PPWR recyclability grades A, B and C

Article 6 says all packaging placed on the market must be recyclable. Packaging is recyclable only if it is designed for material recycling and, when it becomes waste, can be separately collected, sorted into specific waste streams without harming other streams, and recycled at scale.

The grade decision starts at the packaging-unit level. Article 6 requires the manufacturer to assess recyclability using the Commission delegated acts for design-for-recycling criteria and the implementing acts for recycled-at-scale methodology.

Annex II Table 3 expresses the design-for-recycling assessment as a weighted percentage per packaging unit. Grade A is 95% or higher, Grade B is 80% or higher, and Grade C is 70% or higher.

A packaging unit below 70% is technically non-recyclable under Annex II Table 3. From 2038, Grade C is no longer enough for market placement: Article 6 says packaging must be recyclable within Grade A or Grade B.

Article 6 uses linked dates rather than a single universal switch. The design-for-recycling rule applies from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later.

The recycled-at-scale requirement applies from 1 January 2035 or five years after the relevant implementing acts enter into force, whichever is later. The Commission must adopt those implementing acts by 1 January 2030.

Annex II does not grade a package only by its main material name. The category, components, sortability, separability, recycling yield, and secondary raw material quality matter because the design-for-recycling criteria are built around operational collection, sorting, and recycling processes.

The JRC report helps teams prepare evidence because it identifies possible elements and parameters for a recyclability methodology. Its consolidated list includes predominant material, decoration and branding, closing and opening systems, and other packaging features.

A defensible PPWR grade file should let a reviewer trace the result from packaging category to design-for-recycling criteria, component assumptions, recycled-at-scale data where applicable, and final approval.

Article 6 links compliance to technical documentation, and the recycled-at-scale mechanism is expected to rely on downstream data about collection, sorting, and recycling facilities. That means teams should not treat the grade as a one-time spreadsheet value.

The main risk is publishing a broad recyclability claim before the package has been assessed under the right Article 6 pathway. A package can look recyclable to a consumer and still fail a PPWR grade because of component incompatibility, sorting limits, recycled-at-scale evidence, or the 2038 Grade A or B requirement.

A second risk is blending binding law, Commission overview text, and JRC technical recommendations into one undifferentiated source reference . Keep the legal rule, policy summary, and technical study clearly labelled.