PPWR Insights 1 - What do the new recyclability requirements mean for your business?
The Packaging and Packaging Waste Regulation (PPWR) introduces strict new recyclability requirements for all packaging placed on the EU market. In this blog, we will take a closer look at these requirements, how and when they will be defined, and how they will affect packaging design.
When is packaging considered recyclable?
From 2030 onwards, all packaging must be designed for recycling, ensuring it can be processed into secondary raw materials of sufficient quality to replace virgin materials.
Packaging is considered recyclable when it:
- is designed for recycling and meets certain quality standards.
- meets recyclability grades A, B or C, which will become more stringent over time. From 2038 onwards, only levels A and B will be permitted.
- can be collected separately, sorted efficiently and recycled at scale (from 2035 onwards).
- meets performance grades (A, B or C) for recyclability, which will become stricter over time (from 2038, only grades A and B will be allowed).
By 2028, the European Commission is to develop detailed and standardised criteria for the recyclability of packaging. Each type of packaging will be assigned a score based on these criteria. The criteria are still under development and are being further discussed in separate working groups (see box).
Exemptions and financial incentives
Certain packaging types, including packaging for medicines and baby food, are temporarily exempt. Innovative packaging solutions that do not yet meet the new recyclability criteria may be placed on the market for a maximum of five years, provided there is a clear roadmap to full compliance.
As of 2030, Extended Producer Responsibility (currently Green Dot) fees will be adjusted according to each packaging item’s recyclability score. This means that producers will pay higher fees for hard-to-recycle packaging and reduced fees for materials with superior recyclability.
What does "recycled at scale" mean?
By 2030, the EU is to introduce a methodology to assess whether packaging is actually recycled at scale. This will be based on the effective recycling rates for each packaging material, monitored using a transparent tracking system. The PPWR introduces a phased approach: the design-for-recycling criteria reflect theoretical technical recyclability, while the “recycled-at-scale” criteria ensure that materials are actually sufficiently recycled in practice across the European Union. The deadline for this has been set at 2035.
However, it remains unclear whether a material group that is not widely recycled by 2035 will be banned from the market – as a strict interpretation of the text suggests – or whether it will simply receive a lower recyclability score.
What are the next steps?
The recyclability criteria for each material are currently being developed within CEN (European Committee for Standardisation). Expert working groups, of which Fost Plus is a member, are drawing up so-called traffic light tables to assess the recyclability of each material type. The system classifies packaging into the following categories:
- Green – Encouraged packaging
- Yellow – Tolerated but not ideal
- Red – Banned from the market
The assessment considers, among other factors, how packaging components behave in sorting facilities. For example, a polystyrene yoghurt pot is assessed together with its sealing film and wrapper, as these typically end up together in sorting centres. Components are assessed separately only if, in more than 80% of cases, they are removed by consumers before sorting.
Fost Plus is closely following developments in two specific working groups: WG10, which defines the criteria for plastic packaging recyclability, and WG3, which does the same for materials such as paper/cardboard, glass, aluminium and metal.
In April 2026, CEN published the 14 new standards for the recyclability of plastic packaging (EN18120). For other materials, such as paper-board, glass, aluminium and steel, the publication of the standards is expected in the second half of 2026.
It is expected that the updated standards will be published during 2028. Based on these standards, it will then be assessed whether a packaging may still be placed on the European market in 2030 and which recyclability grade it falls into – and therefore which tariff will need to be paid.
What can you do right now?
The 2030 deadline may seem far away, but it is approaching quickly when taking into account the development cycles of packaging and packaged products. The answer to the question of whether you should wait until all final recyclability criteria have been published before taking action is no. At this point in time, there is already sufficient convergence between the various reference frameworks on recyclable packaging to act with confidence.
To help companies make design decisions today for plastic packaging that complies with the PPWR, Fost Plus and Valipac, in collaboration with Verpact (Netherlands), Citeo (France), Green Dot Norway and NPA Sweden, have developed the No Regrets Playbook for plastic packaging. This Playbook is based on a thorough comparison of existing guidelines on the recyclability of plastics and the published European standards for plastic packaging. The result is a set of solid, widely supported design choices that are already applicable today — with concrete examples of well-designed packaging as well as packaging to be avoided.
As a company, you can already take stock of your entire packaging portfolio and list the exact composition of each packaging item. This information can be checked against the No Regrets Playbook to verify whether your packaging contains any elements that will no longer be permitted in the future.
How does Fost Plus support you?
Would you like to deepen your knowledge of packaging recyclability in the context of the PPWR? We offer you an overview of relevant information and tools.
- PPWR dossier page: here we bring together the most recent insights, developments and explanations regarding the regulations.
- Sustainable packaging page
- Design4Recycling guidelines: practical recommendations to improve the recyclability of packaging in accordance with Belgian collection, sorting and recycling processes.
- No Regrets Playbook (plastics): concrete design choices that are already applicable today and aligned with European guidelines.
- Q&A on recyclability: answers to frequently asked questions, compiled with experts from Belgium and abroad.
- European standards (CEN): technical specifications for recyclability are available through the Belgian Bureau for Standardisation.