PPWR recyclability: What companies need to know and check now

What does recyclability under the PPWR mean?

A package is recyclable under the PPWR Regulation if it meets two requirements:

1. The material recovered from the recycled packaging must be of sufficient quality to replace virgin raw material.

2. The packaging must be suitable for separate collection and sorting without contaminating other waste streams. It must also be recycled at scale.

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Designed for recycling – what does that mean in practice?

“Design for Recycling” (DfR) means designing packaging so that it can be recycled. What matters is not how the packaging looks, but its structure and materials. These must be separable and sortable appropriately. Individual components such as closures, labels, adhesives or coatings must not compromise the recyclability of the main packaging component.

For a beverage bottle, this includes the bottle, cap and label. Each component must be compatible with established collection, sorting and recycling processes. One point is important for your planning: The specific criteria for the individual design-for-recycling categories have yet to be defined. Start collecting all your packaging data now. This will allow you to assess your packaging once the criteria are available.

Recyclability and minimum recycled content are not the same

Recyclability and minimum recycled content both relate to packaging, but they answer different questions. Can the packaging be collected, sorted and recycled after use? That describes its recyclability. How much recycled plastic does the packaging contain? That is what the minimum recycled content requirement addresses. Recycled material is material recovered from waste and used again.

A PET bottle (PET stands for polyethylene terephthalate) can therefore be designed for easy sorting and recycling while still being made from virgin plastic. Conversely, recycled plastic content does not automatically make packaging easy to recycle. Assess the recycled content of your materials and the recyclability of your packaging separately.

When do the requirements for PPWR recyclability apply?

There is no single deadline for PPWR recyclability. Instead, the PPWR introduces the requirements in stages.

When the regulation applies and initial obligations

The PPWR states: “All packaging placed on the market must be recyclable.” However, the specific criteria for assessing recyclability will be established only through further EU legal acts. The regulation also provides for exemptions for certain types of packaging. Whether an exemption applies depends on the type of packaging and how it is used.

Design-for-recycling criteria and assessment grades

The first specific assessment step concerns Design for Recycling (DfR). Packaging must be designed so that its materials can be recycled and the recovered material can replace virgin raw materials. Recyclability is assessed in three performance tiers – Class A, B or C. These tiers indicate how well packaging meets the criteria for recyclable design. The EU weights the criteria for each packaging category and calculates a percentage score. Class A requires 95%, Class B 80% and Class C 70%. Below 70%, packaging is considered technically non-recyclable and its placing on the market is restricted.

Recycling at scale and later requirements

Another assessment is introduced through “Recycled at Scale”, meaning recycling at scale. It is not enough for packaging to be designed for recycling; it must also be collected, sorted and recycled in significant volumes in practice. The PPWR assesses this by comparing how much packaging material from a category is placed on the market with how much is recycled. The PPWR requires manufacturers to make financial contributions for their packaging under extended producer responsibility. In future, the recycling grade is also expected to affect the amount of these contributions. The EU still has to determine the contribution for each grade.

All requirements at a glance

Some requirements have two possible dates. Why is that? The PPWR links some obligations to further EU legal acts. If the relevant legal act enters into force on time, the date specified in the regulation applies. If it enters into force later, the start date is postponed accordingly.

Who is affected by the PPWR recyclability requirements?

The PPWR obligations that apply to your company depend on your role in the supply chain. The PPWR distinguishes four roles: manufacturer, supplier, importer and distributor.

Obligations for manufacturers

Who is considered a manufacturer? A manufacturer is any person or company that has packaging or a packaged product developed or made under its own name or brand. Manufacturers must assess the packaging against the EU criteria. They must document the packaging’s recyclability and include the evidence in the technical documentation. Before placing the packaging on the market, the manufacturer must carry out the required conformity assessment and prepare the technical documentation. Once conformity has been demonstrated, the manufacturer issues the EU Declaration of Conformity.

Obligations for suppliers

Who is considered a supplier? A supplier is a company or person that supplies packaging or packaging material to a manufacturer. Suppliers must provide the manufacturer with the information and documentation needed to demonstrate the packaging’s conformity. This may include details of materials, components and packaging design. The manufacturer uses this information for its assessment and documentation.

Obligations for importers

Who is considered an importer? An importer is a company or person based in the EU that first makes packaging from a non-EU country available on the EU market. Importers must ensure that the manufacturer has carried out the required conformity assessment and prepared the technical documentation. If an importer has reason to believe that packaging does not meet the applicable requirements, it must not place it on the market until conformity has been achieved.

Obligations for distributors

Who is considered a distributor? A distributor is a company or person in the supply chain that makes packaging available on the market, other than the manufacturer or importer. Distributors must take the PPWR requirements into account carefully when making packaging available. If packaging is non-compliant, they must not make it available on the market until compliance has been achieved. Distributors must store and transport packaging in a way that keeps it compliant.

Preparing for PPWR recyclability: A step-by-step approach

To assess the PPWR recyclability of your packaging, it is best to proceed step by step. Note that the Commission has yet to define the detailed criteria and assessment methods for each packaging category.

1. Take stock of your packaging and clarify responsibilities

• List all packaging that your company places on the EU market — including secondary, transport and shipping packaging. For each item, note whether your company acts as the manufacturer, supplier, importer or distributor.
• Decide who will coordinate the assessment and obtain any missing data from suppliers.

2. Document the materials and structure of each item of packaging

• Record the material, packaging type and components, such as the label, closure, adhesive or coating.
• Note which parts are attached and which are separate. This matters because integrated and separate components are assessed differently.

3. Assess recyclability against the applicable criteria

• Check which EU criteria and assessment methods apply to the relevant packaging category.
• Record the method used and the date of your assessment. Update it when new rules apply.

4. Request information and evidence from suppliers

• Ask suppliers for the technical details needed for your assessment — for example, information about materials, components and packaging design. They must provide the manufacturer with the necessary information and documentation.
• Record missing or conflicting information. Track evidence of recycled content separately: This is a distinct PPWR requirement and is not the same as recyclability.

5. Set priorities and document every change

• Start with packaging for which important data is missing or changes may be needed. Define the next step and the person responsible for each item.
• Record assessments, evidence, open questions and changes. Evidence of recyclability belongs in the technical documentation.

What does the PPWR minimum recycled content requirement mean?

The minimum recycled content (also called the minimum recycled material content) specifies how much recycled plastic must be contained in plastic packaging. It does not indicate whether the packaging itself is designed for recyclability. Minimum percentages depend on packaging type and format. They apply no earlier than 2030. If the EU act on calculation and verification enters into force later, the obligation will begin three years after that. Minimum thresholds will increase from 2040.

What should companies do now to prepare for PPWR recyclability?

You can get started even before all the detailed rules are in place. Take stock of the packaging data you already have and identify what is still missing. Clarify who is responsible and assign the appropriate role in your company to each item of packaging. Fill in missing data and collect information about materials and components. Keep recycled-content information separate from your recyclability assessment. Track deadlines and new EU rules. Update your assessment once the criteria apply. For more information about PPWR obligations, see our overview of the PPWR labelling requirements.

Stay on top of your PPWR obligations with leadity

Meeting your obligations under the PPWR requires clear organisation and a structured overview. Yet packaging data, deadlines and evidence are often spread across different teams. Bring them together in one place to identify outstanding PPWR recyclability requirements earlier. Our PPWR software helps you centralise packaging data, manage evidence in a structured way and implement regulatory requirements more efficiently.

Your benefits with leadity:

• A central packaging database for your packaging and material data.
• You can prepare technical documentation faster and capture requirements for substance composition, labelling and reusability.
• You can generate Declarations of Conformity (DoCs) in a central system in line with PPWR requirements.
• You can manage supplier documents, certificates and declarations centrally and keep them traceable.
• You can transfer packaging data from existing systems.

In summary: Preparing for PPWR recyclability in a structured way

The PPWR introduces new requirements for packaging, data and evidence. The obligations that apply depend on the type of packaging and your role in the supply chain. Take stock of your packaging portfolio, clarify responsibilities and close data gaps. This will give you a reliable basis for the next steps. For a comprehensive overview of the regulation, see our article on the PPWR.