Under the EU Packaging and Packaging Waste Regulation (PPWR), most packaging placed on the EU market must be designed for recycling and reach recyclability grade A, B or C. Article 6 excludes some packaging, such as medicinal and infant-formula packaging, and allows a limited derogation for innovative packaging. This applies from 1 January 2030, or 24 months after the design-for-recycling delegated acts enter into force if that is later. From 2035 at the earliest, a recycled-at-scale test is added to the grading.
From that start date, packaging that scores below grade C, under 70 percent, counts as technically non-recyclable and cannot be placed on the EU market. From 1 January 2038 the bar rises: only grades A and B may be placed on the market.
What each grade means:
- Grade A: the packaging unit scores at least 95 percent in the design-for-recycling assessment. This is the safest design choice.
- Grade B: a design-for-recycling score of at least 80 percent. Grade B packaging may be placed on the EU market from the start date above, and it is still allowed from 1 January 2038.
- Grade C: a score of at least 70 percent. Grade C packaging may be placed on the EU market from the start date above until 31 December 2037. From 1 January 2038 it may not, so a grade C design needs a plan to reach grade A or B by then.
For packaging design, this means:
- All packaging going into the EU must be designed for recycling. A recyclable label on its own is not enough.
- Materials should be mono-material or easily separable
- Components that block recycling need to be changed or removed
- The design must work with real EU collection and recycling systems
The EU PPWR guide covers this in more detail.