PPWR design for recycling requires all packaging placed on the EU market to be designed for recycling from 1 January 2030, graded A, B or C for recyclability under Annex II criteria set by forthcoming delegated acts, with grade C excluded from 2038 and a recycled-at-scale test applying from 2035.
What design for recycling means
Design for recycling is packaging design that ensures recyclability with established collection, sorting and recycling processes proven in an operational environment (Article 3). From 1 January 2030, or 24 months after the relevant delegated acts enter into force, whichever is later, all packaging placed on the EU market must be designed for recycling and meet the design-for-recycling criteria in Annex II. GreenSutra supports exporters through PPWR recyclability and packaging redesign, mapping each format to its likely grade before the delegated acts fix the thresholds. The criteria will cover, for each packaging format:
- collection, sorting and recycling proven at operational scale
- the recyclable share of the unit weight
- and, from 2035, a separate recycled-at-scale rate
Recyclability performance grades A, B and C
Recyclability is expressed in performance grades set out in Annex II. The reported thresholds, which remain subject to the forthcoming delegated act, are:
| Grade | Recyclable share of unit weight | Market status |
|---|---|---|
| A | at least 95 percent | permitted |
| B | at least 80 percent | permitted |
| C | at least 70 percent | permitted from 2030, excluded from 2038 |
| Below 70 percent | non-recyclable | barred from the market from 2030 |
From 1 January 2038 only grades A or B may be placed on the market, so grade C packaging needs a redesign path well before that cliff.
Recycled at scale from 2035 and recycled content
From 1 January 2035 recyclability is also assessed against a recycled-at-scale test: the packaging category must be recycled at Union level at a rate of at least 55 percent annually, and at least 30 percent for wood, with the rate set through delegated and implementing acts. Recycled content runs on a parallel track under Article 7, differentiated by category from 2030, for example 30 percent for contact-sensitive PET other than single-use beverage bottles and 35 percent for all other plastic packaging, rising in 2040. Across GreenSutra’s PPWR work, packaging teams often treat recyclability as a late-stage label question rather than a design decision taken at the material and format stage. The EU PPWR guide sets out how these dates connect.
Sources: Regulation (EU) 2025/40 (EUR-Lex) · European Commission, Packaging waste