A recyclability grade under PPWR is not a label for the marketing team. It is the number that decides whether a pack can be sold in the EU from 2030 and how much extended-producer-responsibility fee it carries every year until then. The PPWR recyclability assessment under Article 6 requires each packaging to be assessed against design-for-recycling criteria and expressed in the performance grades A, B or C. Under Regulation (EU) 2025/40, that grade has teeth: from 1 January 2030 only packaging graded A, B or C may be placed on the market at all, and the grade already shapes the fee a producer pays.

Article 6(3) sets the scale: recyclability is expressed in the performance grades A, B or C, as described in Table 3 of Annex II. Annex II also carries the categorical worst-of rule, under which the least recyclable component sets the classification for a multi-material pack. Article 38 and Annex VII are a different job — the conformity assessment procedure and the technical documentation in which the result is recorded. This guide stays on what the grade obliges and what it costs you, in market access and in fees. The design-for-recycling criteria behind each band are still being completed by implementing acts; the grades, the thresholds and the dates below are not.

In this guide:

What the recyclability assessment requires of every packaging
The A, B and C performance grades and what each band means
Annex II Table 3 for the grade, Annex VII for the conformity file
The 2030 market-access gate
How grades drive EPR fees through eco-modulation
6-entry FAQ covering grades, thresholds, timing, and methodology

What the Recyclability Assessment Requires

PPWR Article 6 requires each packaging to undergo a recyclability assessment against design-for-recycling criteria, and Article 6(3) requires the result to be expressed in the performance grades A, B or C described in Table 3 of Annex II. From 1 January 2030 only packaging graded A, B or C may be placed on the EU market, and the grade also influences extended-producer-responsibility fees.

The assessment is carried out per packaging type, against the design-for-recycling criteria the regulation sets, and the result is documented in the technical file that supports the Declaration of Conformity. It is not a one-time marketing exercise but a standing classification: the grade follows the packaging and is the basis on which both market access and fees are decided. A producer who cannot state a defensible grade for a pack cannot show it is compliant.

The A, B and C Performance Grades

How a PPWR recyclability grade maps to EPR fee level and 2030 market access — Each grade carries two consequences: a fee level and, from 2030, market access.

There are three grades, and Annex II Table 3 sets each one by recyclability performance: A from 95%, B from 80%, C from 70%. Below 70% the packaging is technically non-recyclable — not a fourth grade but the absence of one. The grades are a performance class rather than a simple pass or fail: a pack sits in a band, and the band determines the consequences. A higher band means lower fees; falling below grade C means, from 1 January 2030, being shut out of the market altogether.

The grade is built on the design-for-recycling criteria set out under Article 6: how well the packaging can actually be collected, sorted, and reprocessed at scale. Design choices that frustrate sorting or reprocessing, such as incompatible material combinations or problematic additives, push a pack down the grade scale. The grade is, in effect, a score for how recyclable the design really is in the systems that exist.

Annex II vs Annex VII

Difference between the Annex II worst-of methodology that sets the A, B or C grade and the Annex VII technical documentation that evidences it — Two methodologies behind one grade: categorical worst-of and quantitative grading.

Two methodologies feed the grade, and it helps to keep them distinct. Annex II applies a categorical worst-of rule: in a multi-material pack, the least recyclable component can set the classification for the whole, which is why a single problematic layer drags an otherwise recyclable pack down. The Annex II worst-of methodology guide works through the edge cases where this bites.

Annex VII is not where the grade comes from. It is the technical documentation annex that Article 38, the conformity assessment procedure, cross-references: the file in which the assessment and its result are recorded and kept available to authorities. The grade itself comes from Article 6(3) and Table 3 of Annex II. Keeping the two apart matters in practice, because the question "what grade is this pack" and the question "can I produce the file that proves it" fail in different ways and are fixed by different teams.

The 2030 Market-Access Gate

The most material consequence of the grade is not the fee, it is market access. From 1 January 2030, only packaging graded A, B or C may be placed on the EU market: a pack that falls below grade C is a pack the producer can no longer sell. From 1 January 2038 the gate rises again to grades A or B only, so a pack that clears the first gate at grade C does not clear the second.

Both thresholds are set in the regulation itself, which makes them the two firmest dates in packaging design: grade C by 1 January 2030, grade B by 1 January 2038. What the implementing acts are still completing is the design-for-recycling detail that decides which band a given construction lands in. Any pack sitting at or near a threshold is therefore a commercial risk with a fixed deadline, and the lead time to redesign packaging and re-qualify suppliers is measured in years, not months. That is why recyclability grading is a board-level issue and not a back-office one.

How Grades Drive EPR Fees

Before and alongside the market gate, the grade works through money. Extended-producer-responsibility schemes increasingly apply eco-modulation: better-graded packaging pays lower EPR fees, worse-graded packaging pays more. The grade therefore becomes a recurring annual cost signal rather than a one-off classification. Two packs with the same function but different grades carry different fees for every unit placed on the market, year after year.

This makes the grade a live financial variable, not just a compliance attribute. A redesign that moves a high-volume pack up a grade can pay for itself through reduced fees well before the 2030 gate arrives, which is why grading and cost modelling belong in the same conversation. The fee link is also why national scheme detail matters: the modulation is applied through the EPR schemes in each market, so the same grade can carry different fee impacts across countries.

What to Do Now

The work is per-SKU and prioritised by risk. Assess each SKU's grade against the design-for-recycling criteria, identify the lines sitting near or below the 2030 threshold, and prioritise redesign where a grade crosses that gate, because those are the packs that become unsellable rather than merely expensive. High-volume packs near a threshold are the obvious first targets, since they carry both the largest fee exposure and the largest market risk.

Frequently Asked Questions

What is the PPWR recyclability assessment?

It is the Article 6 obligation to assess each packaging against design-for-recycling criteria and express the result in the grades A, B or C set out in Table 3 of Annex II. The assessment is documented in the technical file through the Article 38 conformity assessment procedure, and the grade determines both market access from 1 January 2030 and the EPR fee the packaging carries.

What are the PPWR recyclability grades?

There are three: A from 95% recyclability performance, B from 80%, C from 70%, as set out in Table 3 of Annex II. Below 70% the packaging is technically non-recyclable rather than carrying a lower grade. The band a pack sits in determines its fee level and, from 1 January 2030, whether it can be placed on the market at all.

What happens if my packaging grades below the threshold?

Packaging below grade C pays higher EPR fees today and, from 1 January 2030, may not be placed on the EU market at all. From 1 January 2038 the same is true of grade C itself. A pack at or near a threshold is a commercial risk with a fixed deadline, not a documentation problem.

When does the PPWR recyclability requirement start?

The assessment obligation applies with the regulation. The market-access consequence takes effect on 1 January 2030, when only grades A, B and C may be placed on the market, and tightens again on 1 January 2038, when only A and B may. Both dates are in the regulation; what the delegated acts still complete is the design-for-recycling detail behind each band.

How does the recyclability grade affect EPR fees?

Through eco-modulation: extended-producer-responsibility schemes charge lower fees for better-graded packaging and higher fees for worse-graded packaging. The grade becomes a recurring annual cost, so improving a high-volume pack's grade can reduce fees every year it is on the market.

What is the difference between Annex II and Annex VII?

Annex II carries both the grades themselves (Table 3: A, B, C) and the categorical worst-of rule, under which the least recyclable component sets the classification for a multi-material pack. Annex VII is the technical documentation annex referenced by the Article 38 conformity assessment procedure — the file that records and evidences the result. Annex II decides the grade; Annex VII is where you prove it.

Conclusion

Article 6 turns recyclability into a graded number with two consequences: an annual EPR fee and, from 1 January 2030, market access. The grade comes from the design-for-recycling criteria through Table 3 of Annex II and its worst-of rule, and is evidenced through the Article 38 conformity assessment and the Annex VII technical file. It is the number that decides whether a pack stays sellable.

For a producer, the move is to grade every SKU, find the lines near the 2030 threshold, and redesign those first, because they carry both the highest fees and the real market risk. Done early, grading is a cost-optimisation lever; done late, it is a market-access emergency.

Carbonorm keeps the composition and component evidence for every SKU in one portfolio, so you can see which packs are close to a threshold before the deadline forces the question. Start Audit and see which of your packs face the 2030 gate.