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Article 6 of the Packaging and Packaging Waste Regulation introduces a binding A/B/C recyclability classification for every packaging unit placed on the EU market from 2030. The calculation methodology behind the grade will be harmonised across the EU-27, but the work to define it is still in progress at CEN. What remains at Member State discretion is the layer of bonuses and penalties that each EPR scheme attaches on top of the grade, where national variation will persist into the enforcement window.
Article 6 of the Packaging and Packaging Waste Regulation introduces a recyclability classification that assigns every packaging unit a grade of A, B or C. The grade reflects the share of the packaging that is recyclable in practice against four pillars: design for recycling, separate collection, available sorting infrastructure, and reprocessing capacity at scale. The classification becomes binding from 2030 for the placing-on-market test.
From 2035, the recyclability requirement tightens further: a packaging unit is only treated as recyclable if it is recycled at scale across the Union, evidenced through measurable collection, sorting and reprocessing volumes rather than design specification alone. The 2035 threshold is the regulation's mechanism for ensuring that grade A and B classifications correspond to material that actually re-enters the value chain, not material that is theoretically recyclable in laboratory conditions.
From 2028, two years ahead of the placing-on-market test, Member State EPR schemes must eco-modulate their fees against the grade. Grade A pays the lowest tier of the base fee, grade B pays the base fee, and grade C, where exemptions allow it to remain on the market, carries a malus. This makes the grade an immediate cost item from 2028, well before the 2030 sales restriction takes effect.
Four stages from packaging specification to a signed Article 6 grading report. Most engagements complete within four to eight weeks per format.
Full material composition, geometry, label, closure and decoration. CIRCPACK confirms the scope and the test protocol applicable to the format.
Industrial sorting tests on Material Recovery Facility lines, near-infrared recognition tests, wash tests and pulping tests appropriate to the material. Auditors collect the data on the floor.
The test results are translated into the A/B/C class with a written rationale tied to the specific design features driving the score.
A signed grading report defensible against an Article 6 reviewer, together with the design levers needed to move the format up a class on the next revision.
For brand owners, producers and retailers preparing their portfolios for the 2028 eco-modulation window and the 2030 placing-on-market test.
A defensible A/B/C grade for each format in the portfolio, in time for the 2028 eco-modulation milestone and the 2030 placing-on-market test.
Position formats as class A or class B early, retaining shelf space with brand-owner customers ahead of the 2028 fee window.
Audit private-label packaging ahead of Article 6 enforcement and align supplier specifications with the grading evidence base.
Send us your packaging spec and we'll come back within 48 hours with a scoped quote and timeline.
A RecyClass certificate maps directly to A/B/C for plastic packaging. PPWR recyclability grading extends the same protocol to glass, metals, paper, cardboard and beverage cartons via the CERTIFY and RECY:CHECK schemes, so a multi-material portfolio receives a single, consistent A/B/C answer across formats.
Eco-modulation under Article 6 begins phasing in from 2028. The class C placing-on-market restriction takes effect from 2030. Brand owners typically run grading programmes during 2026 and 2027 to inform design decisions and to have certificates in hand for the first EPR submissions under the new fee schedule.
Two years from issue, provided the packaging specification does not materially change. CIRCPACK revalidates after any change to material, geometry or decoration: the grade is tied to the specification on file.
The calculation methodology itself will be the same. PPWR harmonises the methodology that produces the A/B/C grade, and the underlying work is in progress at the European Committee for Standardisation (CEN). As of 2026 only the plastics norms have reached a working conclusion; the paper and cardboard working groups have recently concluded their positions; other materials remain in earlier stages of the process. What stays at Member State level is the layer of additional bonuses and penalties that each local EPR scheme attaches on top of the grade. A pack that qualifies for a fee reduction at ten percent post-consumer recycled content in one Member State may require thirty percent post-consumer recycled content to qualify for an equivalent reduction in another.