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 can be required as a DPP data field under ESPR, product group by product group.
PPWR recyclability grades
The PPWR (Regulation (EU) 2025/40) introduces a formal EU recyclability grading system for packaging:
| Grade | Meaning |
|---|---|
| A | Design-for-recycling assessment of at least 95% per packaging unit |
| B | At least 80% |
| C | At least 70% |
There is no grade below C. Packaging that scores under 70% counts as technically non-recyclable (Annex II, Table 3). From 2035 a recycled-at-scale assessment is added to the design-for-recycling assessment.
Regulatory thresholds:
- From 1 January 2030, or 24 months after the design-for-recycling delegated acts enter into force if that is later: only grades A, B, or C may be placed on the market (Article 6(3)). Minimum recycled content for the plastic part of packaging applies from 1 January 2030, or 3 years after the related implementing act enters into force if that is later (Article 7(1))
- From 1 January 2035, or later for the recycled-at-scale requirement: packaging must also be recycled at scale, not just technically recyclable (Article 6(2))
- From 1 January 2038: Only grades A and B permitted
This grading creates a direct design incentive: once the 2030 rule applies, packaging that scores below grade C cannot be placed on the market.
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 is not a list of minimum DPP fields. Each delegated act selects the data for its product group's DPP from the elements Annex III lists (Article 9(2)(a)). Those elements include information on the product's performance against the Annex I parameters, which cover design for recycling and the ease and quality of recycling. Any recyclability data a product group's DPP must hold is set in its delegated act.
For packaged products, PPWR Article 12(5) requires a single data carrier for the product information and the packaging information where Union law requires product information through a data carrier. The PPWR recitals add that where the product needs a DPP under ESPR, that DPP should also carry the relevant packaging information.
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