PPWR — 100% recyclability and classes A to E

This is the central obligation of the PPWR and, paradoxically, the one whose criteria are least known to date. The principle is simple: 100% of packaging recyclable in 2030. The precise definition of what counts as recyclable, and to what level, will be set by delegated acts published in early 2028 at the earliest. That gap between publication of the criteria and the date of application is the regulation's main operational problem.

Packaging development cycles run between 18 and 36 months. With criteria published in early 2028 and application in January 2030, teams have 24 months at most. For complex projects such as multi-layer or barrier packaging, that is not enough. The only way to meet the deadline is to anticipate on the guidance available today, notably RecyClass for plastics and CEFLEX for flexibles.

The notion of recyclable at scale, which will be added in 2035, makes the reading harder still. A well-designed pack may be classed as non-recyclable if the collection infrastructure in certain Member States is insufficient to process it in practice. It is a criterion partly outside the manufacturer's control, dependent on the state of waste-management systems in 27 different countries.