Recyclability is not a property of the polymer alone. The assessment covers the whole packaging, its components and its behaviour in the relevant collection, sorting and recycling system.
The two pillars of Article 6
The PPWR combines technical design for recycling with a subsequent assessment of whether the relevant packaging category is actually recycled at scale.
The whole packaging matters
The main polymer does not determine the result on its own. Labels, sleeves, adhesives, closures, barriers, pigments, additional components and their separability during processing can all matter.
Grades A, B and C
The PPWR sets recyclability performance thresholds:
- A – at least 95%;
- B – at least 80%;
- C – at least 70%.
A result below 70% fails to meet the relevant technical recyclability threshold in the table in Annex II.
The 2030 stage
Design-for-recycling requirements are to apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever date is later.
The 2035 stage: recycling at scale
At the next stage, technical recyclability alone will no longer be sufficient. The actual operation of collection, sorting and recycling systems for the packaging category will also matter. The recycled-at-scale requirement applies from 1 January 2035 or five years after the relevant implementing acts enter into force, whichever date is later.
The 2038 stage
From 2038, standard market access is to require grade A or B. Grade C should therefore be treated as a transitional solution rather than a long-term design objective.
Recyclability and recycled content
Articles 6 and 7 answer different questions. Packaging can contain a high percentage of PCR while having poor recyclability. It can also contain no recycled material but be well designed for the next material cycle.
RecyClass and the PPWR
RecyClass methodologies can support technical assessment and design development. However, a current RecyClass result should not automatically be equated with a future legal PPWR grade. Compliance remains based on the legislation and the acts adopted under it.
Key point
Manufacturers should manage recyclability as a design parameter for the whole packaging, with control over components, versions and evidence, rather than as a simple characteristic assigned to one polymer.