How does PPWR define recyclability for flexible food packaging?

The PPWR (EU Packaging and Packaging Waste Regulation) defines recyclability for flexible food packaging through a performance-grade system, Grades A, B, and C, based on how much of a packaging unit can be recovered as quality recyclate. Packaging that falls below the Grade C threshold is treated as non-recyclable and cannot be placed on the EU market from 2030. The rules apply equally to all packaging materials, but fibre-based formats are assessed differently from plastic flexible packaging, creating important strategic distinctions for food manufacturers. The sections below address the key questions procurement managers and sustainability directors are asking right now.

Which packaging formats does PPWR classify as recyclable?

Under the PPWR, a packaging format is recyclable if it achieves Grade A, B, or C in the regulation’s performance-grade system. Grade A requires at least 95% recyclability by weight, Grade B at least 80%, and Grade C at least 70%. Any format that cannot meet the Grade C threshold is treated as non-recyclable and will be prohibited from the EU market from 1 January 2030.

The regulation covers all packaging regardless of material, plastic, paper and cardboard, glass, metal, and wood, and assesses recyclability per individual packaging unit, not across a product range. Formats provisionally expected to score well include clear PET bottles, natural HDPE containers, aluminum cans, glass, and uncoated kraft board. Mono-material flexible films in PE or PP are provisionally Grade B candidates where collection infrastructure exists. Coated fibre formats and beverage cartons are generally expected to land at Grade C. The most challenging formats are multi-layer flexible laminates where bonded layers cannot be separated economically; these are expected to fall below Grade C entirely.

It is important to note that no packaging can be formally graded A, B, or C yet. The detailed Design for Recycling criteria and assessment methodology must be adopted by the European Commission through delegated acts by 2028. Any grading before those acts are in force is an industry anticipation, not a legal determination. What is enforceable today, from 12 August 2026, is a general recyclability requirement assessed under the existing EN 13430 standard, a softer obligation, but now simultaneously binding across all 27 EU member states for the first time.

What criteria must flexible packaging meet to pass PPWR recyclability tests?

Flexible packaging must meet two cumulative conditions under Article 6 of the PPWR to be considered recyclable. First, it must be designed for material recycling so that the recovered material is of sufficient quality to substitute for virgin raw materials. Second, from 2035, it must also be recyclable at scale, meaning it can actually be separately collected, sorted, and recycled through existing infrastructure at sufficient EU-wide volumes.

The detailed Design for Recycling criteria are being developed through delegated acts expected by 2028. These acts will assess how well components in multi-material packaging can be separated, how efficiently sorting and recycling processes handle each format, and whether the resulting recyclate is genuinely useful as a substitute for virgin material. In April 2026, the European Committee for Standardisation published the EN 18120 series, 14 new harmonized standards covering plastic packaging recyclability, including EN 18120-13 specifically for flexible PE and PP formats. These standards are expected to inform the Commission’s delegated acts.

The 2035 “at scale” requirement adds a further layer that goes beyond design intent. A packaging format can be perfectly engineered for recyclability and still fail to comply in 2035 if the corresponding recycling stream does not exist at EU scale. This creates a meaningful distinction between theoretical recyclability and practical recovery, and it is why formats with established collection infrastructure, such as paper and cardboard, carry lower long-term regulatory risk than formats dependent on infrastructure that is still being built.

From 2038, the threshold rises further: only Grade A and Grade B packaging may be placed on the EU market. Grade C is a transitional position, not a destination. Packaging that achieves only Grade C in 2030 will become non-compliant eight years later, making early investment in higher-performing formats a sound long-term procurement decision. The PPWR’s eco-modulated EPR fee system, anticipated from around 2029, will also financially reward higher grades, meaning lower recyclability will carry a direct cost, not just a compliance risk.

How does PPWR treat fibre-based packaging differently from plastic flexible formats?

Fibre-based packaging is not subject to the PPWR’s mandatory minimum recycled content targets, which apply only to plastic packaging. Paper, cardboard, and moulded fibre formats are exempt from post-consumer recycled content quotas, though they must still meet recyclability requirements and material minimization standards. This is a material regulatory advantage over plastic flexible formats, which face both recyclability and recycled content obligations from 2030.

A critical threshold determines how composite packaging, formats that combine fibre with a plastic layer, is assessed. If the plastic content of a fibre-based composite is 5% or less by mass, the packaging is assessed as paper and board, not as plastic packaging. If the plastic content exceeds 5%, the format is treated as a fibre-based composite material, a more complex regulatory category. This threshold also determines whether a format is subject to the single-use plastic bans applying from 2030 under Annex V of the PPWR; composite packaging with plastic content at or below 5% is exempt from those bans.

For food manufacturers evaluating fibre-based tray formats, this 5% threshold is strategically significant. Jospak® carton trays, for example, are designed with the thinnest possible plastic film liner to enable gas-tight MAP sealing while keeping the fibre content dominant. The tray reduces plastic use by at least 85% compared to equivalent all-plastic packaging, and it can be recycled alongside other cardboard packaging in established collection systems across markets including Germany, Sweden, Finland, and Poland. A cardboard tray that sorts with paper and board in existing infrastructure carries a fundamentally different recyclability profile from a multi-layer plastic laminate that has no established recycling stream at EU scale.

Plastic coatings on fibre-based packaging do present a technical challenge: if the plastic layer disrupts the paper recycling process, it reduces fibre quality and yield. The 4evergreen alliance’s Recyclability Evaluation Protocol provides an industry-standard method for assessing fibre-based packaging recyclability ahead of the official PPWR delegated acts, and it specifically addresses how plastic components interact with fibre recovery processes. Formats where the film can be separated from the board, either mechanically during sorting or by the consumer before disposal, perform better under these assessments than inseparable laminates.

When does PPWR’s recyclability mandate come into force for food packaging?

The PPWR’s recyclability obligations apply in phases, not all at once. A general recyclability requirement under Article 6(1) has been enforceable across all EU member states since 12 August 2026, assessed under the existing EN 13430 standard. The more demanding Design for Recycling grade system, requiring Grade A, B, or C, applies from 1 January 2030, subject to the delegated acts being adopted by 2028.

The key dates food packaging decision-makers need to plan around are:

• 12 August 2026: General recyclability requirement enforceable under EN 13430; PFAS concentration limits for food-contact packaging apply; EU Declaration of Conformity required for each packaging type; EPR registration with national schemes required.
• By 2028: European Commission must adopt delegated acts setting Design for Recycling criteria and recyclability performance grades by packaging category.
• 1 January 2030: All packaging on the EU market must achieve Grade A, B, or C. Packaging below Grade C cannot be placed on the market. Minimum recycled content targets for plastic food-contact packaging also begin. Single-use plastic bans under Annex V take effect.
• 1 January 2035: Packaging must be recyclable at scale, actually collected, sorted, and recycled through installed infrastructure at sufficient EU-wide volumes, not just designed for recyclability in principle.
• 1 January 2038: Only Grade A and Grade B packaging may be placed on the EU market. Grade C is eliminated as a permissible grade.

The regulation is a directly binding EU regulation, not a directive, meaning it applies in all 27 member states without national transposition and with no grace period for new stock placed on the market after the relevant dates. As the August 2026 application date makes clear, the compliance clock has already started. For food manufacturers sourcing packaging today, the practical implication is straightforward: formats that rely on recycling infrastructure that does not yet exist at EU scale, or that are likely to score below Grade C under the 2028 criteria, carry compounding regulatory and financial risk through 2030, 2035, and 2038. Fibre-dominant composite formats with minimal plastic content and established cardboard recycling pathways are structurally better positioned for each of those milestones.