The most consequential technical element of the PPWR is the recyclability grading system. When the A–E grades are adopted (EU Commission delegated acts expected by 1 January 2028), they will become the primary driver of EPR fee differentials across the entire EU. Brands whose packaging lands in Grade D or E face materially higher costs from 2030. Brands in Grade A or B will pay less.
This article explains how the grades will work, what the current state of technical development is, and how to position your packaging ahead of the 2028 deadline.
PPWR Article 6 requires all packaging placed on the EU market to be recyclable, with recyclability assessed against criteria to be established by the Commission through delegated acts. Article 6(3) specifically mandates that the Commission adopt delegated acts establishing:
PPWR Article 7 requires that EPR fee modulation is based on these grades. The link is legally mandated: once grades are adopted, all EU PROs must reflect them in fee structures.
Timeline:
The Commission is developing the recyclability assessment methodology in collaboration with industry bodies (CEFLEX for flexible packaging, RecyClass for rigid packaging, CITEO for French-specific criteria) and the European Environment Agency.
The methodology is expected to assess packaging against four dimensions:
Can the packaging format be correctly identified and sorted by automated sorting facilities (near-infrared spectroscopy, optical sorters, AI-vision sorters)? Packaging that can't be detected or is misidentified falls to lower grades.
Key sortability factors:
Is the packaging format actually collected for recycling in existing EU infrastructure? Even theoretically recyclable packaging fails if collection rates are below meaningful thresholds.
Collection rate benchmarks (approximate current EU averages):
Packaging with collection rates below ~30% is unlikely to achieve Grade C.
Once collected and sorted, can the packaging be physically recycled into usable secondary material without excessive contamination loss or contamination of other streams?
Factors affecting this dimension:
Does recycling the packaging produce secondary raw material of usable quality? Packaging that degrades the recycled output (through contamination or depolymerisation) scores lower on this dimension.
Based on current technical work by RecyClass, CEFLEX, and national PROs, here is an indicative mapping. This is not the Commission's final determination — grades are still being formalised.
| Packaging format | Indicative grade | Key factors |
|-----------------|-----------------|-------------|
| Clear PET bottles | A | High collection, well-sorted, clean recycle |
| Clear HDPE bottles and containers | A | High collection, reliable sorting |
| Natural/white HDPE containers | A | Same as above |
| Corrugated cardboard (uncoated) | A | Very high collection, established recycling |
| Folding carton (uncoated/clay-coated) | A/B | High collection, some variability |
| Aluminium cans | A | High collection, efficient recycling |
| Steel cans and tins | A | High collection, established recycling |
| Glass bottles and jars | A/B | High collection; slightly lower for coloured glass |
| PP rigid containers | B/C | Sortable but collection rates lower than PET/HDPE |
| Paper/board with aqueous barrier | B/C | Deinkable/re-pulpable; barrier affects scoring |
| Coloured HDPE (non-dark) | B/C | Sortable; slightly lower quality recycled output |
| Dark HDPE and dark PET | D | NIR sorting failure; contaminates stream |
| LDPE flexible film | C/D | Not collected curbside in most EU; film-to-film recycling emerging |
| Multi-layer flexible film (coffee pouches, snack bags) | D/E | Not separable; not recycled at scale; contaminates |
| EPS foam | D | Low collection; contamination issues; non-economic recycling |
| PVC | E | Chlorine contamination of recycling streams; being phased out |
| Paper with PE laminate | C/D | Not de-lamiable in most facilities; some specialist recycling |
| Paper with PVDC coating | D/E | Contamination of paper recycling; not separable |
| Aluminium-plastic laminate | D/E | Separation technically possible but not at scale |
The PPWR requires that EPR fees be differentiated based on grades, but the exact multipliers are not specified in the regulation — they're left to member states to determine (within harmonised bands that the Commission will set).
Based on current national eco-modulation systems and the political direction, the expected structure for 2030:
| Grade | Expected fee treatment |
|-------|----------------------|
| A | Baseline rate or below; possible bonus discount of 20–40% |
| B | Baseline rate or modest discount of 5–15% |
| C | Baseline rate |
| D | Surcharge of 50–100%+ on baseline |
| E | Surcharge of 100–200%+ on baseline; de facto phase-out pressure |
For a brand using Grade D flexible film pouches for a product currently paying €300/tonne in France, the 2030 fee could be €450–€600/tonne for that packaging format. At scale, this creates significant incentive to redesign.
Brands that complete packaging transitions to Grade A/B formats before 2030 benefit in three ways:
1. Lower fees from 2030: Every tonne shifted from Grade D to Grade A packaging represents 50–100%+ fee savings in perpetuity.
2. Eco-modulation discounts in the interim: France's eco-modulation system already applies discounts for recyclable packaging. Transitioning now captures those discounts in 2026–2029 before mandatory grades.
3. Procurement advantage: As EU retailers (particularly German and French retail) apply their own sustainability requirements to supplier packaging, Grade A packaging becomes a supply chain differentiator.
4. Consumer communication: Once PPWR mandated labeling (post-2028 delegated acts) requires recyclability grade labels on packaging, Grade A becomes a visible consumer differentiator.
Until the formal Commission delegated acts are adopted, you can use the following practical heuristics:
Likely Grade A/B:
Likely Grade C:
Likely Grade D/E:
Use RecyClass and CEFLEX tools: Both organisations publish online assessment tools that score packaging formats against current recyclability criteria. RecyClass (for rigid plastics: recylass.eu) and CEFLEX (for flexible packaging: ceflex.eu) provide the most authoritative pre-delegated-act guidance.
The Commission will conduct a consultation process before adopting the grade system. Trade associations (EUROPEN, FEFCO for corrugated, Plastics Europe) are actively engaged.
What to track:
Brands with significant packaging spend should engage through industry associations to influence the grade definitions for packaging formats where the classification is uncertain (particularly the Grade B/C/D boundary for various plastic formats).
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For the fee structures these grades will drive, see EPR cost modelling across 7 EU markets. For the design changes that move you up the grade scale, see Packaging redesign for EPR savings.