If you are approving a new cup, box or pouch specification this year, it will still be on the market when the PPWR's recyclability grades start to decide whether it can be sold in the EU. The PPWR recyclability grades in Regulation (EU) 2025/40 score each packaging unit A, B or C on design for recycling. From 1 January 2030 at the earliest, packaging below grade C cannot be placed on the market, and from 1 January 2038 only grades A and B remain. EPR fees will also be modulated by grade, so the grade will affect cost before it affects legality.
This page explains how the grading works, what is fixed in the Regulation and what is still being written, and what it means for the paper, board and flexible formats buyers order from us. For the wider PPWR context (roles, PFAS, reuse, dates), read our PPWR overview for foodservice and e-commerce buyers first. This is orientation, not legal advice; confirm obligations with your competent authority or compliance scheme.
Status as of October 2026. Sources: Regulation (EU) 2025/40, Article 6 and Annex II, on EUR-Lex (eur-lex.europa.eu/eli/reg/2025/40/oj), and Commission guidance notice C(2026) 3702 of 5 June 2026 (non-binding).
What are the PPWR recyclability grades?
The PPWR recyclability grades are three performance classes, A, B and C, that express how well a packaging unit is designed for recycling, as a weighted percentage under criteria the Commission will adopt for each packaging category. Grade A is at least 95 %, grade B at least 80 % and grade C at least 70 %. Below 70 %, packaging is "technically non-recyclable" and, once the grades apply (1 January 2030, or 24 months after the delegated acts if later), cannot be placed on the market.
| Grade (Annex II, Table 3) | Design-for-recycling assessment per unit | 2030 | 2035 | 2038 |
|---|---|---|---|---|
| A | 95 % or more | Allowed | Allowed if also recycled at scale | Allowed if also recycled at scale |
| B | 80 % or more | Allowed | Allowed if also recycled at scale | Allowed if also recycled at scale |
| C | 70 % or more | Allowed | Allowed if also recycled at scale | Cannot be placed on the market |
| Below 70 % | Technically non-recyclable | Cannot be placed on the market | Cannot be placed on the market | Cannot be placed on the market |
The percentage is not "how much of this pack gets recycled in practice". It is a score from a design-for-recycling assessment that weighs the packaging's materials and components against criteria for its category. Actual recycling volumes enter later, through the separate recycled-at-scale test.
Why do some sources talk about grades A to E?
Earlier drafts of the PPWR, including the Commission's 2022 proposal, used a five-grade scale from A to E. The adopted Regulation (EU) 2025/40 has only three grades, A, B and C, plus the "technically non-recyclable" band below 70 %. If a supplier, consultant or software tool quotes a "grade D" or "grade E", it is using the draft scale, and the result should be re-expressed against Annex II Table 3.
When do the grades apply?
The grades take effect from 1 January 2030 or 24 months after the design-for-recycling delegated acts enter into force, whichever is later. The Commission must adopt those acts by 1 January 2028. The recycled-at-scale requirement follows from 1 January 2035 (or five years after its implementing acts, if later), and only grades A and B are allowed from 1 January 2038.
| Date | What happens | Article |
|---|---|---|
| 12 Aug 2026 | General principle that packaging must be recyclable (Art 6(1)) applies; until the delegated acts exist, the old Packaging Directive requirements and standards such as EN 13430 remain the reference (Commission guidance) | Art 6(1) |
| By 1 Jan 2028 | Commission to adopt design-for-recycling criteria and grades per packaging category, and a framework for EPR fee modulation | Art 6(4) |
| About 18 months after the delegated and implementing acts | EPR fees modulated by grade | Art 6(8) |
| 1 Jan 2030, or 24 months after the delegated acts if later | Only grades A, B or C may be placed on the market | Art 6(3) |
| By 1 Jan 2030 | Commission to adopt recycled-at-scale methodology | Art 6(5) |
| 1 Jan 2035, or 5 years after those implementing acts if later | Packaging must also be recycled at scale | Art 6(2)(b) |
| 1 Jan 2038 | Only grades A or B | Art 6(3) |
Two details matter for planning. First, the Commission's guidance says manufacturers do not need to run the PPWR conformity assessment for recyclability until the delegated acts enter into force, so any "PPWR grade" quoted today is an estimate. Second, the Regulation gives operators three years to comply with new or updated design-for-recycling criteria, so the criteria may be revised during the life of a long-running item.
How is the grade assessed?
The manufacturer assesses each packaging unit against the criteria for its category in Annex II Table 1, weighting the result per unit. Integrated components (a laminated liner, a glued-in window) are assessed with the main body; separate components (a lid, a loose sleeve) are assessed separately; and every component must be compatible with established collection, sorting and recycling and must not hinder recycling of the main body (Article 6(9)).
Annex II Table 4 lists the parameters the criteria will draw on. The ones most relevant to printed paper and flexible packaging:
- Additives and coatings that can mis-sort packaging or contaminate the recyclate.
- Labels and sleeves: coverage, material and adhesive. See labels and recyclability for how facestock and adhesive affect the result.
- Closures and small components, including linings and seals.
- Inks, varnishes and adhesives.
- Barrier layers and their separability.
- Composite structure: how much non-predominant material is present and whether it separates.
The categories matter as much as the parameters. Paper and board appear in two categories: category 2 (paper/cardboard packaging, including flexible paper packaging) and category 3 (composite packaging of which the majority is paper or cardboard, including polyolefin-laminated paper cups, plastic-laminated or metallised board and paper with plastic liners or windows). Plastic flexibles fall under PE flexible (category 11), PP flexible (13) or other flexible plastics including multi-materials (18). Your item's category determines which criteria it will be measured against.
How will grades affect EPR fees?
EPR fees must be modulated by recyclability grade about 18 months after the delegated and implementing acts enter into force, following a framework set in the delegated acts. In practice, a grade C item is likely to cost more in EPR fees than an equivalent grade A item from the late 2020s, well before grade C is phased out in 2038.
National schemes already differentiate fees by recyclability in several countries, and the PPWR framework will harmonise the basis. Fee levels themselves will still be set nationally, so the cost gap between grades will vary by country. National scheme details for Germany and Austria are in our guide to packaging compliance in Germany and Austria.
What is not yet known?
The thresholds and dates are fixed in the Regulation; the criteria that produce the percentages are not. As of October 2026, the design-for-recycling delegated acts for each packaging category have not been adopted, and neither has the recycled-at-scale methodology.
Still open:
- The weighting method and material-specific criteria for each category, including how much coating, ink or adhesive a paper item can carry and still reach grade A or B.
- How coated paper, PE-lined cups and paper with windows will be scored within category 3, and which laboratory test methods will be referenced.
- The recycled-at-scale thresholds per category.
- The exact EPR fee modulation in each Member State.
Industry tools such as the CEPI laboratory repulpability method for paper and RecyClass for plastics are useful indicators of direction, and the delegated acts must take European standards into account. Treat them as preparation, not as a PPWR grade.
Design implications by material family
The safest direction for every family is the same: keep the predominant material as pure as function allows, make other components easy to separate, and collect test evidence now. The specifics differ by format, and detailed comparisons sit on the pages linked below.
| Format | Usual category | Main grade risks | Design direction | Detailed page |
|---|---|---|---|---|
| Paper and board with barrier coatings (takeaway boxes, food bags, wraps) | 2 or 3, depending on coating | Coating weight and type, PFAS-free grease barrier, heavy ink coverage, wax | Lowest coat weight that holds the food; dispersion or refined greaseproof where performance allows; repulpability test on the coated paper | barrier coatings for paper packaging |
| Paper bags with film windows | 3 | Window film material and size; adhesive | Smaller windows, film chosen for separation in the pulper, or windowless designs | window paper bags |
| Corrugated mailer and shipping boxes | 2 | Plastic tapes, laminated finishes, foil, mixed inserts | Paper tapes or glued closures; paper-based inserts; varnish instead of film lamination | custom printed mailer boxes |
| PE-lined paper cups | 3 | PE share, separability at the mill, availability of cup-capable mills | Thinner or one-side linings, dispersion linings tested for hot drinks, alignment with cup collection routes | paper cup linings |
| Multi-material laminates and pouches (PET/PE, foil) | 18 | Incompatible polymers, aluminium foil | Move to mono-material structures where barrier allows | recyclable mono-material pouches |
| Mono-PE bags and pouches | 11 | Barrier layers, inks, PET or paper labels, zipper material | Keep zipper and labels PE; thin barrier coatings; light ink coverage | recyclable mono-material pouches |
Paper and board with coatings and windows
For paper items, the pulper decides recyclability: fibres must separate and non-fibre components must either disperse harmlessly or screen out cleanly. A light, well-chosen barrier and a small separable window are typically better positioned than a heavy laminate or a large window with strong adhesive. Ask for repulpability test results on the finished coated paper, not only on the coating datasheet. Print design matters less than structure, but full-coverage metallic inks and heavy varnish should be reviewed.
Corrugated boxes
Plain corrugated board is among the most widely recycled packaging materials in Europe, so the grade risk for e-commerce boxes sits mainly in additions: plastic tear strips, film-laminated print, foil blocking, magnets and foam inserts. Design these out first. Box sizing and empty space are a separate PPWR topic covered in e-commerce packaging and the PPWR.
PE-lined cups
PE-lined cups are composite paper packaging, and their grade will depend on how the criteria treat polyolefin linings and on mill capability to separate them. That is distinct from the Annex V dine-in restriction from 2030, which Commission guidance applies to paper-based packaging with 5 % or more plastic, and from the SUP Directive, which treats any plastic-lined cup as a single-use plastic product. Recycling routes for cups are covered in paper cup recycling.
Laminates, pouches and mono-PE
For plastic flexibles, the big step is from multi-material to mono-material. A PET/PE or foil laminate falls into "other flexible plastics including multi-materials", where recycling routes are limited. Mono-PE or mono-PP structures with compatible barrier coatings target the PE or PP flexible categories. Recycled-content targets for plastic packaging from 2030 at the earliest run alongside the grades; laminate options are compared in pouch laminate structures.
Which packaging is exempt from the recyclability requirements?
Article 6(11) excludes a short list of packaging types, mostly in medical, pharmaceutical, infant-food and dangerous-goods applications. Ordinary foodservice and e-commerce packaging is not exempt.
The Article 6 exemptions are:
- Immediate packaging of human and veterinary medicinal products, and outer packaging where it is needed to preserve the medicinal product's quality.
- Contact-sensitive packaging of medical devices and in vitro diagnostic medical devices.
- Contact-sensitive packaging for infant formula, follow-on formula, processed cereal-based food, baby food and food for special medical purposes.
- Packaging used to transport dangerous goods.
- Sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax (EPR fee modulation still applies).
Separately, Article 6(10) allows "innovative packaging" that does not meet the criteria to be made available for up to five years from the end of the year it was placed on the market, after notifying the competent authority with technical justification. It is a narrow route, not a planning assumption. The Commission must review the exemptions by 1 January 2035.
How do grades relate to recyclable claims and compostable packaging?
A PPWR grade is a regulatory classification, not a marketing claim. Under the Empowering Consumers Directive (EU) 2024/825, which applies from 27 September 2026, environmental claims need substantiation, and a grade cannot be printed as a consumer label unless the harmonised rules allow it. Compostable packaging outside the few formats listed in Article 9 must also be designed for material recycling. Claim wording is covered in recyclable, compostable and biodegradable packaging.
Next step: grade-proof your highest-volume items
List your top items by annual volume with their structure: predominant material, coating or lining, windows, inks, adhesives, closures. Mark anything that adds a second material and ask your supplier for repulpability or recyclability test evidence on the current structure. Record the results in the technical file behind your PPWR declaration of conformity, and plan sorting labels alongside any redesign with our guide to PPWR labelling requirements. For a structure review on a new or existing item, send the specification through our contact page; options are confirmed at quotation and technical review.