CEN & PPWR: the EU rulebook

CEN, the European Committee for Standardization, develops the technical standards that underpin EU packaging legislation. For recyclability, the relevant work is led by CEN/TC 261 SC 4 Packaging and the Environment, with material-specific drafting handled by working groups including WG 3 (Material recovery) and WG 10 (Design for Recycling - Plastics). The current generation of standards in force is the EN 13430 family, against which the RecyClass, CERTIFY and RECY:CHECK methodologies are aligned. As of August 2026, companies are, as per the PPWR, only allowed to place recyclable packaging on the EU market: for now assessed under the PPWD framework, and from 2030 onwards according to the delegated acts (expected in 2028).

A new generation, the EN 18120 series, is intended to provide the technical basis for the ruleset of the Packaging and Packaging Waste Regulation (PPWR). Several parts of the series are currently in the standard 18 - 24 month CEN revision cycle, with the European Commission's Joint Research Centre (JRC) working in parallel on recyclability performance grades and thresholds.

Because the CEN drafting work was driven primarily by brand owners and packaging producers, with limited input from the recycling industry, the standards are expected to evolve further before they are finalised and integrated in the PPWR.

Packaging and Packaging Waste Regulation (PPWR)

The PPWR is the EU regulation that replaces the Packaging and Packaging Waste Directive and sets legally binding requirements for the design, recyclability and recycled content of packaging placed on the European market. Recyclability grades (A, B, C and non-recyclable), Design for Recycling criteria and performance thresholds will be defined in delegated and implementing acts that draw on the CEN standards described above. The detailed technical framework is not expected to be finalised before 1 January 2028.

In the interim, the certification schemes audited and operated by CIRCPACK provide the most direct way to anticipate the future regulatory environment. RecyClass, CERTIFY and RECY:CHECK are built on the EN 13430 logic, apply stricter protocols on several indicators, and produce a recyclability class on the A-C scale that is expected to map onto the PPWR grading system.

On that basis, an assessment today supports three practical conclusions for a packaging portfolio:

• Packaging that scores A, B or C is very likely to remain compliant under the PPWR.
• Packaging that scores below C, or close to thresholds in the current CEN drafts, is potentially at risk and is a candidate for design review.
• Packaging that fails the strict protocols, or is rated non-recyclable under the CEN drafts, is very likely at risk and should be redesigned before the regulation enters into force.

We can run the assessment, map your portfolio against these three categories, and identify the design changes that deliver the largest reduction in regulatory risk.

What this means for brand owners now.

The CEN standards that will determine how a packaging format is graded under PPWR Article 6 are not yet finalised for most materials. Brand owners cannot wait for the full body of standards to be published before beginning portfolio decisions: the lead time between a design change and the 2030 placing-on-market test is shorter than the time the standards process is still likely to take for some material categories.

CIRCPACK grades packaging today against the working CEN texts and the established protocols those texts build on: RecyClass for plastics, CERTIFY for glass, metals, paper and cardboard, RECY:CHECK for food and beverage cartons. Where the underlying standard shifts during 2027 or 2028, the affected formats are revalidated against the updated text. The cost of acting now against a working protocol is substantially below the cost of holding portfolio decisions until the full standards body is finalised.