Article 6 reframes packaging compliance around a single number: the recyclability grade. Where the old PPWD asked “is this recyclable in principle?”, PPWR asks “at what grade, in this market, with the current sorting infrastructure?” The answer must be computed per packaging type, declared in the Declaration of Conformity, and re-issued whenever the specification changes.
| Grade | Performance | Market consequence |
|---|---|---|
| A | Excellent — ≥ 95% recyclability score under Annex II criteria | Lowest EPR fee; preferred status from 2030. |
| B | Good — 80–95% recyclability score | Standard EPR fee. |
| C | Sufficient — 70–80% recyclability score | EPR fee modulation (surcharge) from 2027. |
| D | Limited — 50–70% recyclability score | Significant EPR surcharge; placeable on the market until 2030. |
| E | Not recyclable — below 50% or fails a binary criterion |
The grade is not an average. Annex II of PPWR defines a worst-of approach: every component of a packaging item — primary substrate, adhesive, ink, coating, closure, label, sleeve — is graded independently, and the worst component sets the overall grade.
Each component is assessed against the criteria of the recognised materia-knowledge body for its material family:
| Material family | Criteria source | Typical grade-A path |
|---|---|---|
| Plastic (PET, HDPE, PP, LDPE, PS) | RecyClass design-for-recycling guidelines | Mono-material, transparent or natural colour, no carbon-black ink, water-soluble or low-tack adhesive, < 5% mass of label. |
| Paper & cardboard | Cepi Recyclability Laboratory Test Method v2 | Single fibre stream, no aluminium lamination > 5%, water-resistant coating ≤ 5%, no PFAS. |
| Corrugated board | FEFCO Industry Recyclability Statement | Single corrugated grade, water-soluble glue, ink limited to declared list. |
| Metal (aluminium, tinplate) | Metal Packaging Europe — recyclability of metal packaging | Magnetic separation possible (tinplate) or eddy-current separable (aluminium), coating < specified limit. |
| Glass | FEVE recyclability assessment | Single colour stream, no ceramic, no heavy metal closure if not removed at consumer stage. |
For composites and multilayer packaging, the dominant material defines the assessment stream, and the non-dominant layers are evaluated as contaminants. A paper-based pouch with a 5 µm aluminium oxide barrier is graded in the paper stream, with the aluminium layer assessed against the “maximum non-paper component” threshold from Cepi.
From 1 January 2035, grade A requires not only excellent Design for Recycling but also that the packaging is “recycled at scale” in the relevant member state — Article 6(6). This is a bar that depends on the sorting and recycling infrastructure in each market, not on the design alone.
Aluminium beverage cans, PET bottles, and corrugated transport packaging will likely meet both bars in most EU markets. Many multilayer consumer flexibles will meet the design bar but fail the 2035 at-scale bar in markets without dedicated sortation.
For a typical 400-SKU portfolio across DACH, a workable approach:
→ Carbonorm runs the Annex II worst-of calculation on every SKU in your portfolio against the live RecyClass / Cepi / FEFCO criteria, surfaces the limiting component on each SKU, and tells you the cheapest substitution path to climb a grade.