Recyclability: what it means and why you have to request the data from your suppliers

From 1 January 2030, only recyclable packaging may be placed on the EU market. That sounds like a task for packaging development. In practice it starts in purchasing: whether packaging meets the requirements depends on data about material, structure, colours, adhesives and labels that almost always sits with the supplier. This article explains what recyclability means under the EU Packaging and Packaging Waste Regulation (PPWR), which information you need for the assessment and how to request it from your suppliers completely and reliably.

Legal basis

Art. 6 and Annex II of Regulation (EU) 2025/40

Minimum grade from 2030

Grade C, i.e. at least 70% of the criteria

Minimum grade from 2038

Grade B, i.e. at least 80% of the criteria

Supplier obligation

Provide information and documents to the manufacturer (Art. 16)

What recyclability means under the PPWR

Under Art. 6 PPWR, packaging is recyclable if it is designed so that, after use, it can be collected separately, sorted and processed into secondary raw materials that replace primary raw materials. What matters is not whether the material can be recycled in principle, but whether this specific piece of packaging actually reaches recycling through the established collection and sorting systems and can be processed cleanly there.

This is measured through design-for-recycling criteria set per packaging category. The share of weighted criteria met determines a performance grade: A from 95%, B from 80%, C from 70%. Below 70%, packaging counts as technically non-recyclable. From 2035 a second condition applies: the material must not only be designed for recycling but also actually be recycled at scale.

1. 12 Aug 2026

   PPWR applies

   Conformity assessment, technical documentation and the suppliers’ duty to cooperate are binding.

2. 1 Jan 2030

   Recyclability mandatory

   Packaging must reach at least grade C. The criteria per category follow in a delegated act.

3. 1 Jan 2035

   Recycled at scale

   Besides design, it counts whether the material is actually recycled in relevant quantities.

4. 1 Jan 2038

   Grade C dropped

   Only packaging of grade A or B may still be placed on the market.

What recyclability depends on

Packaging rarely consists of a single material. Carton, insert, film, lid, label, adhesive and ink are looked at individually, and a single component that is hard to separate can pull down the overall assessment. Typical levers are:

• Material type and structure: mono-material or composite, number and type of layers, barriers and coatings.
• Colours and additives: carbon-black colours that sorting plants cannot detect, or fillers that change the density.
• Labels and sleeves: material, area relative to the packaging and whether they detach in the recycling process.
• Adhesives and closures: whether they are water-soluble, separable and compatible with the main material.
• Weight per component: without weight shares you cannot calculate which part of the packaging meets which criterion.

None of this can be reliably read from the outside. A film can look like pure polyethylene and still contain a barrier layer made of a different plastic. A label can appear recycling-friendly and be applied with an adhesive that does not dissolve in the washing process. Recyclability can therefore only be assessed with data from those who make the packaging or its components.

Why you have to request the data from your suppliers

The PPWR assigns responsibility clearly. The manufacturer, meaning the company that makes the packaging or has it made and places it on the market under its own name, assesses conformity and records the result in the technical documentation under Annex VII. With the EU declaration of conformity it takes responsibility for that. The data it needs, however, it usually does not hold itself.

This is where Art. 16 comes in: suppliers of packaging and packaging materials must provide the manufacturer with all information and documents it needs to demonstrate conformity. This is not a voluntary favour but a legal obligation. It has applied since 12 August 2026, even though the minimum grade only takes effect from 2030.

There is also a practical reason: the criteria per packaging category will only be set by delegated act. If you already have the raw data for your packaging in a structured form, you can calculate the performance grade as soon as the criteria are fixed, instead of chasing dozens of suppliers at that point. If you still need to redesign before 2030, you need that time for development, testing and new tooling.

What to request from your supplier

A good request is specific. Instead of asking generally for “proof of recyclability”, ask for the data from which the assessment can be derived. Per packaging and per component, that usually means:

Also ask for a contact person and a commitment to report changes to material or structure. A recyclability assessment is only valid as long as the packaging stays the same. If the supplier switches the adhesive or the film, the grade can shift.

How a supplier request works in practice

• Record your packaging: list all packaging you place on the market and assign a supplier to each component.
• Standardise the request: use the same fields for all suppliers. Free-text answers by email are hard to evaluate.
• Cite the legal basis: refer to Art. 16 PPWR. That makes clear this is a legal duty to cooperate, not a customer survey.
• Set a deadline: four to six weeks is realistic. Follow up when data is missing.
• Check the answers: do weights and material data match the sample? Are components missing?
• Document the result: file answers, evidence and your assessment in the technical documentation. It must be kept for five years, ten for reusable packaging.

When suppliers do not respond

Not every supplier responds right away. Smaller businesses and suppliers outside the EU in particular often do not yet know the PPWR in detail. Briefly explain why you need the data and offer a simple template. If no answer comes, document that and add the requirement to future supply contracts. When you put packaging out to tender, you can make providing the data a condition from the start.

For packaging where no reliable data can be obtained, the only options left are your own analysis or switching supplier. Both take time. The earlier you know where the gaps are, the more room you have before 2030.