PPWR Recyclability Grades: How A, B, and C Are Assigned and What They Mean
Under the EU Packaging and Packaging Waste Regulation, every packaging unit will be graded A, B, or C for recyclability. Here is how the grading system works and what each grade means for your ability to sell into the EU.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
April 22, 20269 min read
What the grading system is
The EU Packaging and Packaging Waste Regulation (PPWR) introduces a recyclability performance grade for every packaging unit placed on the EU market. Each unit will be assigned one of three grades, A, B, or C, based on how recyclable it is at scale in the EU.
The grade is not cosmetic. It controls whether the packaging can legally be sold in the EU, and, in combination with eco-modulation, how much the producer pays in EPR fees per unit.
How grades are assigned
The grade is assigned based on the packaging's recyclability performance against criteria that the European Commission is finalizing through delegated and implementing acts. The criteria assess factors including:
- Whether the packaging is designed for recycling under the recognized design-for-recycling rules for its material category.
- Whether the packaging is collected and sorted at scale in the EU's recycling infrastructure.
- Whether the packaging is recycled at scalemeaning material is actually reprocessed into secondary raw material in commercial volumes, not just sent to a sorting facility.
A packaging unit must perform well on all three dimensions to receive a high grade. A package that is theoretically recyclable but is not collected, sorted, or reprocessed at scale will not earn an A.
Final percentage thresholds for A, B, and C are set in the PPWR implementing acts.
What each grade means
Grade A, High recyclability. The package meets the highest threshold across design, collection, sorting, and recycling at scale. Grade A units pay the lowest eco-modulated EPR fees and have the most secure path to remaining on the EU market through the PPWR's phase-in.
Grade B, Medium recyclability. The package meets a baseline of recyclability but does not reach the top tier. Grade B units pay higher EPR fees than A and may face additional design requirements over time.
Grade C, Low recyclability. The package falls below the medium threshold. Grade C units pay the highest fees and, after a defined phase-in date, may be prohibited from the EU market entirely. The PPWR's design is to push C-grade packaging out of the market over time.
Exact phase-in dates by which C-grade packaging may be prohibited are set in the implementing acts.
Why the grade can change without you changing the package
The grade is not just a property of the package, it is a property of the package against the recycling infrastructure of the moment. A package that is Grade B in 2026 because no plant in the EU recycles its material at scale can become Grade A later if recycling capacity is built. The reverse is also true: a package that loses an end market can drop a grade.
Producers should expect their grades to be re-evaluated periodically as the European Commission updates the assessment data.
What this means operationally
For each SKU sold into the EU, you need to know:
- The material category and format of the packaging unit.
- The current grade assignment under the active assessment criteria.
- The fee differential between the current grade and the next grade up, to know whether redesign pays back.
- The phase-in date by which a low grade becomes a market-access problem, not just a fee problem.
This is a per-SKU question, not a brand-level question. Different SKUs from the same brand may receive different grades depending on closures, labels, sleeves, and color systems.
What to do in 2026
- Build a per-SKU grade record. Tag every EU SKU with its expected grade and the assumptions behind it.
- Identify your Grade C exposure. Those are the SKUs at risk of market exclusion, not just higher fees.
- Pressure-test "minor" design choices. A dark-pigmented PET bottle, a full-sleeve label, or a multilayer film can drop a grade.
- Track infrastructure announcements. New chemical recycling plants, new sortation lines, and new end markets can move grades up.
How Packgine helps
Packgine maintains a per-SKU recyclability assessment against current PPWR criteria, flags Grade C exposure, and models the fee impact of design changes before you commit. When the European Commission updates assessment criteria, Packgine reruns your portfolio so you know which SKUs moved.
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