A cited field structure for assessing whether a packaging unit can support a PPWR Article 6 decision.
Use it to capture packaging category, design-for-recycling parameters, grade evidence, recycled-at-scale assumptions, and approval records before market, supplier, EPR, or claim decisions.
Use this internal template to maintain the evidence for a PPWR Article 6 decision. It is not an official Commission form and cannot produce a final grade before the applicable delegated and implementing acts supply the criteria, weighting method, recycled-at-scale thresholds, and chain-of-custody rules. Until those methods apply, treat the record as readiness evidence and record the legal exclusion check before scoring the packaging.
Start the assessment at packaging-unit level. Article 6 requires the manufacturer to assess on the basis of the applicable secondary acts, and Annex II grades are applied after weighing criteria per packaging unit. A product-family record is not precise enough when materials, closures, sleeves, adhesives, or residues differ.
The header should also separate the main body, integrated components, and separate components. PPWR states that integrated components are included in the assessment, integrated components that can separate through mechanical stress during transportation or sorting are assessed separately, and separate components are assessed separately.
Complete the Article 6(11) exclusion field before scoring. It covers immediate human or veterinary medicinal-product packaging; contact-sensitive medical-device and in vitro diagnostic packaging; medicinal outer packaging necessary to preserve product quality; specified contact-sensitive infant, baby-food and special-medical-purpose food packaging; dangerous-goods transport packaging under Directive 2008/68/EC; and sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax. The last group remains subject to Article 6(8) on EPR contributions. Record the exact category and facts that meet it, rather than writing only "medical" or "wood".
For the Article 6(10) innovative-packaging route from 2030, retain the pre-market notification to the competent authority, technical details demonstrating innovation, a timeline for reaching recycled-at-scale requirements, and the end date of the derogation, which runs up to five years from the end of the calendar year of market placement. A new material or a supplier claim alone does not establish that route; if the authority rejects the innovative status, the existing design-for-recycling criteria apply.
Sources (1)
Article 6 and Annex II are the binding sources for applicability exclusions, manufacturer assessment, packaging categories, packaging-unit grading, component treatment, and the innovative-packaging derogation.
The manufacturer shall assess packaging recyclability
This PPWR template helps connect Article 6, Annex II, design evidence, recycled-at-scale readiness, owners, and review gates before teams make market, supplier, EPR, or public-claim decisions.
Use the design-for-recycling block to record the facts that can affect collection, sorting, recycling yield, and secondary raw material quality. PPWR Annex II lists parameters for design-for-recycling criteria, and the European Commission Joint Research Centre (JRC) report groups similar facts into predominant material, decoration and information, closing and opening systems, and other parameters.
Keep each field factual. Record the specification, test result, supplier declaration, or engineering judgment behind it, then state whether the evidence supports the claimed packaging category and expected grade.
Sources (2)
Binding PPWR annex listing parameters used as the basis for design-for-recycling criteria under Article 6.
Non-exhaustive list of parameters for setting design for recycling criteria under Article 6
Non-binding 2024 JRC report prepared in the context of the PPWR proposal and used for technical field design; it proposes elements and parameters for assessing recyclability of packaging.
4 elements and 19 parameters
The template should not invent a final grade method before the delegated and implementing acts fill in the detailed assessment rules. It should still capture the grade-relevant evidence that Article 6 and Annex II already identify, then mark whether the current conclusion is final, provisional, or awaiting secondary legislation.
Record dates exactly. The design-for-recycling condition applies from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The recycled-at-scale condition applies from 1 January 2035 or five years after the relevant implementing acts enter into force, whichever is later. From 1 January 2038, packaging within Article 6's scope must reach grade A or B, subject to Article 6(10).
The Commission's June 2026 guidance says the general Article 6(1) recyclable-packaging rule applies from 12 August 2026, but manufacturers do not need to perform the PPWR conformity assessment under Article 38 and Annex VII until the Article 6(4) delegated act enters into force. Until the design-for-recycling condition applies, the guidance directs manufacturers to the previous Packaging Waste Directive requirements and related harmonised standards. Record this as Commission interpretation, not as a replacement for Article 6 or the future secondary acts.
Sources (2)
Article 6 and Annex II are the binding sources for assessment timing, grade bands, manufacturer duties, delegated and implementing acts, and market-placement restrictions.
Packaging recyclability shall be expressed in the recyclability performance grades A, B or C
Non-binding Commission guidance distinguishing the Article 6(1) application date, the later design-for-recycling method, and when the PPWR recyclability conformity assessment begins.
Keep the recycled-at-scale block separate from design for recycling. A design assessment does not prove that the packaging is recycled in practice. Article 6 requires an implementing methodology based on quantities placed on the market and quantities recycled, plus a chain-of-custody mechanism.
Until the implementing acts are in force, label this evidence as a readiness record. Do not present downstream data as a final PPWR recycled-at-scale determination unless the applicable Article 6 methodology and thresholds are available.
Sources (1)
Article 6 and Annex II explain why recycled-at-scale evidence is separate from design-for-recycling evidence and require a methodology, quantity data, thresholds, downstream verification, and a chain-of-custody mechanism.
a design for recycling assessment has been carried out does not, in itself, ensure that packaging is recycled in practice
Use review gates before the assessment reaches packaging artwork, supplier onboarding, EPR fee-modulation inputs, customer statements, or public sustainability content. The record should show what was assessed, what was assumed, which secondary act is still pending, and who approved the internal decision.
Keep the record traceable to the packaging unit, Article 6 and Annex II, the technical parameter evidence, the grade status, recycled-at-scale readiness, and the next review trigger.
Sources (2)
Binding source requiring Article 6 compliance to be demonstrated in technical documentation concerning the packaging.
Compliance with the requirements set out in paragraphs 2 and 3 of this Article shall be demonstrated in the technical documentation
Commission overview used for public PPWR context around recyclable packaging and implementation planning.
All Packaging must be recyclable by 2030
"All Packaging must be recyclable by 2030"
"4 elements and 19 parameters"
"The manufacturer shall assess packaging recyclability"
"Packaging recyclability shall be expressed in the recyclability performance grades A, B or C"
"Non-exhaustive list of parameters for setting design for recycling criteria under Article 6"
"Compliance with the requirements set out in paragraphs 2 and 3 of this Article shall be demonstrated in the technical documentation"
"All packaging placed on the market shall be recyclable."
"a design for recycling assessment has been carried out does not, in itself, ensure that packaging is recycled in practice"
Build PPWR technical documentation and EU declarations of conformity for packaging, with evidence fields, owner checks, retention rules, and official EU sources.
Official source guide to PPWR penalties and fines: Article 68 Member State rules, administrative fines for Articles 24 to 29, market-surveillance action, formal non-compliance, and enforcement evidence.
Determine whether the EU Packaging and Packaging Waste Regulation applies to a packaging item, market activity, operator role, and evidence workflow.
Guide to PPWR Article 12 packaging labels, reusable packaging QR codes, digital carriers, online-sale information, exceptions, and evidence records.
Official source guide to PPWR Article 5 substance controls: substances of concern, the 100 mg/kg heavy-metal cap, PFAS limits for food-contact packaging, and technical-documentation evidence.
Build a PPWR Article 5 evidence workflow for food-contact packaging PFAS checks, limit-value evidence, supplier proof, and Annex VII technical documentation.
Guide to PPWR take-away duties: customer-owned container refill by 12 February 2027, reusable packaging offers by 12 February 2028, conditions, and exemptions.
A cited PPWR checklist for packaging scope, recyclability, recycled content, PFAS, minimisation, labelling, conformity files, and EPR registration under Regulation (EU) 2025/40.
Build a PPWR compliance workflow for packaging placed on the EU market, covering Articles 5-12 controls, conformity assessment, technical files, declarations, labelling, EPR and evidence.
Calendar-style PPWR deadline guide for application, PFAS, labelling, recyclability, recycled content, reuse, refill, deposit return, reporting, and transition dates.
Track PPWR delegated and implementing acts for recyclability, recycled content, reuse, labelling, EPR, reporting, and evidence owners.
Map PPWR roles for packaging teams: manufacturer conformity files, importer and distributor checks, supplier data, fulfilment handling, traceability, and EPR producer registration.
Map PPWR EPR duties for producers, authorised representatives, producer responsibility organisations, online platforms, registrations, reporting and evidence under Regulation (EU) 2025/40.
FAQ index for Regulation (EU) 2025/40 on packaging and packaging waste, covering PPWR scope, recyclability, recycled content, minimisation, reuse, labelling, EPR, and evidence.
Article 12 and Article 55 PPWR guidance for packaging labels, QR codes, online sales information, waste receptacle labels, and consumer information records.
Checklist for PPWR Article 12 packaging labels and Article 13 waste-receptacle labels, including material composition, reuse, DRS, digital carriers, online sales, and transition stock.
Roll out PPWR Article 12 packaging labels, digital carriers, reusable-packaging information, and Article 13 waste-receptacle labels on the correct dates.
Classify PPWR packaging by function, material category, format, reuse status and operator role before assessing recyclability, restrictions, EPR and documentation.
PPWR packaging minimisation guide covering Article 10, Annex IV evidence, protected-design exceptions, empty-space rules, and technical documentation.
A PPWR packaging scope workflow for classifying packaging, assigning economic-operator roles, routing EPR questions, and keeping technical evidence.
Guide to PPWR Article 5 PFAS limits for food-contact packaging, including the 12 August 2026 date, thresholds, scope test, and evidence records.
Article 6 PPWR guide to packaging recyclability grades, Annex II packaging categories, design-for-recycling parameters, recycled-at-scale assessment, and evidence files.
Assess PPWR recyclability by packaging unit: map the Annex II category, screen design-for-recycling parameters, grade the result, and retain Annex VII evidence.
Understand PPWR recyclability grades under Article 6 and Annex II, including design-for-recycling thresholds, 2030, 2035 and 2038 timing, and evidence records.
Article 7 PPWR targets for recycled content in plastic packaging, including 2030 and 2040 percentages, calculation basis, exclusions, and evidence records.
A source-cited overview of Regulation (EU) 2025/40 requirements for packaging scope, recyclability, recycled content, minimisation, labelling, reuse, EPR, and conformity evidence.
Guide to PPWR reuse targets for transport, grouped, beverage, and take-away packaging, including Articles 29 to 33, reporting, and exemptions.
Decide whether PPWR Article 29 reuse targets, Article 32 refill duties, and Article 33 take-away reusable offers apply to a packaging flow.
Use PPWR Article 2 and Article 3 to decide whether an item is packaging, classify sales, grouped, transport, e-commerce and service packaging, and record cited evidence.
Compare PPWR and ESPR without mixing duties: PPWR controls packaging and packaging waste, while ESPR is a separate sustainable-product ecodesign framework that PPWR complements.
Compare PPWR packaging duties with REACH chemical rules for packaging articles, Candidate List substances, Annex XVII restrictions, PFAS, evidence, and deadlines.
Compare PPWR packaging duties with RoHS controls for electrical and electronic equipment, homogeneous-material substance limits, exemptions, CE marking, and evidence.
Compare PPWR with the Single-Use Plastics Directive: all-packaging duties, Annex-listed plastic products, bans, marking, tethered caps, EPR, collection, and PPWR amendments.
Compare PPWR with the Waste Framework Directive where the PPWR text expressly relies on WFD concepts: waste hierarchy, definitions, EPR, collection, traceability, and waste plans.
PPWR implementation timeline separating fixed legal dates from milestones that depend on Commission delegated or implementing acts.
A PPWR FAQ on compostable packaging: mandatory compostable formats, Member State options, recycling default rules, labels, and evidence to retain.
A practical FAQ for online sellers and fulfilment teams applying PPWR rules to e-commerce packaging, including empty-space, labelling, reuse, and evidence records.
Answer whether grouped, transport, and e-commerce packaging need PPWR empty-space controls, what the 50% ratio covers, and what evidence to keep.
A PPWR FAQ on Article 12 and Article 13 labelling dates for packaging, reusable packaging, recycled-content labels, QR codes, waste receptacles, and implementation acts.
PPWR FAQ for micro-enterprises and small businesses: manufacturer responsibility, conditional reuse exemptions, packaging restrictions, reporting and evidence.
Direct FAQ on the PPWR Article 5 PFAS limits for food-contact packaging, including the 25 ppb, 250 ppb, and 50 ppm thresholds.
A PPWR FAQ on recycled content calculations for plastic packaging: Article 7 scope, manufacturing-plant averages, Commission methodology timing, exceptions, and evidence.
Answer when packaging can be treated as reusable under PPWR, what re-use systems must include, and what evidence teams should keep.
Service packaging under the EU PPWR means items designed to be filled at the point of sale. See scope, takeaway, HORECA refill and reuse, and evidence checks.