Recyclability performance grades: what your packaging designer needs to know now

Take apart a 30 ml serum pump: a polypropylene body, a stainless steel spring, a glass ball, sometimes a metallized collar. Four materials in an object of a few grams. That object is exactly what Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), is about to grade.

A scale from A to C, calculated by weight and per packaging unit

The PPWR entered into force on February 11, 2025 and applies from August 12, 2026. Its Article 6 sets the principle: every package placed on the EU market must be recyclable, and recyclability becomes a graded requirement.

Annex II defines three grades: A when at least 95% of the packaging unit's weight is recyclable, B from 80%, C from 70%. Below 70%, the package is not considered recyclable, and from January 1, 2030 it may no longer be placed on the market.

The calendar does not stop there. From 2035, packaging must also be recycled at scale: actually collected, sorted, and recycled in installations that exist, not merely recyclable on paper. And from January 1, 2038, grade C disappears. Only packaging graded A or B stays on the market.

The grade starts costing money before 2030. The financial contributions paid under extended producer responsibility (EPR) schemes will be modulated by grade, so a C-rated bottle will pay more than an A-rated one long before any ban applies to it.

The design criteria arrive through delegated acts, and they are not here yet

Article 6 sets the scale, not the method. The Commission must adopt, by January 1, 2028, delegated acts establishing the design-for-recycling criteria and the grading methodology for each packaging category listed in Annex II: glass, metal, paper and cardboard, rigid PET, other rigid plastics, flexible plastics, and so on. Those criteria are expected to look beyond composition, at how easily components separate, how the package behaves in sorting, and the quality of the recycled output.

Where do things stand as of April 20, 2026? No delegated act on recyclability has been adopted. The first PPWR delegated act, adopted on February 25, 2026, deals with something else entirely: a reuse exemption for pallet wrapping films and straps. The Commission published a guidance document and FAQ on the regulation's application on March 30, 2026. And the Environmental Omnibus presented on December 10, 2025 did not reopen the text, so the Article 6 calendar stands.

The regulation carries its own backstop. If the delegated acts run late, the design-for-recycling obligation applies from January 1, 2030 or 24 months after the acts enter into force, whichever is later. The methodology for assessing recycling at scale follows the same logic: due by January 1, 2030, for a requirement that bites in 2035.

Good to know: the Article 6 exemptions cover the immediate packaging of medicinal products, contact-sensitive plastic packaging of medical devices and in vitro diagnostics, and certain infant food packaging, and innovative packaging can obtain a time-limited derogation of up to five years. Nothing for cosmetics. A face cream jar gets the same treatment as a paint can.

The cosmetics traps: multi-material builds and small formats

The grade is assessed per packaging unit, by weight. That is where cosmetics starts at a disadvantage. A standard lotion pump combines polypropylene, a stainless steel spring, and a glass ball. In a one-liter bottle, those few grams dilute into nothing. In a 30 ml bottle, they are a real share of the unit's weight, and every gram that cannot follow the bottle body through its recycling stream pulls the grade down.

The problem formats are easy to spot on a shelf: the glass jar with a plastic lid and metallized seal, the multilayer tube, the compact with a mirror and a magnet, the shrink sleeve covering the whole bottle, the airless pump with its spring. Small formats are a trap of their own. Samples, sachets, and minis routinely slip through optical sorting and end up rejected even when the material itself is recyclable, which is precisely the kind of real-world behavior the coming criteria are expected to capture.

What your designer can do without waiting for the delegated acts

1. Inventory the range by Annex II category. Every reference gets a packaging category, a main material, and a list of components. Most portfolios have never been described this way.
2. Weigh every component. The grade is a weight percentage, so the component-by-component weighing sheet is the base document of the whole exercise. It also tells you immediately which references sit near a threshold.
3. Shortlist the mono-material candidates. Several manufacturers already offer metal-free, all-polyolefin pumps, and a polypropylene cap on a polypropylene bottle is a solved problem. The quickest wins are the components that can switch polymer without touching the formula.
4. Deal with the lost causes now. Full-body sleeves, multilayer laminates, and mirror-and-magnet compacts will not be saved by a minor tweak. A packaging development cycle runs in years, not months, so a format that needs rethinking for 2030 needs its brief written in 2026.

The delegated acts will set the fine print, not the direction. Build the weighing sheet, rank the portfolio against the 70% and 80% lines, and give your designer the two dates that matter: below C is banned in 2030, and grade C is banned in 2038.

FAQ

What are the PPWR recyclability performance grades?

Regulation (EU) 2025/40 defines three grades in Annex II, assessed per packaging unit by weight: grade A when at least 95% of the unit is recyclable, grade B from 80%, and grade C from 70%. Packaging below 70% is not considered recyclable and is banned from the EU market from January 1, 2030.

What happens if the design-for-recycling delegated acts are adopted late?

The regulation includes a backstop: the design-for-recycling obligation applies from January 1, 2030 or 24 months after the delegated acts enter into force, whichever is later. The acts are due by January 1, 2028, and none had been adopted as of April 2026.

Does cosmetics packaging get any exemption from the PPWR recyclability requirements?

No. The Article 6 exemptions cover the immediate packaging of medicinal products, contact-sensitive plastic packaging of medical devices and in vitro diagnostics, and certain infant food packaging. Innovative packaging can get a time-limited derogation of up to five years, but standard cosmetics formats must meet the grades.

Can grade C packaging stay on the market after 2030?

Yes, until December 31, 2037. From January 1, 2038, only packaging graded A or B may be placed on the EU market. In the meantime, extended producer responsibility fees are modulated by grade, so grade C packaging pays higher contributions than A or B.