PPWR recyclability grades explained (A, B, C)
Under PPWR Article 6, all packaging must be designed for recycling and is graded A, B or C by the share of the unit that is recyclable. From 1 January 2030, grade C is the minimum — packaging that scores below grade C cannot be placed on the EU market. From 1 January 2038, grade C is phased out too, so only grades A and B remain placeable.
The exact grade thresholds and the assessment methodology are set out in Annex II and a design-for-recycling delegated act, which was still pending as of 9 July 2026.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
What the grades mean
Regulation (EU) 2025/40, Art. 6, requires packaging to be "recyclable" — designed for recycling and, later, recyclable at scale. Annex II sets the performance grades by the percentage of the packaging unit, by weight, that is recyclable:
| Grade | Recyclable share (by weight) | Market status |
|---|---|---|
| A | ≥ 95% | Placeable throughout — the only grades left from 2038. |
| B | ≥ 80% | Placeable throughout — the only grades left from 2038. |
| C | ≥ 70% | Minimum from 2030; phased out from 2038. |
| Below C | < 70% | Not placeable on the market from 2030. |
The percentages above are the grade bands anchored in the regulation. The precise way each material's recyclable share is calculated — the design-for-recycling criteria per material category — is left to a Commission delegated act.
The two dates that matter
- 1 January 2030 — grade C minimum. Packaging that does not reach grade C (below ~70% recyclable) may not be placed on the market (Art. 6).
- 1 January 2038 — A/B only. Grade C is withdrawn; packaging must reach grade A or B (≥80%) to stay on the market (Art. 6).
There is also an intermediate milestone: from 1 January 2035, recyclability is assessed "at scale," meaning packaging must be recyclable in practice given the sorting and recycling infrastructure actually installed across the EU — not just recyclable in principle.
What "not placeable on the market" means for you
If a packaging format falls below the applicable grade on the relevant date, you cannot lawfully place it on the EU market from that date — it has to be redesigned, switched to a compliant material, or dropped. Because redesign, tooling and supplier changes take time, the 2030 grade-C floor is effectively a near-term design deadline, not a distant one.
What is still pending
Two things are not yet final as of 9 July 2026: the detailed design-for-recycling methodology (how each material's grade is computed) and the material-category criteria in the delegated act under Art. 6 / Annex II. Until those are adopted, a grade is an informed estimate against the framework, not a certified result. Watch the Commission's packaging page for the act. Recyclability grading is also not a recyclability label — labelling is a separate obligation under Art. 12 (see the labelling guide).
Get this mapped to your own packaging
The report screens your packaging profile against Regulation (EU) 2025/40 and returns only the obligations that apply to you — each with its threshold, deadline and article, plus supplier letters ready to send.
Get my PPWR obligations report →Frequently asked questions
What are PPWR recyclability grades A, B and C?
They are performance grades under Article 6 and Annex II of Regulation (EU) 2025/40 that rank packaging by the share of the unit that is recyclable by weight: grade A is roughly 95% or more, grade B 80% or more, and grade C 70% or more. The precise per-material methodology is set by a delegated act.
When is low-recyclability packaging banned?
From 1 January 2030, packaging below grade C cannot be placed on the EU market. From 1 January 2038, grade C is also withdrawn, leaving only grades A and B (Article 6).
Is the recyclability grade an official certification?
No. The regulation sets the grades and, once the design-for-recycling delegated act is adopted, the methodology to assess them. Until then a grade is an estimate against the framework. An official conformity assessment is a separate matter you should confirm with an accredited body.
Does the grade apply per packaging unit or per material?
The grade is assessed by the recyclable share of the packaging unit by weight (Annex II). Multi-material and composite packaging is more complex because component separability affects the recyclable share — one reason the detailed methodology is left to a delegated act.
Sources
- Regulation (EU) 2025/40 (PPWR) — Art. 6 (recyclability) and Annex II (performance grades / design-for-recycling criteria); 2030 grade-C minimum, 2035 at-scale, 2038 A/B-only — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- Design-for-recycling delegated act under Art. 6 / Annex II — status: pending as of 9 July 2026 — https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en