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. The PPWR definition of recycled at scale sets an EU-wide annual threshold of at least 30% for wood and 55% for every other Annex II Table 2 packaging category, based on installed infrastructure and operational collection, sorting, and recycling processes.

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.

Article 6 does not apply to specified immediate medicinal and veterinary packaging, contact-sensitive medical-device and in vitro diagnostic packaging, certain necessary outer medicinal packaging, specified infant and medical-food packaging, dangerous-goods transport packaging, and listed sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain, or wax. The EPR fee-modulation rule in Article 6(8) still applies to the listed material formats.

Innovative packaging has a separate, time-limited route from 2030. It may be made available for up to five years from the end of the calendar year in which it was placed on the market only after the economic operator notifies the competent authority and supplies technical details plus a timeline for meeting recycled-at-scale requirements. A packaging refresh for presentation or marketing is not innovative packaging under the PPWR definition.

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.

Do not publish a broad recyclability claim before assessing the package under the applicable 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.

Keep binding law, Commission overview text, and JRC technical recommendations distinct. Label the legal rule, policy summary, and technical study by source type.