The PPWR requires all packaging to be recyclable. That sounds like one rule, but it is three, with three different start dates. Anyone who confuses them plans wrong.
Already now: substantiating that the packaging is recyclable
From 12 August 2026 you must substantiate in the declaration of conformity that the packaging is recyclable. This can be done via the European harmonised standard EN 13430. At that point no grade is yet attached, but the claim must rest on something.
From 2030: a performance grade
From 1 January 2030 every packaging is assessed on design for recycling and classified in a performance grade — in the regulation recycling performance grade.
| Grade | Threshold (% recyclable by weight) | 2030 | 2038 |
|---|---|---|---|
| A | ≥ 95% | allowed | allowed |
| B | ≥ 80% | allowed | allowed |
| C | ≥ 70% | allowed | banned |
| below C | < 70% | banned | banned |
If you do not reach grade C, the packaging may no longer be placed on the market in 2030. From 1 January 2038 grade C also lapses: only A and B remain.
Caveat. The exact thresholds and the measurement method will be set in a delegated act, by 1 January 2028 at the latest. The percentages above are the best-substantiated interpretation based on Annex II and the analyses of specialised firms — not certainty. Some sources moreover argue that the regulation legally defines only A, B and C and that anything below is simply “non-conforming”.
From 2035: recyclable at scale
Design for recycling is one thing. Actually being recycled is another. From 1 January 2035 the criterion recyclable at scale is added: you must be able to demonstrate that the packaging is collected, sorted and recycled via existing European infrastructure. The threshold will be set via an implementing act; around 30% is expected. Evidence runs via EPR data or certified recyclers.
This is the provision that puts monomaterial above laminate, regardless of how well that laminate scores on paper.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
What this means for your design
The grade depends on how well the packaging can be taken apart and sorted. In practice four things push the score down:
- Composites and laminates whose layers cannot be separated
- Sleeves and labels that disrupt sorting, particularly dark colours and full-body sleeves on PET
- Adhesives and coatings that do not come off in the washing process
- Colourants, including carbon black, which blinds sorting machines
The direction is monomaterial. Anyone moving their packaging now from laminate to mono-PP or mono-cardboard solves a second problem at the same time: the recycled-content shares from 2030.
Exemptions
Exempt from the recyclability requirement are, among others, medicines, medical devices, packaging for dangerous goods, contact-sensitive packaging for infant food and medical nutrition, and small lightweight packaging of wood, cork, textile, rubber, ceramic, porcelain or wax.
The incentive runs via your EPR fee
The grade is not only a market condition. EPR fees will be mandatorily eco-modulated: higher fees for poorly recyclable packaging, a discount for A and B. So you must also be able to demonstrate the grade to Verpact. See EPR and Verpact.
That means a redesign can pay for itself even before 2030 — not as a compliance cost, but as a lower levy.