PPWR Article 6 requires all packaging sold in the EU to be recyclable. From 2030 at the earliest, every pack needs a recyclability grade of A, B or C, and from 2038 grade C is no longer allowed.
The duty already applies, but the grading system behind it is still being written. Below is what recyclable means under Article 6, how the grades work, which dates apply and what you should do while the rules are missing.
Article 6 has applied since 12 August 2026, but the grades do not apply yet. Until they do, the old Packaging Directive test decides whether a pack counts as recyclable.
PPWR Article 6 at a glance
Article 6 of Regulation (EU) 2025/40 is the recyclability rule in PPWR, and the table below sums it up.
| Question | Answer |
|---|---|
| What it requires | All packaging placed on the EU market must be recyclable |
| Who it hits | The manufacturer, with checks by importers and distributors |
| Applies since | 12 August 2026, with the grades from 1 January 2030 at the earliest |
| What is still missing | The design rules that set the grades (due by 1 January 2028) and the method for measuring recycling at scale (due by 1 January 2030), neither adopted as of October 2026 |
Article 6 sits in the group of packaging rules in Articles 5 to 12, which the guide to the PPWR requirements maps in full.
What recyclable means under Article 6
PPWR does not leave recyclable to a company's own judgement. Article 6(2) sets two tests, and packaging only counts as recyclable when it passes both.
- Designed for recycling. The pack is made so it can go through material recycling and give back material good enough to replace new raw material. The EU calls this design for recycling, and it applies from 1 January 2030 at the earliest.
- Recycled at scale. Once thrown away, the pack can be collected separately, sorted without spoiling other waste streams and actually recycled in large volumes. This test applies from 1 January 2035 at the earliest.
PPWR defines recycled at scale at EU level, per packaging category. At least 55% of a category must be recycled each year across the EU, or 30% for wood, and a later EU act will set the exact method.
So a pack can be well designed and still fail, if the type of packaging it belongs to is not recycled in large enough volumes.
The three recyclability grades and the 70% floor
Annex II of PPWR turns the design test into a score. Each packaging unit is checked against design rules for its category, the result is weighted into a percentage, and the percentage sets the grade.
Below are the grades with the score each one needs and how long it can be sold.
| Grade | Design score | Can be sold |
|---|---|---|
| A | 95% or more | Yes, also after 2038 |
| B | 80% or more | Yes, also after 2038 |
| C | 70% or more | From 2030 until 31 December 2037 |
| Below 70% | Under 70% | No, once the grades apply, as it counts as technically non-recyclable |
From 2035 a second grade is added for recycling at scale. It is based on how much of the pack's category is actually recycled across the EU, so packaging is then judged on both its design and its category.
The grades also feed into what you pay for extended producer responsibility. Under Article 6(8), producer fees must be adjusted by grade 18 months after both EU acts are in force, so the grade will affect what each pack costs to put on the market.
Article 6 dates from 2026 to 2038
Most Article 6 dates have a "whichever is later" clause. If the EU acts arrive late, the dates move back with them.
Below are the dates in order, with what changes on each one.
| Date | What changes |
|---|---|
| 12 August 2026 | Article 6(1) applies, so all packaging must be recyclable, judged by the old Packaging Directive rules for now |
| 1 January 2028 | Legal deadline for the EU design rules and grades |
| 1 January 2030 | Grades A to C required, or 24 months after the design rules enter into force if that is later |
| 1 January 2030 | Legal deadline for the recycled-at-scale method, and the start of the innovative packaging exception |
| 18 months after both acts | Producer fees adjusted by grade |
| 1 January 2035 | Recycled-at-scale test applies, or 5 years after its method enters into force if later |
| 1 January 2038 | Only grades A and B can be placed on the market |
When the EU later updates the design rules, companies get 3 years from the update to meet them.
According to the Commission's PPWR guidance document from the European Commission of 5 June 2026, Article 6(1) has applied since 12 August 2026. Until the grades apply, manufacturers follow the old Directive 94/62/EC and its standards, such as EN 13430.
The guidance also says the formal PPWR conformity check for recyclability is not needed until the design rules enter into force.
How a whole pack gets its grade
A grade belongs to a whole packaging unit, not just its main material. Article 6(9) sets out how the parts are counted.
Below are the three rules for the parts of a pack.
- Parts that stay on are graded with the pack. An integrated component, such as a cap that stays attached, is assessed together with the main body. If such parts can come apart during transport or sorting, they are assessed on their own.
- Parts that come off are graded on their own. A separate component is one that is taken off for good and thrown away before the main body. A foil lid peeled off a yoghurt pot fits that definition.
- No part may spoil the rest. Every part must work with the collection, sorting and recycling processes that exist today, and must not make the main body harder to recycle.
Annex II also lists what the design rules will look at. Labels, sleeves, closures, glues, colours, coatings, inks, leftover product and how easily the parts come apart all count.
How much of a bottle a sleeve covers, for example, affects whether it can be sorted. The ISO 18604 guide to recyclable packaging covers how recyclability is assessed today.
Packaging that Article 6 leaves out
Article 6(11) takes some packaging out of the recyclability rule, mostly where safety comes first.
Below are the exempt types.
- Medicines. Packaging that touches a medicine, and outer packaging where it is needed to keep the medicine in good condition.
- Medical devices. Packaging that is sensitive to contact for medical devices and in vitro diagnostic devices.
- Baby food and medical food. Packaging that is sensitive to contact for infant formula, baby food and food for special medical purposes.
- Dangerous goods. Packaging used to transport dangerous goods.
- Some materials. Sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax. Producer fees for these can still be adjusted by grade.
The Commission must review these exemptions by 1 January 2035.
There is also a time-limited exception for innovative packaging, meaning packaging made from new materials that works clearly better and has a proven environmental benefit.
From 2030 it can be sold without meeting the recyclability tests for up to 5 years after the end of the year it was first placed on the market. The company must tell the national authority first and show a plan to reach recycling at scale.
Who carries Article 6 and what the declaration confirms
The manufacturer is responsible for Article 6. That is the company that makes the packaging or has it made under its own name or brand.
Below is what each role in the supply chain owes under Article 6.
- Manufacturer. Assesses the grade and records how the assessment was done in the technical documentation, the evidence file behind every pack.
- Importer. Checks that the manufacturer did the assessment and has the evidence file, before bringing the packaging into the EU.
- Distributor. Does not sell packaging it has reason to think breaks the rules.
Grading starts with knowing what every part is made of, which usually means asking suppliers. The guide on requesting packaging data from suppliers covers how to ask for it.
How Article 6 connects to the other PPWR rules
The EU's work on harmful substances under PPWR Article 5 feeds into the design rules, and reusable packaging must meet Article 6 too.
From 2030, packaging that meets the design rules must be collected for recycling rather than burned or landfilled.
What the declaration of conformity confirms
The EU declaration of conformity states that the pack meets Articles 5 to 12, Article 6 included. The guide to the EU declaration of conformity explains the document itself.
Repax Declare builds the declaration for each packaging type, with all 8 Annex VIII fields and the signature block, a QR code to the live declaration and a new version whenever the pack changes.
Try Repax Declare for free - no card required Fill in the form, sign it, and get your first declaration. Try it freeDeclare does not grade packaging or make it recyclable. Getting the design right stays the manufacturer's job under Article 15. Declare makes sure the declaration is correct, traceable and ready when an inspector asks.
New EU acts on packaging appear on the European Commission's packaging waste page, and the article text is in Regulation (EU) 2025/40 on EUR-Lex.
Frequently asked questions about PPWR Article 6
Below are the five questions packaging companies ask most often about the recyclability rules.
When does PPWR Article 6 start to apply?
The duty to be recyclable has applied since 12 August 2026. The grades A to C apply from 1 January 2030 at the earliest, recycling at scale from 1 January 2035, and only grades A and B from 1 January 2038.
Is my packaging recyclable under PPWR today?
For now, packaging counts as recyclable if it meets the old Packaging Directive rules and standards such as EN 13430. That is the Commission's reading until the PPWR grades apply, from 1 January 2030 at the earliest.
Are the PPWR design for recycling rules finalised yet?
No. As of October 2026 the Commission has not adopted the design rules, which are due by 1 January 2028. The grades apply 24 months after they enter into force, or from 1 January 2030 if that is later.
Does Article 6 change my EPR fees?
Yes, but later. Producer fees must be adjusted by recyclability grade 18 months after both EU acts behind Article 6 are in force. Until then, Article 6 sets no fee rule of its own.
What happens to packaging that scores below 70%?
It counts as technically non-recyclable and cannot be placed on the market once the grades apply. Grade C packaging, scoring 70% to 80%, can be sold until the end of 2037.
