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.
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.
Official sources: Regulation (EU) 2025/40 · European Commission — PPWR · EUR-Lex summary
Act before your deadline
2038your 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)
Per-packaging export
PPWR grade roadmap (PDF) · €39
A print-ready roadmap: your grade verdict, the market-access and EPR consequences, the full PPWR timeline and the steps to reach grade A or B — built from the answers above.
This is guidance, not legal advice. The export restates the PPWR for your inputs; confirm your grade against the design-for-recycling delegated act.
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.
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.