Recyclability classes A–E in PPWR: how not to be forced out of the market by 2030

There are seemingly four years left until 2030. In practice, however, it is considerably less, as the design, testing and implementation of new packaging is a process measured in months, and sometimes years. The PPWR introduces a rating system that simply did not exist previously in EU packaging law: recyclability performance grades. From 1 January 2030, any packaging that does not achieve the minimum grade will not be able to be legally placed on the EU market – regardless of how well it sells or how long the company has been in business. This is not a distant, theoretical problem ‘for later’. It is a specific deadline by which you must have redesigned your packaging portfolio.

What exactly are classes A–E?

Article 6 of the PPWR (in conjunction with Annex II) introduces a system for assessing what percentage of a packaging item’s mass is actually suitable for recycling – not in theory or as a marketing claim, but in practice, taking into account the material, additives, labels, adhesives, coatings, colourants and the way in which the packaging behaves in existing sorting and processing facilities.

The class thresholds, set out explicitly in the text of the Regulation, are as follows:

• Class A – at least 95 per cent recyclability by weight,
• Class B – at least 80 per cent,
• Class C – at least 70 per cent (minimum acceptable threshold),
• Classes D and E – below 70 per cent; packaging is considered technically non-recyclable.

This is a significant difference from the old Packaging Directive 94/62/EC, which used the general statement ‘suitable for recycling’ without a measurable methodology. The PPWR replaces this declaration with a figure that must be demonstrated in the technical documentation.

Two timetables that are easily confused

This is where an error often appears in many articles and industry communications, so it is worth distinguishing between two separate dates:

Design for Recycling – from 1 January 2030, only packaging classified as Class A, B or C will be permitted on the EU market. The assessment here focuses on the design itself: the material, the construction, the ability to separate components, and the quality of the secondary raw material that can be recovered from the packaging.

Recycling at scale – from 2035, it will not be enough for packaging to be theoretically designed for recycling. It must actually be collected, sorted and processed in practice, in facilities accessible to at least 75 per cent of the EU population. This is a fundamental shift in philosophy: even well-designed packaging may still ‘fail’ if the recycling infrastructure in a given country or region is simply unable to process it.

At the end of this timeline lies another crucial date: from 1 January 2038, Class C will no longer be sufficient. Only Class A or B packaging will be allowed to remain on the market. This means that a company which ‘barely’ meets the Class C threshold in 2030 will have to redesign its packaging again eight years later.

What actually lowers the packaging grade

The assessment does not apply solely to the main material. In accordance with the provisions of Article 6 of the PPWR (including Article 6(9), concerning the assessment of components), every element of the packaging that may physically separate during transport or sorting is assessed separately – and may lower the grade of the whole. In practice, the following most commonly lower the grade:

• complex multi-material laminates – e.g. combinations of paper and plastic film, which are difficult to separate during the recycling process,
• dark dyes and solid colour coverage – these hinder optical sorting at sorting centres, where scanners identify materials partly by colour,
• non-removable labels, metal staples, plastic handles and windows – elements that are not homogeneous with the main packaging material,
• adhesives and barrier coatings – particularly those incompatible with the recycling process for paper or the main plastic,
• mixed polymers – where different types of plastic are permanently bonded together.

A simple rule worth remembering: the more homogeneous (single-material) the packaging, the higher the expected grade. Plain corrugated board with minimal printing is a natural candidate for a high grade. Complex, multi-layered packaging combining several materials is a natural candidate for grade D or E.

Why no one can ‘definitely’ classify their packaging today

Here, there is an important caveat that some industry publications overlook: the detailed methodology for calculating the classes is not yet finalised. The percentage thresholds (95 per cent, 80 per cent, 70 per cent) are set out explicitly in the Regulation and will not change, but the precise assessment criteria – how to calculate, which tests to use, how to treat individual materials – are to be published by the European Commission in delegated acts, which must be adopted by 1 January 2028 at the latest.

Until then, the general recyclability requirement under Article 6 of the PPWR applies, and manufacturers may, as a supplementary measure, rely on the existing harmonised standard EN 13430:2004, which dates back to the old Packaging Directive. The formal conformity assessment procedure and technical documentation relating to recyclability classes are not yet required – they will only become mandatory once the delegated acts come into force.

Practical conclusion: no company or supplier can currently guarantee with 100% certainty that a given packaging item ‘will definitely be in class B’. However, it is already possible today to assess which solutions are structurally risky – and this is the difference that will either cost or save money in 2030.

Why ‘Class C is enough’ is a short-sighted strategy

Formally, from 2030, the market entry threshold is Class C. The problem is that packaging designed today with the round date of 2030 in mind will still have to be redesigned by 2038 at the latest, when Class C will no longer suffice. For companies planning the life cycle of their packaging (and the associated costs of moulds, production lines and materials) over a period longer than eight years, aiming solely for the minimum threshold effectively means incurring the double cost of redesign within the same decade.

Class A and extended producer responsibility (EPR) fees

The recyclability class is not merely a condition for placing a product on the market. The PPWR links it directly to the level of fees under extended producer responsibility (EPR) – a mechanism known as ‘eco-modulation’. The lower the class, the higher the fee for placing packaging on the market. This means that even before the Class C threshold becomes formally mandatory, packaging with low recyclability will already cost a company more than well-designed packaging – in the form of higher fees, rather than an administrative fine.

What this means for different sectors

• Food and cosmetics manufacturers – they are the main users of laminates and barrier coatings (e.g. against moisture and grease), which are among the main candidates for the low-grade category.
• E-commerce – cardboard boxes containing numerous additional components (tape, fillers, plastic windows for address labels) will need to be reviewed for material homogeneity.
• The paper and board industry – has a natural head start, as paper and board have some of the highest recycling rates in Europe, but functional barrier coatings (e.g. those replacing PE film) still require verification.
• Plastic packaging manufacturers – mixed polymers and multi-layer structures represent the area of greatest classification risk.

Summary

The A–E classification system in the PPWR transforms recyclability from a marketing claim into a measurable, legally binding parameter on which access to the EU market depends. The precise assessment methodology is still pending delegated acts from the European Commission (deadline: 1 January 2028), but the percentage thresholds and timetable themselves – Class C as a minimum from 2030, and exclusively Class A or B from 2038 – are already set out in the regulation and will not change. Companies that are currently designing or updating their packaging portfolios can already analyse their material composition to identify which solutions are most at risk of receiving a low classification – before the regulatory timetable forces them to do so.