PPWR Recyclability Grades A, B and C Explained
From 2030, the PPWR assigns a recyclability grade to every packaging unit. Learn how grades A, B, and C will impact your market access and EPR fees.
If you sell physical products to EU customers, your packaging is about to be graded like a school exam. Under the new Packaging and Packaging Waste Regulation (PPWR), every box, mailer, and bottle will receive a recyclability grade based on its design and material composition.
A good grade keeps your products on the market and lowers your compliance bills. A failing grade means your packaging is legally banned. Here is how the new A, B, and C grading scale works, how it changes your Extended Producer Responsibility costs, and what you need to do today.
What are the PPWR recyclability grades?
Under Article 6 of the Packaging Waste Regulation, all packaging placed on the EU market must be recyclable. To enforce this, the European Union has created a grading system based on how much of the packaging unit can be successfully recovered as secondary raw material.
From 1 January 2030, your packaging must achieve at least a Grade C. If it scores below 70 percent, it is classed as technically non-recyclable and banned from the market. 8 years later, the law tightens again, completely eliminating Grade C packaging.
Here is the Annex II recyclability performance grade scale you must meet:
| Grade | Recyclability performance by weight | Status from 1 January 2030 | Status from 1 January 2038 |
|---|---|---|---|
| Grade A | 95 percent or higher | Compliant | Compliant |
| Grade B | 80 percent or higher | Compliant | Compliant |
| Grade C | 70 percent or higher | Compliant | Banned from the market |
| Failing | Lower than 70 percent | Banned from the market | Banned from the market |
"Designed for recycling" versus "recycled at scale"
Many sellers confuse the theoretical recyclability of their packaging with what happens in the real world. The PPWR separates these into 2 distinct milestones.
The 2030 deadline is strictly about being designed for recycling. This means your packaging is technically capable of being recycled based on its material properties. If your materials clear the design requirements in the PPWR timeline, you can legally sell them.
However, from 1 January 2035, your packaging must also be recycled at scale. This means the physical infrastructure to collect, sort, and process your specific packaging format must actually exist and operate commercially across the European Union. A composite material that works perfectly in a laboratory but cannot be processed by standard municipal waste facilities will lose its compliant status.
How recyclability grades will change your EPR fees
Right now, you pay Extended Producer Responsibility fees to national Producer Responsibility Organisations (PROs) based on the weight and material of your packaging. Many countries already use their own national eco-modulation tiers to penalise bad design. For example, Denmark currently applies a 35 percent malus surcharge on poorly recyclable materials, and France operates a complex bonus-malus system through Citeo.
The PPWR will replace this fragmented approach with a harmonised framework. Once the grades apply in 2030, national fee modulation is tied to the EU recyclability performance grades rather than each country's own tiers, which is one of the clearest points where the difference between EPR and the PPWR stops being academic and starts showing up on an invoice.
If you achieve a Grade A, you will receive a financial discount. If you scrape by with a Grade C, expect to pay surcharge fees until the format is banned entirely in 2038.
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What determines a recyclability grade in practice?
Your grade is not just about the primary material. The official parameters for design for recycling criteria evaluate every single component of your packaging unit.
To hit that 95 percent Grade A threshold, you must look closely at:
- Adhesives: Non-washable glues contaminate recycling streams. Washable adhesives ensure clean separation and protect your grade.
- Labels and sleeves: A large plastic sleeve on a PET bottle can confuse optical sorting machines and render the underlying material invisible to scanners.
- Barriers and coatings: Grease-resistant coatings and multi-material barriers often make packaging impossible to recycle mechanically.
- Colours and inks: Heavily dyed plastics or papers downgrade the quality of the recycled output, lowering your score significantly.
The presence of non-washable adhesives, heavy dyes, and barrier coatings can drop a simple paper mailer from a Grade A to a market-banned failing score.
What you must do right now in 2026
Do not wait until the end of the decade to figure out if your packaging passes the test. To prove your grade, you will need detailed material data from your suppliers.
Start by asking your manufacturers for the PPWR technical documentation for your packaging today. You need exact breakdowns of adhesive types, ink coverage, and polymer densities. If you find out a supplier uses a non-compliant barrier layer, you have time to source an alternative before it becomes a market access issue. Getting your PPWR compliance sorted as an importer means building this evidence trail now.
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Frequently asked questions
- What is the minimum recyclability grade under the PPWR?
- From 1 January 2030, all packaging must achieve at least a Grade C, meaning it is 70 percent recyclable by weight. Packaging below this threshold cannot be placed on the EU market.
- When does the PPWR ban Grade C packaging?
- From 1 January 2038, the rules tighten and Grade C packaging will be banned. Only packaging that achieves Grade A or Grade B will be permitted on the market.
- What is the difference between designed for recycling and recycled at scale?
- Designed for recycling is a 2030 requirement focusing on the material composition of the packaging. Recycled at scale is a 2035 requirement ensuring the packaging is actually collected, sorted, and recycled in practice across the EU.