Design-for-recycling under PPWR: the changes that lower your grade and your fee

Design for recycling under the new EU rules will dictate your packaging recyclability grade and your Extended Producer Responsibility fees. To keep access to the European market, your packaging must meet material-specific design criteria from 1 January 2030 – or 24 months after the Commission adopts the criteria, whichever falls later – which is also when eco-modulated fees start penalising hard-to-recycle formats.

Key takeaways

• Grading from 2030 at the earliest: all packaging placed on the EU market must be assessed and graded into recyclability categories A, B or C, with anything lower banned. The date moves later if the delegated acts due by 1 January 2028 are late.
• Modulated fees: Extended Producer Responsibility (EPR) contributions will be modulated based on these grades, directly penalising designs that are hard to recycle.
• Stricter standards from 2038: From 1 January 2038, only packaging of recyclability Grade A or B will be allowed on the market, phasing out Grade C formats.
• Supplier documentation: Economic operators must collect technical specifications and declarations of conformity from their suppliers to prove compliance.

How design choices dictate your recyclability grade and EPR fees

Online sellers often spend hours in spreadsheets trying to calculate packaging weights, wondering if they are doing it right. It is a common struggle. The European Union has resolved to harmonise these rules across the single market. Under the Packaging and Packaging Waste Regulation, your packaging design is now directly tied to your Extended Producer Responsibility (EPR) compliance costs.

When you select a packaging material - whether it is a clear rigid PET bottle or a flexible PE film - that choice determines your packaging category. From 2030, each category will be assessed under a harmonised "design for recycling" methodology. If your packaging design includes elements that disrupt the sorting or recycling process, your design-for-recycling score will drop. This score translates into a performance grade from A to C.

These grades do not just sit on a technical document. Under the mandatory eco modulation explained, national Producer Responsibility Organisations (PROs) must modulate their financial tariffs based on these grades. Packaging with a Grade A rating will benefit from fee reductions, while Grade C packaging will face heavy fee increases.

What design-for-recycling actually means under PPWR

The PPWR introduces a strict, harmonised definition of recyclability. To be considered recyclable, your packaging must be designed for material recycling, collected separately, sorted into specific waste streams without disrupting other streams, and eventually recycled at scale.

According to Article 6 of Regulation (EU) 2025/40, the European Commission will adopt delegated acts by 1 January 2028 to establish clear design-for-recycling criteria and recyclability performance grades for each packaging category listed in Annex II of the Regulation. This means every packaging unit you place on the market must have its design verified against these strict harmonised criteria.

These design parameters cover several specific elements of your packaging:

• Material composition: The use of mono-materials or highly compatible material combinations is preferred to ensure a high yield of secondary raw materials.
• Associated elements: Components like caps, closures, labels, and adhesives must be designed so they can be separated easily during the sorting process.
• Inks and adhesives: The use of non-washable inks or adhesives that leave residue on the recycled material will drag down your grade. Washable adhesives are preferred to ensure clean separation.

If you are shipping physical products to EU customers, you are legally responsible for verifying that your packaging complies with these rules. Non-compliance is not an option; packaging that fails to meet the minimum recyclability requirements will be banned from the market entirely.

Struggling to track the compliance of your materials? You can Get started with Gramta to automate your packaging volume reporting and ensure your materials are fully compliant before the new rules apply.

How the grading system drives your compliance fees

The PPWR replaces fragmented national standards with a single, harmonised grading scale. From 1 January 2030, all packaging placed on the market must achieve at least Grade C. Any packaging that falls below a 70% recyclability score is classified as technically non-recyclable and is banned from the market.

To help you understand how these will be calculated, you can read our guide on recyclability grades a b c. The table below outlines how these grades align with design criteria and fee modulation under the new EU framework.

This grading system will become even more stringent over time. Under the progressive tightening of the law, from 1 January 2038, packaging must achieve at least Grade B (80% recyclability) to be allowed on the market. Grade C packaging will be banned from that date.

The financial modulation of your EPR contributions must be implemented by Member States within 18 months from the date of entry into force of the relevant delegated and implementing acts. These modulated fees will ensure that manufacturers who continue to use difficult-to-recycle materials pay significantly more to finance waste management.

From 1 January 2038, packaging must achieve recyclability Grade B or higher to be placed on the EU market, effectively banning Grade C packaging formats.

In Germany, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register - ZSVR) already publishes the ZSVR minimum standard for determining recyclability under § 26(3) of the new Verpackungsrecht-Durchführungsgesetz (VerpackDG), in force since 12 August 2026, as a foundation for fee modulation.

Practical steps for online sellers to prepare

If you sell online, the responsibility to comply with these rules depends on your role in the supply chain. If you sell packaged products under your own brand or import packaged goods from outside the EU, you are legally considered the manufacturer or importer under the PPWR. This means you must draw up the technical documentation and sign the EU declaration of conformity.

However, if you ship products using standard, off-the-shelf mailers under no brand of your own, you are not the manufacturer of that packaging - the supplier is. In that case your primary duty is to obtain and retain the supplier's declaration of conformity, while continuing to register, report your packaging volumes and pay your national EPR fees. Those EPR duties have been directly applicable EU law since 12 August 2026, and below 10 tonnes a year in a Member State they become a reduced reporting data set under Article 44(8), not an exemption.

To ensure your business remains compliant and avoids delisting or fines, you should take several immediate actions:

1. Conduct a packaging audit: Review all your packaging formats, materials, and components to identify any non-recyclable elements.
2. Consult with your suppliers: Verify that your packaging suppliers can provide the necessary technical documentation and certificates of conformity.
3. Optimise your designs: Switch from composite or heavily coloured plastics to clear mono-materials or paper-based alternatives where possible.
4. Automate your compliance data: Keep accurate, auditable records of packaging materials, weights, and recyclability grades.

By acting now, you can prepare your business for the 2030 design requirements and avoid the sudden, costly fee increases associated with poor recyclability grades.

Keep your compliance clean and simple. Use Gramta to automate your packaging weight calculations and prepare your business for the coming PPWR requirements. Get started with Gramta today to secure your access to European markets.

Sources:

• Regulation (EU) 2025/40 on packaging and packaging waste
• ZSVR minimum standard for determining packaging recyclability
• European Commission packaging waste policy guidance