PPWR Article 6 is the heart of the regulation. It says every packaging item placed on the EU market must be "designed for recycling" and assigns each item a grade: A, B, C, or D. From 2030 onwards, Grade D packaging cannot be placed on the market at all.
What that grade actually means, how it gets calculated, and what evidence is required, is where the work happens. This guide walks through it.
What "designed for recycling" actually means
Under Article 6, packaging is recyclable if it can be collected, sorted, and reprocessed into secondary raw materials of sufficient quality to be used in producing new packaging or other products, at scale, in the EU.
That definition has three operational components:
- Collection. The packaging type is part of an established collection stream in the EU Member States where it's placed on market.
- Sortability. The packaging can be separated from other materials in standard MRF (material recovery facility) sorting, given current technology.
- Recyclability at scale. The recovered material can be reprocessed into a usable secondary raw material — not just theoretically, but in commercial volumes today.
A material that fails any of these three is not "recyclable" under PPWR, regardless of what it says on the consumer-facing label.
How A/B/C/D grading works
The Commission has set thresholds for what percentage of the packaging is recyclable, weighted by recyclability performance:
| Grade | Threshold | Status |
|---|---|---|
| A | ≥ 95% recyclable | Best-in-class. Lowest EPR fees. Future-proof. |
| B | ≥ 80% recyclable | Compliant, but EPR fees scale unfavourably. |
| C | ≥ 70% recyclable | Compliant for now. Phase-out risk. |
| D | < 70% recyclable | Non-compliant from 2030. Cannot be placed on market. |
Where producers commonly underestimate
Multi-layer films
The single biggest Grade D risk for food and personal care brands. A flexible pouch with PE/EVOH/PE structure looks like polyethylene to the consumer but is unrecyclable in current EU streams. PPWR explicitly identifies multi-material laminates as needing redesign or replacement.
Carbon black colourants
Carbon-black-pigmented PET and HDPE bottles are invisible to NIR sortation. They end up as residue. Even if the polymer would otherwise be recyclable, carbon black moves the item toward Grade C or D.
Composite packaging
Beverage cartons, paper-with-plastic-window, foil-lidded plastic trays. Each component may be recyclable independently; the packaging as placed on market often isn't. Article 6 grades the item as sold, not its theoretical decomposition.
Adhesive labels and sleeves
Full-body sleeves on PET bottles can move an otherwise Grade A bottle into Grade C if the sleeve material or adhesive interferes with sortation or wash steps. The label is part of the packaging under PPWR.
The evidence chain Article 6 requires
Claiming Grade A is not enough. Producers must demonstrate it. The evidence chain typically includes:
- Material composition data per packaging component, sourced from suppliers
- Test reports for sortability under conditions reflecting EU MRF standards
- Documentation of recycling-stream availability in target markets
- Methodology used to determine the grade, signed by a competent person
- Five-year retention of the above (Article 26)
Each piece must be linkable to the specific packaging record it supports. Auditors will ask "show me the test report this Grade A claim is based on." If the answer is "let me search my email," the answer is wrong.
How to do the work
- Inventory packaging at component level. Not "PET bottle." Bottle body + cap + neck-ring + label + adhesive + sleeve. Each component has its own composition and recyclability behaviour.
- Map to recycling streams. For each component, identify the EU streams that accept it. Where the answer differs by Member State, record per-market.
- Compute the weighted recyclability percentage. By weight and by component, applying the methodology in PPWR Annex II.
- Apply the grade thresholds. Items that come out under 95% but above 80% are Grade B; below 70% is Grade D.
- Build the evidence pack. For each Grade A or B claim, ensure the supporting documentation is accessible, current, and signed.
For most producers, the bottleneck isn't the recyclability calculation, it's having the underlying material composition data accurately and at scale. PackR8 was built around this problem; our comparison page walks through how that's different from running the same workflow in spreadsheets.
The redesign path
If your inventory shows Grade D items, the redesign options are usually one of:
- Mono-material substitution. Multi-layer pouches becoming mono-PE or mono-PP, sometimes with EVOH-functional alternatives.
- Colour change. Carbon black to NIR-detectable alternatives (Cabot, Holland Colours, and others ship qualified options).
- Component separation. Designing labels and sleeves that detach in wash, or moving from full-body sleeves to wrap labels.
- Material swap. Where redesign isn't viable, switching to a fundamentally different material (rPET vs PVC, paper vs plastic where appropriate).
None of these are quick. Material qualification cycles run 6-18 months. Article 6's 2030 deadline is closer than it looks, and the rPET supply you'll need for some swaps is already constrained.
Producers who started this work in 2024-2025 are the ones with options in 2030. Producers starting in 2028 will be making compromises against locked-in supplier capacity.