Article 6 is the heart of the PPWR. It introduces two tests that every piece of packaging must eventually pass: design for recycling and recycling at scale.
Design for recycling (from 2030)
Packaging must be designed so it can be collected, sorted and recycled using established processes. Performance is graded by recyclability class, with the lowest-performing designs progressively restricted. The criteria will be set out in delegated acts by packaging category — paper, rigid plastic, flexible plastic, glass, metal, and composites.
Recycled at scale (from 2035)
Designing for recycling is not enough — the material must be recycled in practice, at meaningful volumes, across the EU. Formats that cannot demonstrate at-scale recycling face restriction even if they are technically recyclable.
What pushes a grade down
- Multi-material laminates that cannot be cleanly separated.
- Carbon-black pigments that defeat near-infrared sorting.
- Full-body shrink sleeves on PET bottles.
- Non-compatible adhesives, inks or barrier coatings.
Designing up the scale
Mono-material structures, detachable components and sorting-friendly colours all raise a grade. The practical challenge is keeping a defensible record of the recyclability assessment for every SKU — grade, rationale, and the evidence behind it — so it survives an audit and updates cleanly when a design changes.
Recyclability grades depend on delegated acts that are still being finalised. Re-assess your portfolio as the detailed criteria are published.