PPWR Article 6: recyclable packaging and design for recycling

In short: PPWR Article 6 requires all packaging placed on the EU market to be recyclable. From 1 January 2030 at the earliest, packaging must reach recyclability grade A, B or C (at least 70%). From 1 January 2038, only grades A and B (at least 80%) may be placed on the market. From 2035 at the earliest, packaging must also be "recycled at scale". The criteria that produce the grade are still being written: the Commission must adopt them by 1 January 2028.

If you need the dates, the tables below are enough. If you plan a portfolio, keep one point in mind. The regulation fixes the grade thresholds, but the Commission has not yet published the method for scoring a package. Any grade you calculate today is an estimate.

The two conditions for recyclable packaging

Article 6(2) sets two conditions. Packaging is recyclable only if it meets both.

ConditionWhat it meansApplies fromSource
Design for recyclingDesigned for material recycling, so the recycled output can replace primary raw material1 Jan 2030, or 24 months after the Article 6(4) delegated acts, whichever is laterArt. 6(2)(a)
Recycled at scaleCan be collected separately, sorted without harming other streams, and recycled at scale1 Jan 2035, or 5 years after the Article 6(5) implementing acts, whichever is laterArt. 6(2)(b)

Packaging that complies with the delegated acts under Article 6(4) is deemed to meet the design condition. Packaging that also complies with the implementing acts under Article 6(5) is deemed recyclable.

What applies before 2030

Article 6(1), "all packaging placed on the market shall be recyclable", has no separate start date. The Commission guidance (C(2026) 3702, section 6) reads it as applying from 12 August 2026. Until the design condition in Article 6(2)(a) applies, manufacturers comply with the recyclability requirement of the old Packaging Directive 94/62/EC and the harmonised standard EN 13430:2004. The Commission adds that the Annex VII conformity assessment for recyclability is not needed until the Article 6(4) delegated acts enter into force.

PPWR Article 6 recyclability grades

Article 6(3) expresses recyclability in three grades, set out in Table 3 of Annex II. There are no grades D or E.

GradeDesign-for-recycling score per packaging unit20302038
A95% or higherAllowedAllowed
B80% or higherAllowedAllowed
C70% or higherAllowedCannot be placed on the market
Below 70%"Technically non-recyclable"Cannot be placed on the marketCannot be placed on the market

Source: Article 6(3), Annex II Table 3. The 2030 gate applies from 1 January 2030 or 24 months after the Article 6(4) delegated acts, whichever is later. The 2038 gate is fixed at 1 January 2038.

From 2035, Table 3 adds a second assessment: grade A, B or C "RaS" (recycled at scale). Packaging below the at-scale threshold is "not recycled at scale".

How the grade will be calculated

The regulation fixes the thresholds, not the scoring method. By 1 January 2028, the Commission must adopt delegated acts under Article 6(4) that set:

  • design-for-recycling criteria and grades for each packaging category in Table 1 of Annex II, based on the predominant material;
  • how to assess recyclability "per packaging unit, in terms of weighting", including material-specific criteria and sorting efficiency;
  • the conditions for each grade, per packaging category;
  • a framework for modulating EPR fees by grade.

Annex II Table 3 describes the result in the same terms: "After weighing the criteria per packaging unit, it will be classified into categories A, B or C."

Table 4 of Annex II gives a non-exhaustive list of parameters the criteria are based on:

ParameterWhy it matters (Annex II, Table 4)
AdditivesCan cause incorrect sorting and contaminate recycled material
LabelsCoverage, label material and adhesive affect sorting and output quality
SleevesCoverage affects sorting; sleeve material affects separation and recyclability
Closures and small componentsMaterial affects sortability; loose parts can be lost in sorting
AdhesivesResidues can downgrade output purity; washable adhesives help separation
ColoursHeavily dyed paper or plastics can cause sorting problems
Material compositionMono-materials or easily separable combinations are preferable
Barriers and coatingsCan make recycling more difficult
Inks, lacquers, printing, codingInks with substances of concern hinder recycling; released inks can contaminate washing water
Product residues and ease of emptyingResidues affect sorting; packaging should empty fully
Ease of dismantlingFirmly attached components are harder to separate into material streams

The criteria must also consider established collection and sorting processes, available recycling technologies and their environmental performance, and, where appropriate, substances of concern that hinder recycling (Article 6(4)(a)). See Article 5 on substances of concern.

What about industry guidelines? Design guides from RecyClass, Cepi, FEFCO, Metal Packaging Europe and FEVE are useful today to spot weak components. They are not legal criteria under PPWR. The Commission will take into account standards developed by the European standardisation organisations when it adopts the delegated acts (Article 6(4)). Treat a guideline score as a planning signal, not as your PPWR grade.

How components are assessed

Article 6(9) sets how a packaging unit's components are treated:

  • Integrated components are part of the unit and are not removed for it to work, for example a label applied to a bottle. They are included in the assessment of the packaging unit.
  • Integrated components that can come apart from mechanical stress during transport or sorting are assessed separately.
  • Separate components are removed completely and typically discarded before, and separately from, the main body, for example a peel-off lidding film (Article 3(1)). Each is assessed on its own.
  • All components must be compatible with established collection, sorting and recycling processes, and must not hinder the recyclability of the main body.

The last rule matters in practice. A component that disrupts the recycling of the main body is a compliance risk for the whole unit, whatever its weight. The delegated acts will set how much each component weighs in the score.

Recycled at scale

"Recycled at scale" is measured at Union level, per packaging category in Table 2 of Annex II. Packaging waste counts as recycled at scale when it goes through separate collection, sorting and recycling in installed infrastructure. The annual quantity of recycled material in its category must reach at least 55% (30% for wood) across the EU (Article 3(1)(39)).

By 1 January 2030, the Commission must adopt implementing acts with (Article 6(5)):

  • the methodology for the at-scale assessment, based on quantities placed on the market and recycled, in the EU and in each Member State;
  • a chain-of-custody mechanism, including a verification process that lets manufacturers obtain data from downstream operators.

The Commission must make the data public. It publishes PPWR updates on its packaging waste page. By 2035, it may review the at-scale thresholds (Article 6(7)).

What this means for planning: the at-scale test depends on how much of your packaging category is effectively recycled across the EU, not only on your design. A well-designed format in a category with low recycling rates can still fall short from 2035.

Exemptions and derogations

Under Article 6(11), Article 6 does not apply to:

Exempt packagingSource
Immediate packaging of medicinal products and veterinary medicinal productsArt. 6(11)(a)
Contact-sensitive packaging of medical devicesArt. 6(11)(b)
Contact-sensitive packaging of in vitro diagnostic medical devicesArt. 6(11)(c)
Outer packaging of medicinal products, where needed to preserve product qualityArt. 6(11)(d)
Contact-sensitive packaging for infant formula, follow-on formula, processed cereal-based food, baby food and food for special medical purposesArt. 6(11)(e)
Packaging for the transport of dangerous goodsArt. 6(11)(f)
Sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax (EPR fee modulation still applies)Art. 6(11)(g)

The Commission will review these exemptions by 1 January 2035 (Article 6(12)).

Innovative packaging. From 1 January 2030, innovative packaging that does not yet meet the recyclability conditions gets a temporary derogation (Article 6(10)). It may stay on the market for up to 5 years after the end of the year it was first placed on the market. First, the operator must notify the competent authority. The notice gives technical details and a timeline for reaching recycled-at-scale levels. "Innovative" has a strict definition: new materials, a significant functional improvement and demonstrable environmental benefits (Article 3(1)(46)). Modifying existing packaging mainly to improve presentation or marketing does not qualify.

EPR fees and grades

EPR fees will vary by recyclability grade. This starts 18 months after both the Article 6(4) delegated acts and the Article 6(5) implementing acts enter into force (Article 6(8)). The framework for modulation comes from the delegated acts (Article 6(4)(d)). Until then, fee modulation follows existing national EPR rules.

How to document compliance

You demonstrate compliance with Article 6(2) and 6(3) in the technical documentation under Annex VII (Article 6(9)). That documentation supports the EU declaration of conformity (Article 39); see our declaration of conformity guide.

For each packaging unit, keep:

  • the packaging category in Annex II Table 1 and the predominant material;
  • a component list with materials, weights, and whether each is integrated or separate;
  • supplier specifications for labels, adhesives, inks, coatings and closures;
  • the grade and the criteria version used (once the delegated acts apply);
  • for 2035 onward, the recycled-at-scale evidence the implementing acts require.

When new or updated design-for-recycling criteria are adopted, economic operators have 3 years from their entry into force to comply (Article 6(4)).

Timeline

DateWhat happensSource
1 Jan 2028Delegated acts: design-for-recycling criteria, grading method, EPR modulation frameworkArt. 6(4)
1 Jan 2030Implementing acts: recycled-at-scale methodology and chain of custodyArt. 6(5)
1 Jan 2030*Packaging must be grade A, B or C; design condition appliesArt. 6(2)(a), 6(3)
1 Jan 2030Innovative packaging derogation becomes availableArt. 6(10)
18 months after both actsEPR fees modulated by gradeArt. 6(8)
1 Jan 2035*Recycled-at-scale condition appliesArt. 6(2)(b)
By 2035Commission may review at-scale thresholds; reviews exemptionsArt. 6(7), 6(12)
1 Jan 2038Only grades A and B may be placed on the marketArt. 6(3)

* or later, if the related delegated or implementing acts enter into force late.

Five common PPWR Article 6 mistakes

  1. Planning with grades D and E. PPWR has grades A, B and C only. Below 70% is technically non-recyclable and cannot be placed on the market from 2030.
  2. Treating grade C as safe. Grade C is allowed from 2030 but not from 1 January 2038. Start the redesign cycle for grade C SKUs well before then.
  3. Using a guideline score as the legal grade. RecyClass or Cepi results are useful signals. The legal grade comes from the delegated acts due by 1 January 2028.
  4. Assessing recycled at scale per country. The 55% threshold applies at Union level per packaging category, using EU and Member State data.
  5. Forgetting separate components. Caps, sleeves and other separate components get their own assessment. None of them may hinder the recyclability of the main body.

Frequently asked questions

Does Article 6 apply from 12 August 2026?

Partly. The general rule that packaging must be recyclable applies from 12 August 2026; until 2030, the Commission points to the old Packaging Directive and EN 13430:2004. The grade requirement applies from 1 January 2030 at the earliest, and its criteria are due by 1 January 2028.

Is there a grade D or E under PPWR?

No. Annex II Table 3 defines grades A, B and C. Packaging below 70% is "technically non-recyclable".

Can I calculate my PPWR grade today?

Only as an estimate. The thresholds are fixed, but the scoring method and the criteria per packaging category come with the Article 6(4) delegated acts.

Is recyclability the same as recycled content?

No. Article 6 is about whether packaging can be recycled. Article 7 sets minimum recycled content for plastic packaging. A grade A package can contain no recycled material.

Does Article 6 apply to wooden or textile packaging?

Sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax is exempt from Article 6, but EPR fee modulation still applies (Article 6(11)(g)).

Where Carbonorm fits

The Article 6 file starts with component data from your suppliers: label, adhesive, ink, coating and closure specifications. The Carbonorm continuous PPWR compliance platform collects that evidence through a secure form, with no account or login needed, and stores each item next to the PPWR article it supports. When the Commission publishes the Article 6(4) delegated acts, we process them into the rule set and log the change in the public changelog.

A free PPWR audit walks one bill of materials with a regulatory engineer. You leave with the evidence gaps and the article behind each.

Get the PPWR readiness checklist · Book a free PPWR audit

Source: Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025, Articles 3, 6, Annex II and Annex VII; Commission Notice C(2026) 3702, section 6. Rule set as of 5 October 2026. The Article 6(4) delegated acts are due by 1 January 2028; check the change-log for their status.