PPWR Recyclability Grades A, B and C Explained
How the A/B/C scale is scored, what it does to your EPR fees, and what to fix before 2030
The PPWR grades packaging by how much of it can be recovered as secondary raw material: Grade A is 95 percent or higher, Grade B 80 percent or higher, Grade C 70 percent or higher. From 1 January 2030 anything scoring below 70 percent is banned from the EU market, and from 1 January 2038 Grade C is banned as well.
Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026, and to show that the 2030 grading date depends on delegated acts the Commission has not yet adopted.
A good grade keeps your products on the market and lowers your compliance bills. A failing grade means your packaging is legally banned.
Key takeaways
- The grade is set by recyclability by weight – 95 percent or more for A, 80 for B, 70 for C.
- From 2030 the floor is Grade C. From 2038 only Grades A and B may be placed on the market.
- 2030 is a floor, not a fixed date: Article 6 reads "1 January 2030 or 24 months after the design-for-recycling delegated acts, whichever is later", and those acts are due by 1 January 2028.
- Adhesives, labels, coatings and inks all count towards the score. A non-washable glue can drop a simple paper mailer from Grade A to failing.
What are the PPWR recyclability grades?
Under Article 6 of the Packaging Waste Regulation, packaging placed on the EU market must be recyclable, assessed through a grading system based on how much of the packaging unit can be recovered as secondary raw material.
Under the PPWR, 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. Eight years later, the law tightens again and eliminates Grade C entirely.
One qualification on that date. Article 6 ties the grading requirement to delegated acts that set the design-for-recycling criteria and the assessment method, and applies it from 1 January 2030 or 24 months after those acts enter into force, whichever falls later. The acts are due by 1 January 2028. So 2030 is the earliest the grades can bind, and a delay in Brussels pushes it out rather than compressing your preparation time. Treat 2030 as the planning date, not a guarantee.
The Annex II recyclability performance grade scale you must meet is:
| 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 |
What is the difference between "designed for recycling" and "recycled at scale"?
Many sellers confuse the theoretical recyclability of their packaging with what happens in the real world. The PPWR separates these into two 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, under the PPWR, 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 will recyclability grades 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. The same delegated acts that set the grades also govern eco-modulation, so when the grades apply national fee modulation follows the EU recyclability performance grades rather than each country's own tiers. That is one of the clearest points where the difference between EPR and the PPWR stops being academic and starts showing up on an invoice.
Until then, the national tiers are still what you are billed on. When the harmonised grades do land, a Grade A earns a discount and a Grade C a surcharge, until that format is banned outright in 2038.
If tracking material weights and calculating fees across different countries is currently breaking your spreadsheets, see how Gramta automates it.
What determines a recyclability grade in practice?
Your recyclability grade will not be about the primary material alone. The design-for-recycling parameters assess every component of the packaging unit, and the exact criteria arrive with the delegated acts. The factors below are the ones the regulation and existing national methodologies already point at.
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 should you do right now in 2026?
The grades are not in force, but two things already are: the technical-file duty, and the material data problem behind it.
Ask your manufacturers for the PPWR technical documentation for your packaging now – that file has been required since 12 August 2026 for the requirements that already apply, and it is the same document the recyclability grade will eventually live in. You need exact breakdowns of adhesive types, ink coverage and polymer densities. If a supplier turns out to use a non-compliant barrier layer, you have several years to source an alternative rather than several weeks. Getting your PPWR compliance sorted as an importer means building that evidence trail now.
Stop guessing your packaging fees and stressing over compliance deadlines. Turn your real e-commerce orders into the reports each scheme asks for instantly. Get started with Gramta.
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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, and packaging below that threshold cannot be placed on the EU market. Article 6 sets the date as 1 January 2030 or 24 months after the design-for-recycling delegated acts, whichever is later, so it can move later if those acts are late.
- 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.
- How does the recyclability grade affect my EPR fees?
- Not yet. The same delegated acts that set the A/B/C grades also govern eco-modulation, so once they land, national fee modulation follows the harmonised recyclability grades rather than each country's own tiers. Until then, you are billed on your national scheme's existing tiers.
- Which packaging design choices most affect a recyclability grade?
- Adhesives, labels, coatings and inks all count towards the score. A non-washable glue, a large plastic sleeve, or a grease-resistant coating can drop a simple paper mailer or PET bottle from Grade A to a failing, market-banned score.
Reviewed by Anton Kröger