How to Prove Packaging Recyclability Under the PPWR

To prove packaging recyclability under the PPWR, you assess each packaging type against Design for Recycling criteria and record the material weights, component breakdown and resulting grade in your Annex VII technical file. Grade A is 95 percent recyclable by weight, Grade B is 80 percent, Grade C is 70 percent. From 1 January 2030, anything below 70 percent is banned from the EU market.

Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026, and to tie the recyclability grades to the delegated acts that trigger them.

Today you report the total weight of your materials. From 2030 you will also have to demonstrate, against a published method, that they can be recycled.

Key takeaways

• Packaging will be graded from A to C against harmonised Design for Recycling criteria.
• Materials scoring below 70 percent recyclability are banned from 1 January 2030, or 24 months after the delegated acts setting the criteria, whichever is later.
• The technical file you have had to hold since 12 August 2026 is where that proof will eventually live, so the material data is worth gathering now.
• Grades will drive your EPR costs, because the same delegated acts make national fee modulation follow them.

What are the PPWR recyclability performance grades?

The days of making vague claims that a mailer bag is "100 percent recyclable" are numbered. Article 6 will require every packaging unit to be assessed and assigned a formal recyclability performance grade based on its material composition, from 1 January 2030 or 24 months after the design-for-recycling delegated acts enter into force, whichever falls later.

The recyclability performance grades listed in Annex II divide packaging into three acceptable tiers. Grade A packaging is 95 percent or more recyclable by weight. Grade B packaging is 80 percent or more recyclable. Grade C packaging is 70 percent or more recyclable.

Design theory is no longer enough. If your shipping materials score below a 70 percent recyclability threshold in your technical documentation, the European Union will classify them as technically non-recyclable and ban them from the single market entirely.

The recyclability grading system will become even more aggressive over time. By 1 January 2038, the law phases out Grade C completely. From that date, only packaging achieving Grade A or Grade B will be legally permitted for sale or distribution within the European Union.

How do you officially assess and document recyclability?

You cannot just guess your packaging's grade. If your business acts as the legal manufacturer under the new rules or importer, you must calculate the recyclability performance using specific Design for Recycling criteria. These criteria dictate how easily the packaging components can be separated, sorted, and processed into high-quality secondary raw materials.

The European Commission is mandated to publish the exact harmonised criteria and assessment methodology via delegated acts by 1 January 2028. However, national authorities are not waiting for 2028 to enforce these principles. For example, Germany's Central Agency Packaging Register (ZSVR) updated the 2025 minimum standard for determining recyclability to intentionally mirror the upcoming European classification system, forcing companies to adapt early.

When the grades apply, the assessment goes inside your Annex VII technical documentation – exact material weights, component breakdowns and the calculated grade, backing your Declaration of Conformity. That file itself is not a future obligation: it has been required since 12 August 2026 for the requirements already applicable, so the recyclability evidence joins a document you should already be maintaining.

What does "recycled at scale" mean for 2035?

Proving that a custom polybag is technically capable of being recycled in a laboratory is only the first hurdle. The law requires that the material is actively recovered in the real world.

From 1 January 2035, a new factor is added to your assessment: the "recycled at scale" requirement. This means your packaging must be actively collected, sorted, and recycled across established infrastructure representing a significant portion of the European market. If you design a novel, complex material that fits a Grade A profile on paper but local municipal facilities cannot physically process it, that packaging will fail the assessment and lose its market access.

How does your recyclability grade affect EPR fees?

The most immediate impact of your recyclability assessment is financial. Understanding how EPR and PPWR interact is vital because the European Union is using your technical grades to dictate your tax burden.

The delegated acts that establish the grades also govern eco-modulation, so Extended Producer Responsibility contributions will be modulated according to these performance grades rather than each country's own tiers. Invest in mono-material packaging that reaches Grade A and you earn discounts on your national waste fees; rely on complex multi-material formats that barely scrape a Grade C and you face surcharges. Until those acts apply, your fees are still modulated by the national methodologies your PRO uses today.

Do not wait until 2030 to discover your packaging fails the assessment. You need to map your material data now to avoid massive cost increases and blocked shipments. Get started with Gramta to automate your packaging material tracking and secure your compliance documentation before the enforcement begins.

Sources:

• Regulation (EU) 2025/40 – Article 6: Recyclable packaging
• Regulation (EU) 2025/40 – Annex II: Recyclability performance grades
• ZSVR: Information about the minimum standard for determining the recyclability of packaging – 2025 edition
• The European Packaging and Packaging Waste Regulation (PPWR): A Strategic Compliance Framework for Global Supply Chains