PPWR Article 6 Recyclability: Design for Recycling, Grades A to C and the 2030 and 2038 Rules

Article 6 of the PPWR (Regulation (EU) 2025/40) states that all packaging placed on the market shall be recyclable, and defines recyclable through two conditions: design for recycling from 1 January 2030 at the earliest and recycling at scale from 1 January 2035 at the earliest. Recyclability itself is defined in Art. 3(1)(38) as the compatibility of packaging with waste management and processing by design, based on separate collection, sorting, recycling at scale and the use of recycled materials in place of primary raw materials.

Recyclability is one of the design rules of the EU Packaging and Packaging Waste Regulation (PPWR), next to substances, recycled content and minimisation. From the 2030 step, packaging needs at least grade C (70 %) to be placed on the market, and from 1 January 2038, a fixed date, only grades A (95 %) or B (80 %) remain allowed.

The sections below follow Article 6 in order, from the duty to the EPR fees.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; see our methodology and fact-checking.

The key facts of PPWR Article 6 are summarised in the table below.

What Does Article 6 of the PPWR Require?

Art. 6(1) PPWR reads: "All packaging placed on the market shall be recyclable." Art. 6(2) sets two cumulative conditions: design for recycling under point (a) and recycling at scale under point (b). The Regulation applies generally from 12 August 2026 (Art. 71); each condition has its own later date. The full wording of both conditions is in Article 6 in the PPWR legal text.

Two further Art. 3(1) definitions give the conditions their content. Design for recycling (point 37) is the design of packaging, including individual components, that ensures recyclability with established collection, sorting and recycling processes proven in an operational environment. A packaging category (point 42) is the combination of material and specific packaging design which determines recyclability by reference to established collection, sorting and recycling processes.

Condition (a): designed for recycling

Under Art. 6(2)(a) PPWR, packaging must be designed for material recycling so that the secondary raw materials it yields are of sufficient quality to substitute primary raw materials. Compliance with the Art. 6(4) delegated acts creates a presumption of conformity with condition (a), and compliance with those acts plus the Art. 6(5) implementing acts with both conditions (Art. 6(2), second and third subparagraphs). Design for recycling and packaging category are two of the PPWR definitions in Art. 3(1).

Condition (b): recycled at scale

Under Art. 6(2)(b) PPWR, packaging must also be collected separately, sorted without affecting other waste streams and recycled at scale, which Art. 3(1)(39) defines as an annual Union-level recycled quantity of at least 55 %, or 30 % for wood, per packaging category. Separate collection refers to the systems of Art. 48(1) and (5).

Condition (b) applies from 1 January 2035 or 5 years after the Art. 6(5) implementing acts enter into force, whichever is the latest. Those implementing acts, due by 1 January 2030, set the recycled-at-scale methodology and the chain of custody. How the Union-level quantity will be measured is explained under recycled at scale under the PPWR.

When Do the PPWR Recyclability Rules Apply?

The PPWR recyclability rules apply in three steps: design for recycling and grades A to C from 1 January 2030 or 24 months after the Art. 6(4) delegated acts, recycling at scale from 1 January 2035 or 5 years after the Art. 6(5) implementing acts, whichever is the latest in each case, and only grades A or B from 1 January 2038. The dates, their triggers and the status of each Commission act are set out in the table below.

The recyclability dates sit in the wider PPWR timeline of application dates.

Is 1 January 2030 a fixed date?

No: 1 January 2030 is the earliest date, because Art. 6(2) and 6(3) PPWR apply from that day or 24 months after the Art. 6(4) delegated acts enter into force, whichever is the latest.

The Art. 6(4) delegated acts are due by 1 January 2028 and none had been adopted as of 24 October 2026. A delegated act enters into force only if neither the European Parliament nor the Council objects within 2 months of notification, a period that can be extended by 2 months (Art. 64(6) PPWR). The Commission stated on 30 March 2026 (press release IP/26/664) that acts on recyclability criteria are being prepared. Other PPWR 2030 deadlines that depend on a Commission act are compared under PPWR 2030 deadlines.

Which Recyclability Grades Are Allowed from 2030 and from 2038?

From 1 January 2030 or 24 months after the delegated acts, whichever is the latest, only packaging that reaches grade A (at least 95 %), B (at least 80 %) or C (at least 70 %) may be placed on the market, and from 1 January 2038 only grades A or B. Both steps apply without prejudice to the Art. 6(10) derogation.

The grade is assessed per packaging unit, in terms of weighting, under the method that the Art. 6(4)(b) delegated acts will set. The criteria are set per packaging category of Annex II Table 1, which lists 22 categories from category 1 (glass) to category 22 (ceramics or porcelain), based on the predominant material. Annex II Table 3 and the assessment parameters are explained under recyclability performance grades.

Is there a recyclability grade D?

No: Annex II Table 3 PPWR has only grades A, B and C, and packaging below 70 % is classed as technically non-recyclable and cannot be placed on the market once the grades apply. Grade C itself drops out on 1 January 2038, when Table 3 marks it as packaging that cannot be placed on the market.

What Will the Design-for-Recycling Delegated Acts Contain?

By 1 January 2028 the Commission must adopt delegated acts under Art. 6(4) PPWR that set the design-for-recycling criteria and grades, the assessment method and the framework for EPR fee modulation; none had been adopted as of 24 October 2026. As of the same date, the only adopted PPWR delegated act is Commission Delegated Decision (EU) 2026/429. The status of every other mandate is tracked under PPWR delegated acts and implementing acts.

The four elements that Art. 6(4) requires the delegated acts to contain are listed below.

• Point (a): design-for-recycling criteria and recyclability performance grades per Annex II Table 1 packaging category, based on the predominant material.
• Point (b): the assessment method and grades per packaging unit in terms of weighting, including material-specific criteria and sorting efficiency.
• Point (c): the conditions under which each packaging category complies.
• Point (d): the framework for modulating EPR fees under Art. 45(1).

Substances of concern are part of the criteria. Under Art. 6(4)(a)(iv), the acts identify substances of concern that negatively affect re-use and recycling, and under point (a)(v) they may restrict such substances for reasons not relating primarily to chemical safety, without prejudice to REACH Annex XVII and food contact restrictions. The Commission takes into account the results of any Art. 5(2) assessment. By 12 August 2033 it evaluates whether Art. 5 and the Art. 6(4) criteria have sufficiently minimised substances of concern (Art. 5(9)).

Must packaging be redesigned when the criteria change?

Yes: under the fourth subparagraph of Art. 6(4) PPWR, economic operators must meet new or updated design-for-recycling criteria within 3 years of the entry into force of the delegated act concerned.

Who Assesses Recyclability and How Is It Documented?

The manufacturer assesses the recyclability performance grade of its packaging under Art. 6(3) PPWR and records a qualitative description of that assessment in the Annex VII technical documentation (point 2(e)). The assessment becomes part of the PPWR technical documentation for the packaging.

Conformity assessment under Art. 38 PPWR follows Annex VII, Module A, internal production control. No notified body is involved, and the PPWR provides no CE marking.

On that file the manufacturer bases the EU declaration of conformity for the packaging, drawn up under Art. 39 PPWR on the Annex VIII model.

Is there a harmonised standard or a PPWR recyclability certificate?

No PPWR recyclability certificate exists: the Regulation provides only self-assessment by the manufacturer under internal production control, with no notified body. For condition (a), the presumption of conformity in Art. 6(2) attaches to compliance with the Art. 6(4) delegated acts, which were not adopted as of 24 October 2026.

Standards enter through the delegated acts: Art. 6(4) requires the Commission to take into consideration standards developed by the European standardisation organisations when it sets the criteria. How outside providers support a recyclability assessment is covered under PPWR testing and recyclability assessment.

Which Packaging Is Exempt from the Recyclability Requirements?

Art. 6(11) PPWR exempts seven groups of packaging from the recyclability requirements, mostly packaging for medicinal products, medical devices, infant food and dangerous goods, and the Commission must review the exemptions by 1 January 2035 (Art. 6(12)). The seven points are listed in the table below with their legal references.

What else applies to these packaging groups is covered under PPWR for pharmaceuticals and medical devices.

Is all wooden packaging exempt?

No: Art. 6(11)(g) PPWR exempts only sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax, and Art. 6(8) still applies to EPR fees for that packaging. Recital 34 explains the exemption: each of these categories amounts to less than 1 % of the weight of packaging placed on the Union market, although the recital does not list wax.

The other rules for wood packaging under the PPWR are collected on the material page.

How does the Commission read the baby food and dangerous goods exemptions?

The Commission's PPWR FAQ (non-binding) reads the baby food exemption through Art. 2(2)(f) of Regulation (EU) No 609/2013, so not every fruit juice or purée marketed for babies is covered.

For dangerous goods, the same FAQ, section II, states that the exemption covers packaging used for dangerous goods under Directive 2008/68/EC, including limited quantities without UN approval. UN-approved packaging used for goods that are not dangerous is not exempt.

What Is the Innovative Packaging Derogation under Article 6(10)?

From 1 January 2030, Art. 6(10) PPWR lets innovative packaging that does not yet meet the recyclability conditions be placed on the market for up to 5 years from the end of the calendar year in which it was placed on the market. Innovative packaging (Art. 3(1)(46)) uses new materials and brings a significant improvement in packaging functions, such as containment, protection, handling or delivery, and overall demonstrable environmental benefits; changes mainly for presentation and marketing are excluded.

The economic operator must notify the competent authority before placing the packaging on the market, with technical details and a timeline for reaching recycled at scale. That authority is designated under Art. 40(1) PPWR, which lists Art. 6(10), and Member States had to notify their competent authorities to the Commission by 12 July 2025 (Art. 40(3)). In Ireland, S.I. No. 541/2025, made on 6 November 2025, designates the Minister as competent authority for Art. 6(10). Ireland's designation of competent authorities is covered under PPWR in Ireland.

The Commission's PPWR FAQ (non-binding) states that no further guidance on innovative packaging is envisaged.

How Does Recyclability Affect EPR Fees?

EPR fees must be modulated by recyclability performance grade 18 months after both the Art. 6(4) delegated acts and the Art. 6(5) implementing acts have entered into force (Art. 6(8) PPWR). Who pays these fees is set out under packaging EPR under the PPWR.

The PPWR does not harmonise fee amounts, and sales packaging exempt under Art. 6(11)(g) stays inside fee modulation, with Member States taking into account technical feasibility and economic viability (Art. 6(8), second subparagraph).

National fee scales are compared under EPR fees and eco-modulation.

How Does Article 6 Fit with the Other PPWR Requirements?

Article 6 is the second of the Chapter II sustainability requirements, after the Art. 5 rules on substances in packaging and before the Art. 7 recycled content targets. The other design and composition rules are explained under PPWR requirements for packaging.

Art. 5 and Art. 6 meet in Art. 6(4)(a)(iv), under which the design-for-recycling criteria identify substances of concern that hinder re-use and recycling. Environmental claims about packaging that the PPWR does not regulate follow the general EU rules in Directive (EU) 2024/825, according to the Commission's PPWR FAQ (non-binding); that topic is covered on greenwashingdirective.com.

Recyclable packaging does not have to contain recyclate; that is a separate duty under the PPWR recycled content targets, which apply to plastic packaging only, from 1 January 2030 or 3 years after the Art. 7(8) implementing act, whichever is later.

What happens to recyclable packaging waste under Article 48?

Art. 48(1) PPWR requires packaging that complies with the Art. 6(4) design-for-recycling criteria to be collected for recycling and prohibits its incineration and landfill, except waste from the treatment of separately collected packaging for which recycling is not feasible or not the best environmental outcome.

Member States must set up systems for the return and separate collection of all packaging waste from end users, open to all operators and to imported products (Art. 48(1) and (5)). Member State duties on separate collection are explained under EU packaging waste collection and recycling.

Does Article 6 apply to packaging imported into the EU?

Yes: Art. 6(1) covers all packaging placed on the market, so packaging brought in from a third country by an importer established in the Union must meet the same recyclability rules on the same dates. The importer is defined in Art. 3(1)(17) PPWR.

What else the importer must check is set out in the PPWR obligations of importers.

Do the pending PPWR amendments change Article 6?

No: as of 24 October 2026, neither of the two pending amending proposals, COM(2025) 982 and COM(2026) 590, touches Article 6. COM(2025) 982 (2025/0395(COD)) proposes to suspend Art. 45(3) and COM(2026) 590 (2026/0265(COD)) to delete Art. 63; neither is law.