All topics

Topic

Design for recycling

All packaging must be recyclable: designed for material recycling into usable secondary raw materials, and separately collected, sorted and recycled at scale. Recyclability is expressed as performance grades A, B and C, set by Commission delegated acts due by 1 January 2028. From 1 January 2030 packaging must reach at least grade C; from 1 January 2035 it must also meet the recycled-at-scale condition; from 1 January 2038 only grades A and B are sufficient. Where design-for-recycling criteria are later updated, packaging has three years from the new act to comply.

What you must do

  • Assess each packaging item against the design-for-recycling criteria for its material.
  • Redesign or replace items that would fall below grade C by 2030 — and below grade B by 2038.
  • Keep the assessment evidence in the technical documentation (Annex VII).

Dates that apply

  • 1 January 2030Design-for-recycling grade required
  • 1 January 2035Recycled at scale requirement
  • 1 January 2038Only grades A and B accepted

Source: Article 6 (recyclable packaging); grades and criteria in Annex II.