PPWR Article 6 Without the Lobby Spin

Article 6 of Regulation (EU) 2025/40 is one of the most quoted and most paraphrased provisions of the PPWR. Industry associations, material groups and consultancies have published their own readings of it. Many are useful. Some describe rules the regulation does not contain, and some read the text in a way that shifts the burden onto another material category.

This piece does not take a position on materials. It walks through what Article 6 literally says, where industry design guidelines such as RecyClass fill the operational gap, and which grey areas are genuine. By the end you should be able to tell a legal requirement from an industry reading, and build a grade file that holds up once the criteria arrive.

What Article 6 literally says

The core rule is one sentence. Article 6(1): “All packaging placed on the market shall be recyclable.” Article 6(2) then defines recyclable through two conditions: the packaging is designed for material recycling, and, when it becomes waste, it can be collected separately, sorted and “recycled at scale”.

Three points in the text do most of the work. The design condition applies from 1 January 2030 or 24 months after the Article 6(4) delegated acts enter into force, “whichever is the latest”. The recycled-at-scale condition applies from 1 January 2035 or five years after the Article 6(5) implementing acts, again whichever is later. The burden of proof sits with the manufacturer: Article 6(3) says the manufacturer shall assess recyclability, and Article 6(9) requires compliance to be shown in the technical documentation under Annex VII.

The recyclability scale in plain language

There are three grades, not four or five. Table 3 of Annex II sets them by the design-for-recycling score of each packaging unit. The thresholds are fixed in the regulation. The scoring method behind them is not: the Commission must adopt it in delegated acts under Article 6(4) by 1 January 2028.

• Grade A. Score of 95 % or higher. Allowed from 2030 and after 2038.
• Grade B. Score of 80 % or higher. Allowed from 2030 and after 2038.
• Grade C. Score of 70 % or higher. Allowed from 2030; cannot be placed on the market from 1 January 2038.
• Below 70 %. “Technically non-recyclable”. Cannot be placed on the market from 1 January 2030 at the earliest. From 2035, Table 3 adds a second assessment for recycled at scale (grades A, B or C “RaS”).

Where RecyClass and other industry guidelines come in

Until the delegated acts exist, no one can calculate a legal PPWR grade. Design guidelines from RecyClass, Cepi, FEFCO, Metal Packaging Europe and FEVE fill that gap in practice. They show, at component level, which labels, inks, barriers or closures cause problems in today's sorting and recycling. They are not law, and PPWR does not name them. Article 6(4) only requires the Commission to take into consideration standards developed by the European standardisation organisations when it adopts the criteria.

In practice: a guideline assessment is a sound planning signal and useful evidence of design intent. It is not your PPWR grade. Record which guideline and version you used, and plan to re-score once the delegated acts are adopted. Later updates to the criteria give economic operators three years to comply (Article 6(4)).

After weighing the criteria per packaging unit, it will be classified into categories A, B or C.

Three genuine grey areas

Some questions that circulate in industry papers are already answered by the text. Recycled content does not raise a recyclability grade: minimum recycled content is Article 7, a separate obligation. Recycled at scale is measured at Union level per packaging category, not per member state. Three questions remain genuinely open.

1. How the score is weighted. Article 6(4)(b) and Table 3 speak of assessment “per packaging unit, in terms of weighting”. How much each component counts is not yet defined. Some industry readings present a rule where the worst component sets the grade. That rule is not in the regulation. What the text does say (Article 6(9)) is that separate components are assessed on their own and that no component may hinder the recyclability of the main body. How the delegated acts combine the two is the open question.
2. How recycled at scale will be demonstrated. Article 3(1)(39) sets the threshold at Union level: at least 55 % of each packaging category recycled per year (30 % for wood). The methodology and a chain-of-custody mechanism come in implementing acts due by 1 January 2030 (Article 6(5)). Until then it is unclear which data an individual manufacturer will hold, and the Commission may review the thresholds by 2035 (Article 6(7)).
3. What applies before 2030. Article 6(1) has no separate start date. The Commission's guidance (C(2026) 3702, section 6) reads it as applying from 12 August 2026, with the old Packaging Directive 94/62/EC and EN 13430:2004 as the benchmark until the design condition applies. That is the Commission's interpretation, not text in the regulation. Binding interpretation remains with the Court of Justice of the EU.

Building a grade file that holds up

A defensible grade file has three parts. It names the legal basis: Article 6(2) and 6(3), Annex II Table 3 and, once adopted, the Article 6(4) delegated act. It states the method: today a named industry guideline and version, later the legal criteria. And it keeps the data for each packaging unit: packaging category and predominant material, a component list with materials and weights, and supplier specifications for labels, adhesives, inks, coatings and closures.

A grade without these parts is not necessarily wrong; it is unprovable. Article 6(9) requires compliance to be shown in the Annex VII technical documentation, which supports the EU declaration of conformity. Build the file with that in mind and the lobby spin stops mattering.