PPWR Series Part 1 - Recyclability

For companies manufacturing or converting packaging, the important question is not simply whether a package is recyclable. PPWR introduces recyclability performance grades, a phased implementation and, from 2035, an additional assessment of whether packaging is actually recycled at scale.

For PP and PE value chains, these distinctions could become increasingly important.

Three recyclability grades

Article 6 of Regulation (EU) 2025/40 establishes three recyclability performance grades: A, B and C.

From 2030, packaging will have to achieve at least Grade C to remain eligible for placement on the EU market. The thresholds are:

Grade A: ≥95% recyclable per unit, by weight

Grade B: ≥80% recyclable per unit, by weight

Grade C: ≥70% recyclable per unit, by weight

From 1 January 2038, the minimum performance level increases to Grade B. Packaging below 80% will no longer meet the relevant requirement for placement on the EU market.

The message is therefore that 70% is the 2030 floor, not the long-term destination. A packaging format that achieves exactly 70% may satisfy the initial requirement, but it is already below the level that will be required later.

Recyclability starts now but the detailed test comes later

The next question that comes to mind is, what exactly is this percentage score? How will it be calculated and who will do that?

For 2030, recyclability will be decided based on the Designed for Recyclability (DfR) score, not how much of the packaging is actually recycled. The Commission's June 2026 guidance confirms that the general requirement that packaging placed on the EU market must be recyclable applies from 12 August 2026. However, the detailed design-for-recycling requirements and assessment methodology apply later, following the relevant delegated acts.

Until those detailed requirements apply, manufacturers are expected to follow the existing requirements under the previous Packaging and Packaging Waste Directive and relevant harmonised standards. The full PPWR recyclability conformity assessment is not required until the relevant delegated acts enter into force.

So, 2030 is not the starting point for recyclability compliance. It is the point at which the more detailed and harmonised PPWR framework begins to apply, subject to the timing of the delegated acts.

The packaging unit matters

The detailed recyclability assessment will look beyond the identity of the main polymer.

The PPWR considers factors including collection, sorting, recycling technologies, the quality of recycled output and the ability to use secondary raw materials. The assessment is made at the level of the packaging unit.

For PP and PE packaging, this is particularly important.

A package cannot necessarily be considered recyclable simply because its main body is made from PP or PE. Closures, labels, barriers, additives, colours and other components can influence the overall assessment.

Recyclability therefore becomes a packaging-system question rather than simply a polymer-selection question.

Who would do the DfR assessment?

The primary responsibility for conforming to the DfR criteria will be on the manufacturer / responsible economic operator. The manufacturer may appoint an authorised representative who can perform certain tasks on its behalf. However, the legal responsibility for ensuring conformity and preparing the technical documentation remains with the manufacturer. There will be market surveillance authorities in each member state that will check for compliance.

The 5% rule: a small threshold with wider implications

Another detail worth highlighting is the PPWR's treatment of composite packaging, which refers to packaging made from two or more different materials that cannot be easily separated by hand and therefore require specific treatment for recycling.

Where one material represents an insignificant part of the packaging unit and in any event no more than 5% of its total mass, the packaging is not considered composite packaging under the PPWR on that basis. For example, if a paper-based package contains a plastic window, and the plastic accounts for no more than 5% of the packaging unit’s total mass, the packaging would not be considered composite packaging on that basis under the PPWR.

‍2035 changes the question

The next major step comes in 2035, when the PPWR introduces the recycled-at-scale (RaS) dimension.

The distinction is fundamental:

From 2030: Is the packaging designed for recycling according to the applicable criteria?

From 2035: Can it also be collected, sorted and recycled at scale?

The regulation will add another layer that will require actual recycling performance by weight/quantity while keeping the DfR criteria.

Collection infrastructure, sorting capacity, recycling technologies and actual material flows can therefore become increasingly important. The assessment of actual quantities recycled will be carried out at the packaging-category level. The European Commission will adopt an implementing act by 1 January 2030 to establish RaS assessment methodology and RaS threshold.

The manufacturer will remain legally responsible for assessing packaging recyclability, but the commission will also establish, by 1 January 2030, a chain-of-custody mechanism, which must include “technical documentation on the quantity of collected packaging waste sent to sorting and recycling facilities and a verification process enabling manufacturers to obtain the necessary data from downstream operators to demonstrate that packaging is recycled at scale.”

Therefore, for 2035, the DfR threshold will remain the same, but we don’t know yet what the RaS threshold will be that will allow packaging to be placed in the EU market. 

What does this mean for PP and PE?

For PP and PE producers and converters, polymer selection alone will not determine future compliance.

Packaging structures will need to be considered as complete systems. Recyclability performance can also have a financial consequence, as the PPWR provides for modulation of extended producer responsibility contributions according to recyclability performance.

The strategic challenge is therefore not simply to design packaging that passes the 2030 minimum.

Companies making packaging decisions today need to consider the 70% Grade C floor from 2030, the move towards Grade B from 2038, and the recycled-at-scale dimension from 2035 as one regulatory trajectory.

PPWR is moving Europe from “recyclable by design” towards packaging that can demonstrate actual recycling at scale. This may mean that producers, entities that place packaging in the market, may prioritise simpler, mono-material, easier-to-recycle, and optimum-performance packaging over cost-cutting and aesthetics. Recyclability alone is not the benchmark that the packaging manufacturers must meet, as there are other domains of PPWR that are as important while designing and manufacturing packaging structures. There are other domains of the PPWR that will force the producers to exclude unnecessary packaging and include recycled content. We will talk about those in our upcoming articles in the PPWR series.

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