Recyclability
Definition
Recyclability is the measurable capacity of a product or material to be collected from consumers or industry, sorted by material type, and reprocessed into secondary raw materials that can substitute for virgin materials. In EU law, recyclability is not a binary yes/no — it is a graded performance characteristic formally defined for packaging under the Packaging and Packaging Waste Regulation (PPWR) and increasingly required as a DPP data field under ESPR.
PPWR recyclability grades
The PPWR (Regulation (EU) 2025/40) introduces a formal EU recyclability grading system for packaging:
| Grade | Meaning | |-------|---------| | A | Recyclable at scale with high material recovery | | B | Recyclable with moderate material recovery | | C | Recyclable but with limitations (material loss, limited infrastructure) | | D | Not recyclable under current conditions |
Regulatory thresholds:
- From January 2030: Only grades A, B, or C may be marketed; minimum recycled content thresholds for plastic packaging apply
- From January 2035: Recyclability must be demonstrated at scale (not just technically possible)
- From January 2038: Only grades A and B permitted
This grading creates a direct design incentive — products rated D become legally unsellable as packaging from 2030 onwards.
How recyclability is assessed
Recyclability is not determined by the producer alone. EU recyclability assessments consider the full system:
- Design for recycling — material composition, colour, presence of additives, multi-material combinations, adhesives, labels
- Collection infrastructure — whether the material is actually collected by EU member state systems
- Sorting technology — whether sorting facilities can identify and separate the material
- Recycling process — whether reprocessing technology exists to achieve meaningful material recovery
- Output quality — whether the recycled material can be used as a secondary raw material
A product may be technically recyclable but practically non-recyclable if collection or sorting infrastructure does not exist at scale.
Recyclability in DPP
ESPR Annex III includes recyclability as a minimum DPP data field. Specific DPP data requirements per product category (recyclability percentage, grade, sorting instructions) will be defined in delegated acts. For packaging subject to both PPWR and ESPR DPPs, the same DPP must carry PPWR recyclability grade data — no separate packaging DPP is required.
Related terms
- Digital Product Passport (DPP) — where recyclability data is disclosed
- Extended Producer Responsibility (EPR) — fees modulated on recyclability grades
- Ecodesign — design approach that maximises recyclability from the start
- Circular Economy — the economic model recyclability enables