Recyclability A, B or C? The PPWR grades
The PPWR turns “recyclable” into a measurable legal concept. Every piece of packaging is placed, via design for recycling, into one of three performance grades: A (≥ 95%), B (≥ 80%) or C (≥ 70% of the weighted criteria). Below 70% it counts as technically non-recyclable. From 1 January 2030 only packaging reaching at least grade C may be placed on the market — and from 1 January 2038 only grade A or B.
What is recyclability under the PPWR?
Under Art. 6 of the PPWR, recyclability is the legally defined property that a piece of packaging is designed for material recycling and, as waste, can be separately collected, sorted and processed into secondary raw materials. It is assessed through design-for-recycling criteria and expressed in the performance grades A, B or C under Annex II.
The principle in Art. 6(1) is unambiguous: all packaging placed on the market has to be recyclable. “Recyclable” is therefore no longer a marketing promise but a verifiable criterion whose fulfilment the producer has to evidence in the technical documentation under Annex VII. A green recycling arrow on the pack does not suffice as evidence.
- Grade A
- ≥ 95% of the weighted DfR criteria
- Grade B
- ≥ 80% of the weighted DfR criteria
- Grade C
- ≥ 70% of the weighted DfR criteria
- Below 70%
- Technically non-recyclable
What do the performance grades A, B and C mean?
The performance grades A, B and C are classes indicating what share of the weighted design-for-recycling criteria of its category a piece of packaging meets: A from 95%, B from 80%, C from 70%. Below 70% the packaging counts as technically non-recyclable. The higher the grade, the better the material can be processed at scale into high-quality secondary raw materials.
Performance grade & threshold
- A — ≥ 95% of the weighted DfR criteria
- B — ≥ 80% of the weighted DfR criteria
- C — ≥ 70% of the weighted DfR criteria
- Below 70% — no valid grade
Consequence for placing on the market
- Marketable indefinitely — including after 2038
- Marketable indefinitely — including after 2038
- Marketable only until 31.12.2037 — no longer from 2038
- No placing on the market from 2030 (technically non-recyclable)
A common piece of misinformation: the PPWR works with three performance grades A, B and C — NOT with “school grades A to E”. Anyone reading about an A–E scale is confusing the PPWR with other assessment systems. For conformity only the thresholds 95% / 80% / 70% from Annex II count.
From when does which minimum recyclability grade apply (2030 vs 2038)?
From 1 January 2030 packaging may only be placed on the market if it reaches at least grade C (that is, A, B or C). From 1 January 2038 the requirement tightens: grade C falls away, and only packaging of grade A or B remains marketable — meaning at least 80% of the DfR criteria met.
The bulk of Regulation (EU) 2025/40 becomes applicable (Art. 71). The recyclability grades take effect in stages from 2030.
Only packaging of grades A, B or C may be placed on the market. Below 70% placing on the market is no longer permitted.
Beyond the design, what counts is whether the material is actually recycled at scale — as a second assessment factor.
Grade C falls away. Only packaging of performance grade A or B (≥ 80%) remains marketable.
What happens to packaging below 70%?
Packaging meeting less than 70% of the weighted design-for-recycling criteria counts as technically non-recyclable. It reaches none of the three performance grades and may in principle no longer be placed on the market from 1 January 2030. Affected packaging has to be redesigned by then so that it reaches at least grade C.
In practice that means: material combinations that are hard to separate, disruptive components, problematic colours or multilayer constructions push the assessment down. Anyone running packaging below grade B today should set up a redesign roadmap — not least to be ready for 2038, when grade C no longer suffices.
What is design for recycling?
Design for recycling (DfR) describes designing packaging so that it can be recycled. The DfR criteria of a packaging category determine which performance grade a packaging item reaches. Criteria concern, among other things, the choice of material, the separability of components, disruptive constituents and suitability for established sorting and recycling processes.
The specific design-for-recycling criteria per packaging category are not laid down in the regulation itself but are expected to come via a delegated act of the European Commission. A fixed date should not be asserted as settled — check the status of the act regularly before you finalise a grade.
What does “recycled at scale” mean from 2035?
“Recycled at scale” means that the material of a packaging category is not merely recyclable in theory but is actually recycled to a relevant extent. From 1 January 2035 this factor joins the design-for-recycling assessment as a second condition. A piece of packaging can therefore be well designed and still only pass if functioning collection and recycling streams exist for its material.
For packaging developers and purchasing that means: beyond the design itself, you should check whether the chosen material is in fact recycled to any meaningful extent. Materials with weak recycling streams can become a risk from 2035, even where the DfR assessment holds up.
How is multi-part packaging assessed?
Multi-part packaging is assessed per packaging component: carton, inlay, lid and label each enter the assessment separately. A well recyclable carton can be pulled into a lower overall grade by a hard-to-separate inlay or a disruptive label. It is precisely this component-level view that makes clean capture of the constituents so important.
In practical terms: master data has to represent every component with its material, weight and disruptive features. Only then can the performance grade be derived traceably and evidenced in the technical documentation.
How does the recyclability grade relate to EPR fees?
The performance grade steers the eco-modulation of EPR contributions under extended producer responsibility. Put simply: a better recyclability grade tends to mean lower financial contributions, a worse one higher. Recyclability therefore has not only a regulatory but an immediately economic dimension.
For the business case it is therefore worth factoring EPR modulation into the calculation of a packaging redesign early. Moving from grade C to B can partly pay for itself through lower fees — and makes the packaging 2038-proof at the same time.
Certain packaging is exempt from Art. 6, including primary packaging of medicinal products, contact-sensitive packaging of medical devices and packaging for dangerous goods (Art. 6(11)). For these the performance grades A/B/C do not apply in the same way — but the exemption should be checked specifically per product.
Sources
- Regulation (EU) 2025/40 (PPWR), Art. 6 (recyclable packaging) and Annex II (performance grades A/B/C, DfR criteria).
- Regulation (EU) 2025/40, Art. 6(11) (exemptions including medicinal products, medical devices, dangerous goods).
- Regulation (EU) 2025/40, Art. 71 (date of application 12.08.2026).
- Reviewed: July 2026. Not legal advice — the final assessment follows the EU legal acts.
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