EU Packaging & Packaging Waste Regulation · Reg (EU) 2025/40
What does your packaging recyclability grade mean?
Under the EU Packaging and Packaging Waste Regulation, packaging recyclability is graded A, B or C — and those grades decide market access and EPR fees. Pick your material and grade and see exactly what it means and by which dates you must act.
PPWR recyclability grades
Annex II, Table 3Grades are set per material by design-for-recycling delegated acts (due by 1 Jan 2028, not yet adopted). Order shown illustrates the A→C performance scale, not a measured percentage.
Act before your deadline
Allowed until 20382038your binding deadline
Grade C is recyclable and may be placed on the market from 2030, but from 1 January 2038 only grades A or B are allowed — you must improve before then.
EPR fees: higher modulated fees — grade C is penalised relative to A and B.
What to do
- Plan to improve from grade C to grade A or B before 1 January 2038 — from then, grade C may no longer be placed on the marketReg (EU) 2025/40, Art. 6 (only A/B from 1 Jan 2038)
- Expect EPR fees to be modulated by recyclability grade (better grade = lower fee), from about 18 months after the implementing actsReg (EU) 2025/40 (EPR fee modulation by recyclability grade)
PPWR recyclability timeline
- 2026PPWR appliesReg (EU) 2025/40, Art. 78 (application 12 Aug 2026)
- 2028Design-for-recycling delegated acts adoptedReg (EU) 2025/40 (DfR criteria by 1 Jan 2028)
- 2030Packaging must be recyclable in grade A, B or C to be placed on the marketReg (EU) 2025/40, Art. 6 + Annex II
- 2035'Recycled at scale' criteria added to the grade assessmentReg (EU) 2025/40 (from 2035)
- 2038Only grades A or B may be placed on the market — grade C phased outReg (EU) 2025/40, Art. 6 (from 1 Jan 2038)
The rule, in one line
The PPWR (Regulation (EU) 2025/40) applies from 12 August 2026. From 1 January 2030, packaging must be recyclable in grade A, B or C to be placed on the EU market; from 1 January 2038, only grades A or B are allowed — grade C is phased out. Extended-producer-responsibility fees are modulated by grade: better grades pay less. The design-for-recycling criteria that define the grades arrive in delegated acts due by 1 January 2028.
- 2030
- From 1 Jan 2030, packaging must be designed for recycling at grade A, B or C to be placed on the EU market.
- 2035
- From 1 Jan 2035, packaging must also be recyclable 'at scale' to keep its grade.
- 2038
- From 1 Jan 2038, only grades A or B are allowed — grade C is phased out.
Official sources: Regulation (EU) 2025/40 · European Commission — PPWR · EUR-Lex summary
What this tool is — and isn't
This checker restates the PPWR (Regulation (EU) 2025/40) market-access and EPR consequences for the grade you select. It is an estimate and orientation, not legal advice. The exact per-material thresholds that define grade A/B/C come in design-for-recycling delegated acts not yet adopted — confirm your grade against them.
How the determination works
1. The grade system
The PPWR expresses recyclability in performance grades A, B or C (Annex II, Table 3), based on design-for-recycling criteria. Grade A is the most recyclable; grade C is the lowest grade still considered recyclable.
2. Market access by date
From 1 January 2030, packaging must be recyclable in grade A, B or C to be placed on the EU market. From 1 January 2038, only grades A or B are allowed — grade C is phased out, and packaging below C cannot be sold from 2030.
3. EPR fees + the moving parts
EPR financial contributions are modulated by recyclability grade — better grades pay less — from about 18 months after the implementing acts. The detailed thresholds arrive via delegated acts due by 1 January 2028; 'recycled at scale' is added from 2035.
The grade bands in numbers: Annex II, Table 3
Regulation (EU) 2025/40 expresses recyclability as performance grades set out in Table 3 of Annex II. The grade reflects how much of the packaging unit, by weight, is designed to be recyclable — assessed per packaging category, meaning against the collection, sorting and recycling path that actually exists for that format and material, not in the abstract.
| Grade | Recyclable share per unit (by weight) | Market access under the PPWR |
|---|---|---|
| Grade A | 95 % or more | Marketable from 2030 and beyond 2038 — the band EPR fee modulation rewards most |
| Grade B | 80 % to below 95 % | Marketable from 2030 and beyond the 2038 cut |
| Grade C | 70 % to below 80 % | Marketable from 2030, phased out from 1 January 2038 |
| Below C | Under 70 % | Considered technically non-recyclable — cannot be placed on the EU market from 1 January 2030 |
What counts toward that percentage — separability of components, behaviour in state-of-the-art sorting, whether the recyclate is good enough to substitute virgin material — is fixed by the design-for-recycling delegated acts due by 1 January 2028, and those acts had not been adopted as of July 2026. The Commission’s March 2026 guidance confirms that until they apply, recyclability keeps being assessed under the existing essential-requirements framework — so any grade you use today is a self-assessment against the reference criteria below, not a certified result.
Sources: Reg (EU) 2025/40, Art. 6 + Annex II; Commission PPWR guidance document (C(2026) 3702) and press release IP/26/664, 30 March 2026.
2030 and 2038 — and the small print on both dates
| Date | What changes for recyclability |
|---|---|
| 12 Aug 2026 | The PPWR applies in general: the recyclability obligation exists formally, economic-operator duties and documentation start — but the grade gate is not yet substantive |
| 1 Jan 2028 | Deadline for the Commission’s design-for-recycling delegated acts that define the criteria and the grade methodology per packaging category |
| 1 Jan 2030 | Grade C floor: only packaging graded A, B or C may be placed on the market. Small print: this applies from 1 January 2030 or 24 months after the design-for-recycling delegated acts enter into force, whichever is the latest |
| 1 Jan 2035 | “Recycled at scale” joins the assessment: your packaging category must actually be collected, sorted and recycled EU-wide at a rate of at least 55 % a year (30 % for wood) in installed infrastructure |
| 1 Jan 2038 | Grade B floor: grade C is phased out; only A and B remain marketable |
The “whichever is the latest” clause is worth reading twice: if the delegated acts slip past January 2028, the 2030 gate slips with them, 24 months after the acts actually enter into force. Plan your redesigns for 2030 anyway — betting a packaging line on a Brussels delay is not a strategy — but it explains why the Commission’s own guidance treats the current period as transitional rather than enforceable grading.
Sources: Commission PPWR guidance, 30 March 2026 (the Art. 6(2)(a) timing clause); Reg (EU) 2025/40, Arts. 3 and 6 (recycled-at-scale definition and grade floors).
Design for recycling by material — what moves a grade
Until the delegated acts land, three reference sets tell you what will plausibly count: EN 18120, CEN’s design-for-recycling series for plastic packaging published in April 2026 (15 parts, from principles and terminology through sortability testing to per-stream guidelines for PET, PE/PP and PS); the German ZSVR minimum standard under §21 VerpackG, which has graded packaging against actual sorting and recovery practice for years (2026 edition in force since 1 January 2026); and the Commission’s March 2026 guidance. None of them has been cited in the Official Journal under PPWR Article 36, so none grants a presumption of conformity — they are the state of the art your technical file can cite, nothing more.
| Material | Typically helps the grade | Typically hurts the grade |
|---|---|---|
| Plastic | Mono-material PET, PE or PP in an established stream; colours a near-infrared sorter can detect; labels and adhesives that release in the wash step (the EN 18120 per-stream parts specify both) | Carbon-black pigments sorters cannot see; PVC/PVDC layers; full-body sleeves that mask the base polymer; barrier layers or additives incompatible with the stream |
| Paper & cardboard | High fibre yield; coatings kept minimal and separable in repulping | Full plastic lamination; fibre-composites whose layers do not separate; wet-strength or coating chemistry that survives repulping |
| Glass | Container glass in standard colours — a mature closed loop; closures and labels that come off in processing | Glass-ceramics; heavy enamel decoration; non-glass elements that stay attached through cullet processing |
| Metal | Steel and aluminium bodies — reliably sorted by magnet and eddy current | Very small formats that fall through sorting screens; composite closures; full sleeves that defeat metal detection |
| Composite / multi-material | Layers that separate in real processes; formats with a dedicated stream, such as beverage cartons where collection actually operates | Inseparable layers; adhesives that defeat separation; any format whose theoretical recyclability has no operating stream behind it |
Treat the table as design heuristics from the cited reference sets, not as legal thresholds — the per-material numbers arrive with the delegated acts. And remember the 2035 layer: where a recycling stream does not operate at scale in practice, the recycled-at-scale test can pull an otherwise well-designed pack down, whatever its design grade says.
Sources: CEN-CENELEC on EN 18120 (June 2026); EN 18120-1:2026; ZSVR minimum standard for recycling-friendly packaging.
EPR fees: the grade also decides your invoice
Separate from market access, the PPWR harmonises how extended-producer-responsibility fees are modulated: financial contributions are to be adjusted according to the recyclability performance grade — the better the grade, the lower the fee per kilogram placed on the market — with harmonised modulation criteria arriving through further delegated acts (Reg (EU) 2025/40, Art. 45 with recital 35).
In practice nobody is waiting for 2030. Germany already modulates against the annual ZSVR minimum standard under §21 VerpackG — the consultation on the next edition opened in June 2026 — and other national schemes run comparable bonus-malus systems. The marketplace layer is real too: platforms must verify sellers’ EPR registration, and Amazon’s May 2026 study of ten EU markets found registration forms averaging 16 fields per country, completion timelines of two to six weeks and portals often available only in the local language. Your grade does not gate your listing until 2030 — but it prices your packaging fees now, wherever a scheme modulates.
Frequently asked questions
- What are the PPWR recyclability grades?
- A, B or C (Annex II, Table 3 of Regulation (EU) 2025/40), based on design-for-recycling criteria. Grade A is the most recyclable; grade C is the lowest grade still allowed (until 2038).
- When must my packaging be recyclable?
- From 1 January 2030, packaging must be recyclable in grade A, B or C to be placed on the EU market. Packaging below C cannot be sold from then.
- What happens to grade C?
- Grade C is allowed from 2030, but from 1 January 2038 only grades A or B may be placed on the market — grade C is phased out. Plan to improve before then.
- How does the grade affect my EPR fees?
- EPR financial contributions are modulated by recyclability grade — better grades pay lower fees — from about 18 months after the implementing acts.
- Where do the exact grade thresholds come from?
- From the design-for-recycling delegated acts, due by 1 January 2028, set per packaging material. They are not yet adopted, so this tool works from your self-assessed grade.
- Is this legal advice?
- No. This tool restates the PPWR market-access and EPR consequences for the grade you select. It is orientation, not legal advice. Confirm your grade against the delegated act for your material.
- My packaging is 75% recyclable — what grade is that?
- In the Annex II, Table 3 bands, 70% to below 80% is grade C: marketable from 2030 but phased out from 1 January 2038, with higher modulated EPR fees. Note that the percentage that counts is the one measured under the design-for-recycling methodology once the delegated acts fix it — not your own estimate of recyclable content.
- Are the design-for-recycling delegated acts adopted yet (July 2026)?
- No. They are due by 1 January 2028 and had not been adopted as of July 2026. The Commission's March 2026 guidance confirms recyclability keeps being assessed under the existing essential-requirements framework until they apply — and the 2030 grade gate applies from 1 January 2030 or 24 months after the acts enter into force, whichever is the latest.
- What does 'recycled at scale' add in 2035?
- From 1 January 2035 the assessment also checks that your packaging category is actually recycled at scale EU-wide: at least 55% a year (30% for wood) collected, sorted and recycled in installed infrastructure, per the Article 3 definition. Good design alone stops being enough if the real-world stream doesn't operate.
- Can I use EN 18120 or the German minimum standard to prove my grade?
- As evidence, yes; as a legal presumption, no. Neither EN 18120 (CEN's 2026 design-for-recycling series for plastic packaging) nor the ZSVR minimum standard has been cited in the Official Journal under PPWR Article 36, so they support your technical documentation as state of the art. The binding grade comes only from the delegated acts due by 1 January 2028.