Article 6 contains specific exceptions and transitional provisions for certain packaging categories. Applicability depends on the packaging and should be checked individually.
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