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Packaging rule · European Union · Design rule

PPWR: all packaging recyclable by 2030

Design rule rule covering all packaging in the European Union, set by European Parliament and Council of the EU. Adopted; applies from 1 January 2030.

By the SPI teamRule ID PR-EU-010Source consulted 14 October 2026Verified 14 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
European Union
Authority
European Parliament and Council of the EU
Rule type
Design rule
Materials
All packaging
Status
Adopted, not yet applying Enacted
Adopted or published
19 December 2024
Applies from
1 January 2030
From the source

“recyclable in an economically viable way by 2030”

Official source European Commission (DG ENV): Packaging wasteOfficial (government or regulator) · consulted 14 October 2026

Deadlines

Key dates

  1. Adopted or published 1 year and 9 months ago

  2. Source consulted by the SPI team 1 day ago

  3. Re-checked by a second SPI team member 1 day ago

  4. Today

  5. Applies from in 3 years and 2 months

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

Packaging placed on the EU market must be recyclable in an economically viable way by 2030, assessed under design-for-recycling criteria, with limited exemptions.

In practice

From 1 January 2030, packaging placed on the EU market is expected to be recyclable, assessed against design-for-recycling criteria and expressed as performance grades A, B or C (PPWR recital 28). Each format and component will be measured against grades set in Commission delegated acts, and from 2035 also against recycling at scale (recital 31). Packaging below grade C is treated as technically non-recyclable, and from 1 January 2038 the minimum is grade B (recital 28). The grades are also linked to the modulation of EPR fees (recital 35).

Where the record is unclear

  • SPI has not yet confirmed the exact wording and deadlines against the operative text of Article 6.
  • The delegated acts setting design-for-recycling criteria and grades were not shown as adopted on the pages consulted.
  • The 2035 recycled-at-scale methodology was not found in adopted form.

Where it sits in the tracker

  • One of 18 packaging rules we track in the European Union, of which 4 are design rule rules.
  • In all, 6 design rule rules are tracked across 2 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

Article 6(1) of Regulation (EU) 2025/40 states that "All packaging placed on the market shall be recyclable", and because that sentence carries no deadline the Commission reads it as applying from 12 August 20261. The measurable tests come later and in two layers. Article 6(2)(a), design for material recycling, applies from 1 January 2030 or 24 months after the Article 6(4) delegated acts enter into force, whichever is later. Article 6(2)(b), separate collection, sorting and recycling at scale, applies from 1 January 2035, or for the at-scale element five years after the Article 6(5) implementing acts enter into force1.

The recitals explain the design. Recyclability is expressed in performance grades A, B and C, packaging below grade C is treated as technically non-recyclable, and from 1 January 2038 the floor rises to grade B (recital 28)2. From 2035 a second assessment looks at the quantity of material actually recycled (recital 31)2. The same grades are meant to modulate producer fees under harmonised criteria, without the Regulation setting the fee amounts (recital 35)2.

Until Article 6(2)(a) bites, manufacturers keep meeting the essential requirements carried over from Directive 94/62/EC, using standards such as EN 13430:20041. The Commission's short version is that all packaging must be recyclable by 20305.

Duties

Who must do what

Packaging manufacturers

  • Place on the market only packaging that is recyclable (Article 6(1)), with the design-for-recycling test applying on 1 January 2030 at the earliest, or 24 months after the Article 6(4) delegated acts if that is later1.
  • Run the Article 38 conformity assessment for recyclability once the Article 6(4) delegated acts are in force; until then it is not required for this requirement (guidance section 6).
  • Meet grade C at minimum when the grading applies and grade B from 1 January 2038 (recital 28)2.
  • Notify the Commission and the competent authority before placing on the market packaging with innovative features that seeks extra time to meet recyclability rules (recital 33)2.

Producers paying EPR fees

  • Expect EPR fees to be modulated by recyclability grade under harmonised criteria; the Regulation does not set the amounts (recital 35).
  • Keep paying EPR fees on exempt sales packaging made of lightweight wood, cork, textile, rubber, ceramic or porcelain, since the exemption does not extend to fees (recital 34).

European Commission

  • Adopt delegated acts with design-for-recycling criteria and grades by 1 January 2028 (Article 6(4)).
  • Adopt implementing acts on the recycled-at-scale methodology by 1 January 2030 (Article 6(5)).
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. Is the item packaging placed on the EU market?

    If yes
    Article 6(1) has applied since 12 August 2026, with graded tests from 2030 and 2035.
    If no
    Article 6 does not apply.

  2. Is it packaging for infant formula or packaging used to transport dangerous goods?

    If yes
    It is exempt from the recyclability requirement.
    If no
    Continue with the material tests.

  3. Is it sales packaging made of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax?

    If yes
    It is exempt from recyclability requirements because each of these materials is under 1% of packaged weight, but EPR fees still apply.
    If no
    The grades apply when the delegated acts take effect.

  4. Would the format score below grade C under the design-for-recycling criteria?

    If yes
    It is treated as technically non-recyclable and cannot be placed on the market once the grading applies.
    If no
    Grade C is enough until 31 December 2037; grade B is needed from 1 January 2038.

  5. Does the packaging have innovative features with demonstrable environmental benefits?

    If yes
    It may get extra time to meet the recyclability rules, after notification to the Commission and the competent authority.
    If no
    The standard timetable applies.
Checklist

Compliance checklist

  1. Keep current design files against Directive 94/62/EC requirements

    By Now

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Until the Article 6(2)(a) date, recyclability is shown against the essential requirements carried over from the old Directive, with EN 13430:2004 as the reference standard.

    Evidence to keep Per-format EN 13430 assessment held in the technical file.

  2. Rank formats by likely grade

    By Now

    Score each format and component, including closures, labels and barrier layers, against current design-for-recycling guidance to find candidates for grade C or below.

    Evidence to keep Portfolio grid by format, material, component and provisional grade.

  3. Read the delegated acts on criteria and grades

    By 2028-01-01

    The Article 6(4) delegated acts are due by this date. The 24-month clock for Article 6(2)(a) starts from their entry into force, so their publication date sets the real deadline.

    Evidence to keep Dated note of the act's entry into force and the derived application date.

  4. Prepare the Article 38 conformity assessment

    By When the Article 6(4) acts enter into force

    From this point recyclability becomes part of the conformity assessment, the technical file and the declaration of conformity each manufacturer signs.

    Evidence to keep Conformity assessment file and signed EU declaration of conformity per format.

  5. Redesign formats below grade C

    By 2030-01-01

    Formats below grade C cannot be placed on the market once Article 6(2)(a) applies; plan redesign or withdrawal.

    Evidence to keep Redesign plan with supplier approvals and last production date for each affected format.

  6. Plan for recycled-at-scale evidence

    By 2035-01-01

    From 2035, or five years after the Article 6(5) implementing acts, recyclability also depends on collection, sorting and recycling at scale; track the methodology due by 1 January 2030.

    Evidence to keep Market-by-market record of collection and sorting availability for each material.

  7. Lift grade C formats to grade B

    By 2038-01-01

    The minimum grade rises on this date, so grade C formats need a second redesign cycle.

    Evidence to keep Grade upgrade plan for every format still at grade C.

Enforcement

Enforcement and penalties

Who enforces
Each Member State's market surveillance bodies, acting on the basis of Regulation (EU) 2019/1020, check the conformity documents drawn up under PPWR Articles 38 and 39 (guidance sections 2, 5 and 6).
Powers
Authorities can examine the technical documentation and EU declaration of conformity and act against packaging that fails recyclability rules once the grades apply; national EPR schemes apply fee modulation linked to the grades.
Enforcement so far
Graded recyclability has not started; no case is shown on the Commission pages reviewed for this rule.

No fine for non-recyclable packaging is written into the PPWR provisions cited here. Member States lay down the sanctions; as of 14 October 2026 SPI has not yet confirmed the wording of the PPWR article that requires them against the official text. In practice the first financial effect is likely to come through EPR fee modulation by grade, which recital 35 foresees2.

Connections

How it fits with other rules

  • Packaging and Packaging Waste Directive 94/62/EC repealed PR-EU-013
    The Commission guidance says that until Article 6(2)(a) applies, manufacturers still meet the recyclability essential requirements of the repealed Directive 94/62/EC and standards such as EN 13430:2004. The old Directive therefore keeps a practical role for this rule into 2030 or later.
  • PPWR: 2030 minimum recycled content in plastic packaging PR-EU-004
    Recycled content targets for plastic packaging start in 2030, the same year as design for recycling. A pack that drops below grade C cannot be sold, so its recycled content no longer matters; the two rules need to be planned together.
  • PackUK year 2 (2026-27) modulated packaging EPR fees PR-GB-003
    The UK modulates producer fees by a red, amber and green recyclability rating. Recital 35 foresees EU fees modulated by PPWR grades, so firms selling in both markets will face two separate grading systems for one pack.
  • SUP Directive: tethered caps on plastic beverage containers PR-EU-015
    Tethered closures stay attached to the bottle and travel into the same recycling stream. Closure material and attachment design therefore feed the bottle's grade under the Article 6(4) criteria.
  • California SB 343 recyclability labelling restrictions PR-US-011
    California's SB 343 controls when a recyclability claim may appear on a label, while Article 6 controls whether the pack may be sold at all. The tests use different criteria, so a grade under one does not prove compliance with the other.
Timeline

History of the rule

  1. Commission proposes recyclability grades in COM(2022) 677.

  2. Parliament approves the negotiated text with the 2030, 2035 and 2038 steps.

  3. Regulation (EU) 2025/40 enters into force.

  4. Commission Notice C/2026/3084 sets out the staged application dates for Article 6.

  5. Article 6(1) applies with the rest of the Regulation, according to the Commission.

  6. Today

  7. Delegated acts on design-for-recycling criteria and grades due (Article 6(4)).

  8. Earliest date for design for recycling; recycled-at-scale methodology acts due (Article 6(5)).

  9. Earliest date for the recycled-at-scale test.

  10. Minimum grade rises from C to B.

Questions

Questions

Does the PPWR recyclability rule already apply in 2026?

The Commission reads Article 6(1) as applying from 12 August 2026 because it has no deadline of its own. The graded design-for-recycling test applies only from 1 January 2030 or 24 months after the criteria acts, whichever is later.

Is grade C enough to stay on the EU market?

Grade C is the minimum when the grading first applies. From 1 January 2038 packaging must reach at least grade B, and anything below grade C is treated as technically non-recyclable (recital 28).

Which packaging is exempt from recyclability requirements?

The Legislative Observatory summary lists infant formula packaging, packaging for transporting dangerous goods, and sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax. Recital 34 explains that each of those materials is under 1% of packaged weight.

Do exempt packs still pay EPR fees?

Yes. Recital 34 of Regulation (EU) 2025/40 says the recyclability exemption does not remove the obligation to pay extended producer responsibility fees. Fee modulation by grade under recital 35 applies to packaging that is graded.

What happens if the criteria acts are late?

The design test applies 24 months after the Article 6(4) delegated acts enter into force if that is later than 1 January 2030. The acts are due by 1 January 2028, so a delay beyond that date moves the deadline back by the same amount.

Glossary

Definitions

Placing on the market
Defined in EU Packaging and Packaging Waste Regulation (PPWR) applies PR-EU-001
Sources

Sources for this analysis

  1. EUR-Lex: Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40, sections 2, 5 and 6 Official · Consulted 14 October 2026
  2. EUR-Lex: Regulation (EU) 2025/40, OJ L 22.1.2025, recitals 28 to 35 Official · Consulted 14 October 2026
  3. European Commission Green Forum: PPWR implementation timeline Official · Consulted 14 October 2026
  4. European Parliament Legislative Observatory: Regulation (EU) 2025/40 summary Official · Consulted 14 October 2026
  5. European Commission (DG ENV): Facts about the new EU rules on packaging and packaging waste Official · Consulted 14 October 2026
  6. European Parliament Legislative Observatory: procedure file 2022/0396(COD) Official · Consulted 14 October 2026
  7. European Commission (DG ENV): Packaging waste Consulted 13 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 14 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Changed: rate note

  3. Verified by a second SPI team member

  4. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-EU-010 and the source. Corrections are logged in this history.

Other jurisdictions

Design rule rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
Administrative Measures for Postal and Express PackagingPR-CN-002ChinaDesign ruleAll packagingIn force12 March 2021
GB 23350-2021 restriction of excessive packaging (food and cosmetics)PR-CN-003ChinaDesign ruleAll packagingIn force1 September 2023

Every design rule rule in the tracker

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