PPWR recyclability grades: A, B and C explained

PPWR recyclability grades are the three performance classes, A, B and C, that Regulation (EU) 2025/40 sets for packaging placed on the EU market. They measure how much of a packaging’s weight is effectively recyclable. This page explains the thresholds, the deadlines, and how a grade is assessed and documented in practice.

The grades sit in Annex II, Table 3 of the regulation. It applies from 12 August 2026, and the A/B/C performance classes condition market access from 1 January 2030, or 24 months after the Article 6(4) delegated acts enter into force, whichever is later. PPWR is EU law, and it governs packaging placed on the EU market. This applies regardless of where the manufacturer or brand is based. It is relevant for UK and US companies exporting into the EU.

These PPWR grades are separate from the 1-7 plastic resin identification codes moulded into packaging. The two systems measure different things and are not interchangeable. This page does not replace legal advice, and the official delegated-act criteria for assigning grades are not yet published. It explains the framework as it stands. The full PPWR requirements, roles and penalties are covered separately on PPWR Regulation (EU) 2025/40: requirements and timeline.

Summary: legal basis, thresholds and key dates

Grades, thresholds and market status

* 1 January 2030, or 24 months after the Article 6(4) delegated acts enter into force, whichever is later. The Regulation defines three performance grades; the last row is not a fourth grade, it is the case where a packaging unit does not reach the minimum threshold. Packaging already placed on the market before the threshold may remain there.

Grade A is not mandatory. From 2030, grades A, B and C are all permitted on the EU market. The pressure on Grade C comes from two directions: higher modulated EPR contributions once modulation applies, and the 2038 cutoff. Producers have the 2030-2038 window to move Grade C structures toward A or B.

How the recyclability percentage is calculated

The percentage refers to the share of the packaging unit’s weight that is effectively recyclable. It is assessed on the whole unit, not on the base film alone. Closures, zippers, valves, labels, inks, lacquers and adhesives all count toward the result. A pouch made of a single polymer can still score low if its components interfere with sorting or contaminate the recyclate.

The binding calculation methodology arrives with the delegated acts under Article 6(4), due by 1 January 2028. Until then, the assessment follows the design-for-recycling criteria of the industry reference frameworks described below. The percentage is a design property. It is fixed by what the packaging is made of, so it cannot be improved by declaration alone.

What lowers a packaging’s grade

The most common grade reducers in flexible packaging are known from the RecyClass and CEFLEX design guidance:

• Incompatible polymer combinations, such as PET/PE or PA/PE laminates
• Aluminium foil layers and heavy metallisation
• Barrier layers, such as EVOH, above the compatibility limits of the target stream
• Carbon-black pigments that NIR sorting systems cannot detect
• Adhesives and inks that degrade the quality of the recyclate
• Oversized labels or sleeves that cover too much of the pack surface
• Closures, valves or zippers made from a different polymer family than the body

Typical flexible-film structures and their likely position

The outcomes below are indicative, based on RecyClass v3.1 and CEFLEX D4ACE guidance. They are not guaranteed grades. The binding criteria arrive with the delegated acts, and every structure is assessed on its exact components.

Who is responsible for the grade

Under the PPWR conformity framework, the manufacturer of the packaging answers for its compliance, including recyclability once the Article 6 criteria apply. The grade is not assigned by declaration alone. It must be supported by the Annex VII technical documentation and, from 12 August 2026, by the EU Declaration of Conformity. Commission guidance notes that the conformity assessment for recyclability is not required until the delegated acts enter into force, with 24 months to comply from that date. A brand that has packaging made under its own name or trademark counts as the manufacturer. Importers must be able to produce the manufacturer’s documentation, and material suppliers are legally required to pass compliance information down the chain under Article 16.

What “placing on the EU market” means for a non-EU manufacturer

PPWR applies at the point packaging is placed on the EU market, not at the point it is manufactured. A UK brand shipping finished goods into the EU is subject to the same grade thresholds as an EU-based manufacturer. So is a US company sourcing film for products sold in the EU. This is separate from, and in addition to, any UK or US domestic packaging rules. UK companies may be used to voluntary schemes such as On-Pack Recycling Label (OPRL). The key difference is that PPWR grades are a legal market-access requirement from 2030, not a labelling recommendation. Confirming the intended market before finalising a film structure is worth doing early. A structure built for Grade C is not automatically upgradable to A or B without a planned redesign.

How the grade affects EPR fees

The grade becomes a cost line as well as a market-access rule. PPWR requires Extended Producer Responsibility contributions to be modulated by recyclability grade. Modulation applies 18 months after both the Article 6(4) delegated acts and the Article 6(5) implementing acts enter into force. The delegated acts are due by 1 January 2028 and the implementing acts by 1 January 2030, so the clock runs from whichever is later; Article 6(8) itself sets no calendar date. The same pack weight placed on the market will then cost more at Grade C than at Grade A. The contribution is paid by the producer placing the packaged product on the market, through each Member State’s EPR scheme, and the amounts remain national.

The order of the two pressures matters for planning. Market access closes first: from the Article 6(3) date, a structure below Grade C can no longer be placed on the market. Fee modulation follows, once both sets of acts are in force. A Grade C structure stays legal until 2038 and starts costing more once modulation applies. What arrives before either is commercial: retailers and brand owners ask for recyclability evidence well ahead of any statutory deadline. How the two frameworks interact, and which design levers actually move the bill, is set out on PPWR and EPR.

Design for recycling vs recycled at scale: two different tests

The grades measure design for recycling: whether the packaging is built so its material can re-enter an existing stream. This is a property of the structure itself, fixed by its components. It is what applies from 2030, under Article 6(2), point (a).

From 1 January 2035, or five years after the Article 6(5) implementing acts enter into force, whichever is later, a second test adds on top: “recycled at scale”, under Article 6(2), point (b). Packaging must be shown to be collected, sorted and mechanically recycled at industrial scale in real EU infrastructure, not just in theory. A structure can pass the first test and still face the second if no stream actually processes it. Mechanical recycling capacity for flexible PE and PP film is established in Germany, the Netherlands and Belgium, and investment is expanding into Central and Eastern Europe. Designing toward the dominant PE and PP film streams today is the practical way to reduce the 2035 risk.

How grades are assessed until the official criteria arrive

Until the delegated acts arrive, due by 1 January 2028, two industry frameworks serve as reference: the RecyClass Online Tool and CEFLEX D4ACE Phase 2. A result obtained on either is a working estimate, not the legal grade. This page stops at the summary. How each framework rates a structure, the standards behind them, and the documents a supplier should provide are covered on the compliance and documentation side of mono-material film.

For mono-material film built toward these grades, see mono-PE and mono-PP.

Frequently asked questions