PPWR recyclability assessment template

Start the assessment at packaging-unit level. Article 6 requires the manufacturer to assess recyclability 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, while separate components are assessed separately.

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 recyclability grade.

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 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 recyclability 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.

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.

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.