Under the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40), all packaging placed on the market must be recyclable, and recyclability is expressed as a performance grade of A, B, or C against a defined methodology. The recyclability assessment is the work a producer does to establish that grade for each packaging format. The grade does two jobs: it is a market-access gate, because the lower grades are squeezed out of the market over time, and it is a cost lever, because the extended producer responsibility fee is modulated by it. The exact grading methodology is set through Commission delegated acts.
The PPWR does not ask packaging producers for a money-laundering-style risk assessment. The assessment instrument at the center of the regime is the recyclability assessment: the analysis that establishes whether a packaging format is designed for recycling and what performance grade it earns. Because that grade controls both whether the packaging can be sold and how much the producer pays in EPR fees, the assessment is the document the whole obligation turns on. This guide covers what the assessment must establish, how the grades work, what the grade drives, and how to document it.
What the assessment establishes
All packaging placed on the EU market must be recyclable, which the PPWR defines as designed for material recycling and, once it becomes waste, capable of being separately collected, sorted, and recycled at scale. The recyclability assessment establishes both halves of that test for a given format: that it is designed for recycling against the criteria, and that it fits the collection and sorting reality. The output is a performance grade. The regulation entered into force on 11 February 2025 and applies generally from 12 August 2026, with the recyclability grades themselves applying from 2030 and a stricter minimum grade taking effect in 2038.
How the grades work
The PPWR expresses recyclability as a performance grade, A, B, or C, assigned against a defined methodology set through Commission delegated acts. A delegated act is the detailed implementing rule the Commission adopts to fill in a framework regulation, so the grading methodology is being finalized through those acts rather than spelled out in full in the regulation itself. The grade reflects how well the packaging is designed for recycling.
| Grade | What it signals |
|---|---|
| Grade A | The strongest design-for-recycling performance against the methodology. |
| Grade B | Intermediate design-for-recycling performance. |
| Grade C | The lowest passing performance; over time the lower grades are progressively squeezed out of the market. |
Because the exact methodology and thresholds are set by delegated acts, the grade an existing format earns can move as those acts are finalized. The assessment has to be re-run against the methodology in force, not against an earlier expectation.
What the grade drives
The recyclability grade carries two consequences at once.
- Market access. Recyclability is a condition of placing packaging on the market, and as the regime matures, packaging will need to reach the higher grades to remain saleable. A format that cannot reach a passing grade is a market-access problem, not just a cost one.
- Eco-modulated fees. Extended producer responsibility under the PPWR is operated per Member State, and producer fees are modulated according to the recyclability performance grade. A better grade means a lower fee, so the assessment has a direct and recurring cost effect. The fee modulation begins eighteen months after the relevant delegated and implementing acts enter into force.
The obligation falls on the producer: under the PPWR, the producer is the operator that first makes packaging available on the market of a Member State, whether the manufacturer, importer, or seller depending on the arrangement. That is the entity that must hold the recyclability assessment.
How to conduct one
Step 1: Define the packaging format and its materials
Identify the format, its components and materials, and the product it packages, since the unit of assessment is the format, not the company.
Step 2: Apply the design-for-recycling criteria
Assess the format against the criteria in the methodology in force, including material composition, separability, and any features that impair recycling.
Step 3: Establish the performance grade
Determine the A, B, or C grade the format earns against the methodology.
Step 4: Connect the grade to market access and fees
Check the grade against the market-access thresholds that apply to the format and the eco-modulated fee it produces in each Member State of sale.
Step 5: Document and re-run on change
Keep the assessment in the technical documentation, and re-run it when the format changes or when a delegated act changes the methodology.
Where it goes wrong
- Assessed against the wrong methodology. The grade is taken from an earlier expectation rather than the delegated act in force.
- Treated as a cost question only. The producer optimizes the fee but misses that a low grade is also a market-access gate as the regime matures.
- Not in the technical file. The grade is asserted but the supporting assessment is not retained as part of the conformity documentation.
Treat the recyclability grade as a live number, not a one-time label. Because the methodology is set by delegated acts that are still being finalized and the market-access thresholds tighten toward 2030 and 2038, a format that passes today can slip a grade tomorrow, and the fee follows it. The producer that re-runs the assessment against the rules in force keeps both its market access and its EPR cost under control. For the wider regime, see the packaging EPR compliance guide and the packaging EPR glossary; for how a materiality-style assessment scopes a reporting obligation, see the CSRD double materiality assessment.
Primary sources
- Regulation (EU) 2025/40 (PPWR), Article 6 (recyclable packaging): All packaging must be designed for recycling and is graded against a defined methodology in performance classes A to C; the grade is set out through delegated acts and gates market access over time.
- Regulation (EU) 2025/40 (PPWR), extended producer responsibility and fee modulation: EPR is operated per Member State; producer fees are modulated according to the packaging's recyclability performance grade.