Under the PPWR, all packaging placed on the EU market must be designed for recycling and reach recyclability grade A, B or C. This applies from 1 January 2030, or 24 months after the Commission’s design-for-recycling acts if that is later. Grade C is no longer allowed from 1 January 2038, and a recycled-at-scale test is added from 2035 at the earliest.
What design for recycling means
Article 3 of the PPWR defines design for recycling as packaging design that makes the packaging recyclable with collection, sorting and recycling processes proven in an operational environment. From 1 January 2030, or 24 months after the relevant delegated acts enter into force if later, all packaging on the EU market must be designed for recycling. It must also meet the design-for-recycling criteria in Annex II. GreenSutra’s recyclability work starts by mapping each packaging format to its likely grade, before the Commission sets the assessment criteria, and then plans any redesign. 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
Annex II, Table 3, of the PPWR sets the recyclability grades and their thresholds, shown below. The Commission’s delegated acts, due by 1 January 2028, will set the design criteria used to score packaging against them.
| 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 and B may be placed on the market, so grade C packaging needs a redesign plan well before that date.
Recycled at scale from 2035 and recycled content
From 1 January 2035, or five years after the Commission’s method acts if that is later, packaging must also be recycled at scale. Article 3(1), point (39), of the PPWR sets the bar: at least 55 percent of each packaging category recycled each year across the EU, or 30 percent for wood. The implementing acts will set how that is measured. Recycled content follows its own timetable under Article 7, with figures that differ by category from 2030. For example, contact-sensitive PET other than single-use beverage bottles needs 30 percent and all other plastic packaging 35 percent, rising in 2040. In GreenSutra’s PPWR work, packaging teams often leave recyclability until the label stage, although it is settled much earlier, when the material and format are chosen. The EU PPWR guide sets out how these dates connect.
Sources: Regulation (EU) 2025/40 (EUR-Lex) · European Commission, Packaging waste