PPWR Recyclability Grades A, B and C: What a Grade Rests On While the Article 6 Act Is Pending
On 31 August 2026 a customer ticket put the problem in one line: the recyclability grade is displayed, but nothing says what it rests on. Three days earlier, a quality manager at a German chemicals company had written that he was “a bit confused because the EU hasn’t published the calculation scheme yet”. Both were describing the same gap, and the gap sits in the regulation itself, not in any tool.
Regulation (EU) 2025/40 defines three recyclability performance grades, A, B and C, and fixes their thresholds in Annex II. What it has not yet delivered is the method that turns a real packaging unit into one of those letters: the design-for-recycling criteria of Article 6(4), which the Commission has until 1 January 2028 to adopt. This article, first published on 15 March 2026 and rewritten in September 2026, explains what a grade is, which obligation binds today, what a grade displayed now is worth, and why a metal handle or a removable label can move the letter.
Key facts
- Article 6(1), recyclable packaging: all packaging placed on the market shall be recyclable, in force since 12 August 2026, transport packaging included (Regulation (EU) 2025/40, Article 6).
- Three grades: grade A is 95 % or higher, grade B is 80 % or higher, grade C is 70 % or higher; below 70 % the packaging unit is technically non-recyclable (Annex II, Table 3).
- Graded floor, Article 6(2), point (a): applies from 1 January 2030 or 24 months from the entry into force of the Article 6(4) delegated acts, whichever is the latest; from 1 January 2038, only grades A or B (Article 6(3)).
- Article 6(4) delegated act: due by 1 January 2028; not adopted as of the referential baseline of 3 September 2026.
- EN 18120: published in April 2026, 14 parts; recorded by the referential as not harmonised and as giving no presumption of conformity.
- Verification baseline: PPWR Connect referential, reviewed 3 September 2026.
What is a PPWR recyclability grade?
A recyclability performance grade is the letter, A, B or C, that Regulation (EU) 2025/40 assigns to a packaging unit according to the share of the unit that is recyclable, under Table 3 of Annex II. Grade A is 95 % or higher, grade B is 80 % or higher, grade C is 70 % or higher. Below 70 %, the packaging unit is technically non-recyclable.
The regulation knows three grades and nothing beneath them. A unit under the grade C floor does not receive a lower letter; it leaves the scale. Table 3 says so in its own words: when a packaging unit’s recyclability performance grade is below 70 %, “the packaging will be considered technically non-recyclable and its placing on the market shall be restricted”. Any material that presents a five-letter scale is quoting the 2022 proposal, not the adopted text. The thresholds are in the regulation today; the criteria that produce the percentage, for which Table 4 of Annex II lists parameters, are not.
Which recyclability obligation applies today, and which one is still waiting?
Article 6(1) applies today: all packaging placed on the market shall be recyclable, since 12 August 2026, transport packaging included (Regulation (EU) 2025/40, Article 6). The graded floor of Article 6(2), point (a), is waiting: it applies from 1 January 2030 or 24 months from the entry into force of the Article 6(4) delegated acts, whichever is the latest.
The March 2026 version of this article presented 1 January 2030 as a firm date for the grade C floor. The referential now returns that formulation as contradicted, and the correction is textual. The fourth subparagraph of Article 6(2) reads: “Point (a) of the first subparagraph of this paragraph shall apply from 1 January 2030 or 24 months from the date of entry into force of the delegated acts adopted pursuant to the first subparagraph of paragraph 4, whichever is the latest.” The date is a floor, not a deadline.
The second step is dated in the text. The third subparagraph of Article 6(3) states that from 1 January 2038 packaging shall not be placed on the market unless it is recyclable within grades A or B, and the 2038 column of Table 3 marks grade C as “cannot be placed on the market”. Grade C is a transitional grade by construction.
What does a recyclability grade displayed in September 2026 rest on?
A grade displayed today rests on a method chosen by whoever produced it, not on the harmonised criteria of Article 6(4), because those criteria are not adopted. The referential records the Article 6(4) delegated act as due by 1 January 2028 and not adopted at its baseline of 3 September 2026. A grade shown without its method, version and date is an unsupported number.
That is what the ticket of 31 August 2026 was pointing at. A letter on a screen looks like a regulatory verdict; in September 2026 it cannot be one, for anybody, whatever the software or the laboratory behind it. It can be a documented estimate, which tells a brand owner which packaging units are far from the floor, which are close, and which components drive the result. A grade that can be defended in a supplier dispute carries five things next to the letter: the method, its version, the date, the packaging unit assessed, and the composition of each of its components. Our article on what applies now and what waits on an act develops that register.
Is EN 18120 enough to prove a grade?
No. EN 18120 is a European standard series on packaging recyclability, published in April2026 in 14 parts. The referential records EN 18120 as not harmonised and as giving no presumption of conformity with Article 6 of Regulation (EU) 2025/40. Assessing a packaging unit against EN 18120 is sound engineering; it is not, today, legal proof of a grade.
A harmonised standard is a European standard whose reference the Commission has published in the Official Journal of the European Union, so that conformity with the standard gives a presumption of conformity with the requirement it covers. EN 18120 has no such status in the referential. Article 6(4) does say that the Commission adopts the delegated acts “after taking into consideration standards developed by the European standardisation organisations”, so the series is a plausible input to the criteria; an input to a future act is not a presumption under the present one. A grade assessed under EN 18120 should be labelled as such, with the part and the version.
Why can a separable component change the grade?
Because the grade is assessed per packaging unit, and a packaging unit is made of every component placed on the market with it. A metal handle on a plastic pail, a label, a closure or a coating is part of the unit that is graded. Whether that component counts as recyclable, and at which separation stage, is what the Article 6(4) criteria decide.
A customer raised the case in August 2026: a plastic pail with a metal handle, where the handle is hard for a consumer to remove by hand but is extracted easily by magnetic separation after shredding, and a label designed to be removable. The referential holds the thresholds of Table 3 and the fact that Table 4 lists parameters for the criteria; it does not hold the parameters themselves, so this article does not list them. What can be said today is that the answer depends on the stage of separation the criteria retain, and that the physical facts of the component are what the eventual criteria grade.
The PPWR applies to all packaging regardless of material, industrial and commercial B2B packaging included, under Article 2(1) of Regulation (EU) 2025/40. A drum with a steel closure and a sales carton with a plastic window raise the same question as the pail. Recording material, weight and how each component detaches is the work that keeps its value whatever the criteria say.
What changes on the day the Article 6(4) delegated act enters into force?
Three things change. The design-for-recycling criteria and the grading method become law, based on Table 3 and the parameters of Table 4 of Annex II. A 24-month clock starts, and the graded floor of Article 6(2), point (a), applies at the later of 1 January 2030 and the end of that clock. Every grade produced under a provisional method has to be re-run under the harmonised one.
The mandate is written in Article 6(4): “By 1 January 2028, the Commission shall, after taking into consideration standards developed by the European standardisation organisations, adopt delegated acts in accordance with Article 64 to supplement this Regulation by establishing: (a) design for recycling criteria and recyclability performance grades based on Table 3 of Annex II and the parameters listed in Table 4 of Annex II”. The act completes the scale; it does not create it. The letters and the percentages already exist in the regulation.
Does the PPWR modulate EPR fees by recyclability grade?
The March 2026 version of this article carried a fee table by grade and an article number. Both are withdrawn. The referential records the seat of fee modulation as a point it has not settled on the primary text, so this article names no article for it and publishes no fee band. A fee modulated by grade needs a binding grade to modulate, and the grades are not binding today.
Which grade-related dates are firm, and which are conditional?
| Provision | Status | What that means |
|---|---|---|
| Article 6(1) — all packaging placed on the market shall be recyclable | In force since 12 August 2026 | Applies now to every packaging unit, transport packaging included |
| Annex II, Table 3 — grades A, B, C at 95 / 80 / 70 % | In the regulation | Thresholds are fixed; the method that produces the percentage is not |
| Article 6(4) — design-for-recycling criteria and grading method | Delegated act due by 1 January 2028, not adopted | No harmonised grade exists until the act enters into force |
| Article 6(2), point (a) — graded floor, at least grade C | Conditional | From 1 January 2030 or 24 months after the Article 6(4) acts, whichever is the latest |
| Article 6(3), third subparagraph — at least grade B | Dated in the text | From 1 January 2038, grade C cannot be placed on the market |
| Article 6(5) — recycled at scale | Conditional | From 1 January 2035 at the earliest, subject to the Article 6(5) implementing acts |
Every line of this table was checked against a dated referential before publication. The rows marked conditional are conditional in the text of the regulation itself, not in our reading of it.
How should you record a grade today so that it survives the delegated act?
Record the method, its version, the date, the packaging unit assessed and the composition of every component, next to the grade. Conformity with Article 6 is demonstrated in the technical documentation drawn up in accordance with Annex VII, and the EU declaration of conformity follows the model of Annex VIII under Article 39. A grade with provenance can be re-run; a bare letter cannot.
Who holds the record differs along the chain; what it contains does not. A brand owner holds the component list and the grade it was given. An importer holds the same record for a unit it did not design. A converter holds the process data that explains why a label, an adhesive, an ink or a varnish behaves the way it does in a recycling stream. A distributor holds the least and is asked first. Our article on what counts as evidence in a supplier declaration sets out what each of them can reasonably ask for, and our guide to the technical documentation file shows where each element goes. Keep firm and conditional obligations in separate columns, archive a superseded grade instead of overwriting it, and write the referential’s baseline date next to every regulatory statement.
What did the verification referential decline to confirm?
Four claims in this article are backed by a recorded fact of the referential with a verbatim Official Journal quote: the application of Article 6(1) since 12 August 2026, the conditional start of the graded floor, the scope of Article 2(1), and the Annex VII and Annex VIII documentation chain. The other statements rest on the referential’s dated baseline entries, read on the primary text and recorded with their reading date.
The referential does not settle which article carries fee modulation, so none is named. It does not list the parameters of Table 4 of Annex II, so this article does not describe the criteria. It does not carry the wording of the Commission guidance of 10 June 2026 on grades, so the guidance is cited as a source and not quoted. And it returned as contradicted the one sentence most readers of the March 2026 version will remember, the unconditional 2030 floor. Where the referential says nothing, this article says nothing.
What changed in this article since March 2026?
The tense: the March text spoke of the regulation in the future, and it now applies. The 2030 floor: presented as firm, now conditional on the Article 6(4) act. Withdrawn: a fee modulation table by grade with an article number, lists of “typically grade A” formats by material, laboratory cost figures and a four-factor grade formula, because no harmonised criteria support them. Added: EN 18120, the 1 January 2028 due date of the delegated act, Key facts, question headings and the firm-versus-conditional table.
Related reading
- What applies now, and what waits on a delegated act
- PPWR deadlines: which are firm, and which wait on an act
- The Commission guidance of June 2026: what changed
- The PPWR technical documentation file
- Supplier declarations: what counts as evidence
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.