What are the Recyclability Performance Grades in PPWR?

The EU’s Packaging and Packaging Waste Regulation (PPWR) introduces recyclability performance grades that will determine whether packaging can remain on the market.

These grades will sit at the heart of future packaging compliance, influencing both market access and Extended Producer Responsibility (EPR) costs.

This article explains how the PPWR grading system works, what grades A, B and C mean in practice, and why packaging that falls below the threshold could create future compliance risks for producers, manufacturers, importers and brand owners.

PPWR defines recyclability performance using three grades: A, B and C.

Packaging that does not achieve at least grade C is considered technically non-recyclable and cannot be placed on the EU market once the rules apply.

In practical terms:

• Grade A = highest recyclability performance
• Grade B = good recyclability performance
• Grade C = minimum acceptable recyclability performance
• Below C = technically non-recyclable and non-compliant

While some industry commentary refers to “A–E grades”, PPWR legally defines only grades A to C, with anything below grade C treated as non-recyclable.

These grades will also be used to modulate EPR fees, meaning lower-performing packaging is likely to attract higher costs.

Annex II of PPWR sets out the performance thresholds behind each grade.

From 2030:

• Grade A means recyclability performance of 95% or more
• Grade B means recyclability performance of 80% or more
• Grade C means recyclability performance of 70% or more
• Below 70% means the packaging is considered technically non-recyclable

This means grade C is the minimum compliance threshold in the first phase of PPWR.

Under Article 6 of PPWR, packaging is considered recyclable if it meets fulfils the following conditions:

• It is designed for material recycling, so that recycled material is of sufficient quality to replace virgin raw materials, and
• It can be separately collected, sorted and recycled at scale, without negatively affecting the recyclability of other waste streams.

This definition makes clear that recyclability is not just about material choice, it depends on real-world system performance.

From 1 January 2030, or 24 months after the relevant delegated acts enter into force, packaging can only be placed on the EU market if it achieves grade A, B or C.

That means packaging that scores below grade C will fail the market access test.

For businesses, this creates a clear compliance threshold, if your packaging design cannot achieve at least grade C, it may need to be redesigned before the rule starts applying.

From 2035, PPWR assessment introduces an additional requirement.

Recyclability will no longer be assessed on design alone. Packaging must also be recycled at scale in practice.

This means compliance will depend on:

• Design for Recycling (DfR), and
• Recycled-at-scale performance

A packaging format could be well designed but still fail if there is insufficient collection, sorting or recycling infrastructure in place.

From 1 January 2038, the threshold tightens further.

From that point, packaging must achieve grade A or grade B to remain on the market. Grade C will no longer be sufficient.

This is a critical point for long-term packaging strategy.

A format that is compliant in 2030 could still become non-compliant later if it only achieves grade C. Businesses designing packaging now should keep that 2038 shift in mind rather than treating grade C as a future-proof solution.

The detailed criteria and methodology for assessing recyclability performance grades have not yet been published, but will be set out in delegated acts that the European Commission must adopt by 1 January 2028.

PPWR already sets out that the assessment will consider the packaging category, the predominant material, and factors such as whether packaging components can be separated, sorted and recycled effectively.

Annex II also highlights examples of design features that can affect recyclability, including:

• Additives
• Labels
• Sleeves
• Glues and adhesives
• The ability to separate components
• The efficiency of sorting and recycling processes.

This means recyclability will depend on more than the headline material. A pack made from a widely recycled material can still receive a lower grade if design features interfere with sorting or recycling.

For producers, manufacturers, importers and brand owners, recyclability grades will directly impact:

• Market access – whether packaging can legally remain on the EU market
• Cost exposure – through EPR fee modulation
• Packaging strategy – particularly for formats with long lifecycles
• Future risk – especially where packaging only meets grade C

In short, recyclability grades are not just a technical measure; they are a commercial and regulatory risk factor.

At Clarity, we support producers in understanding emerging packaging regulations and preparing for future compliance requirements.

As PPWR recyclability rules develop, businesses should begin to:

• Review current packaging formats
• Identify potential high-risk components
• Assess alignment with future recyclability thresholds
• Build data and evidence needed to demonstrate compliance

Taking action now will reduce the risk of costly redesigns, non-compliance and unexpected EPR costs in the years ahead.