Design for Recycling at PPWR – how to design packaging that complies with the law?

Design for Recycling (PPWR) means designing packaging in such a way that, after use, it can be collected, sorted and recycled in a manner that yields secondary raw materials of the appropriate quality. Under PPWR, a general statement that packaging is „recyclable” is not sufficient. From 2030, recyclability will be assessed according to classes A, B or C, and packaging with a recyclability rating below 70% will be considered technically non-recyclable and its placing on the market will be restricted. Annex II of the PPWR specifies that Class A denotes a recyclability rate of at least 95%, Class B at least 80%, and Class C at least 70%.

For businesses, this means a change in the way packaging is designed. It is not only the main material that will matter, but also the label, adhesive, closure, colourant, coating, varnish, print, product residues and the ability to separate the components. Packaging compliant with the PPWR must be designed not just for the moment of sale, but for its entire life cycle: use, emptying, separation, sorting and recycling.

What is Design for Recycling at PPWR?

‘Design for Recycling’ – that is, designing packaging with recycling in mind – is an approach in which design decisions are made with the end of the packaging’s life in mind. Packaging is intended to fulfil protective, logistical, informational and marketing functions, but it must not hinder collection, sorting or recycling.

The PPWR states that packaging will be considered recyclable if it is designed for material recycling and the resulting secondary raw material is of sufficient quality to replace virgin raw material. From 2035, an additional condition will be the ability to collect, sort and recycle on a large scale, in accordance with EU methodology.

Design for Recycling is not about choosing a „more environmentally friendly” material. It is about designing the entire packaging unit in such a way that it does not hinder effective recycling.

This means that paper packaging with a coating that is difficult to separate may be less suitable than simple plastic packaging designed as a single material stream. Similarly, a PET bottle may lose some of its recyclability due to a full sleeve, unsuitable adhesive, dark dye or a label that interferes with sorting.

Why is PPWR changing its approach to recyclability?

Until now, many companies have used the term „recyclable” rather loosely. Packaging could be described as recyclable if its main material was, in theory, recyclable. The PPWR introduces a more formal approach: it is not only the material that counts, but also the actual possibility of recycling the entire package.

The European Commission states that by 2030, all packaging must be recyclable and designed in such a way that its components can be reused as valuable materials rather than being incinerated or sent to landfill.

For businesses, this means that recyclability is becoming a criterion for legal compliance. It will no longer be merely a selling point or a component of an ESG report.

Recyclability classes in PPWR: A, B and C

The PPWR is introducing recyclability performance grades. These are intended to assess how well a given packaging unit meets the criteria for design for recycling.

Recyclability class	Recyclability level	Practical significance
Class A	≥ 95%	Top-of-the-range; packaging very well designed for recycling
Class B	≥ 80%	Regulatory compliance will remain assured even after 2038.
Class C	≥ 70%	The minimum acceptable level from 2030, but insufficient from 2038.
Below 70%	< 70%	Packaging that is technically non-recyclable

From 2030, packaging will have to be classified as Class A, B or C in order to be placed on the market. From 2038, Class C will no longer be sufficient — only Class A or B packaging will be permitted.

The safest design strategy is not to aim for Class C. Companies should design packaging to meet at least Class B standards, as Class C will no longer be sufficient from 2038 onwards.

‘Design for Recycling’ from 2030 and ‘recycled at scale’ from 2035.

There are two stages in the assessment of recyclability within the PPWR.

The first stage is Design for Recycling. From 2030, packaging will be assessed in terms of its design: materials, components, sortability, recyclability and the quality of the secondary raw material. This assessment determines „whether the packaging has been designed in such a way that it can be recycled”.

The second stage is ‘recycled at scale’. From 2035, the assessment will include a criterion to determine whether packaging is actually recycled on a large scale. The PPWR states that, from 2035, the assessment will take into account the amount of material actually recycled in each packaging category, in accordance with the methodology set out in the implementing acts.

This distinction is very important. Packaging may be well designed in theory, but if, in practice, there is no effective collection, sorting or recycling system in place for that particular category, its status after 2035 could be problematic.

When will the European Commission clarify the criteria?

The PPWR provides that, by 1 January 2028, the European Commission is to adopt delegated acts establishing ‘Design for Recycling’ criteria and recyclability classes for packaging categories. The criteria are to take into account, amongst other things, the predominant material, the ability to separate into material streams, sorting, the quality of secondary raw materials, recycling technologies and substances of concern.

However, companies should not wait until 2028 to take their first steps. Annex II of the PPWR already sets out the parameters that will be taken into account when establishing design-for-recycling criteria. This provides a sufficient basis for commencing an audit of current packaging and identifying risks.

Which packaging components affect recyclability?

The PPWR sets out in Annex II a non-exhaustive list of parameters that will be used in developing the Design for Recycling criteria. These include, amongst other things, the separability of components, the efficiency of sorting and recycling, the development of sorting technologies, and the retention of functionality in recycled materials.

Labels

A label can improve the information provided on the packaging, but it can also make sorting and recycling more difficult. Its surface area, material, adhesive and whether it can be separated from the body of the packaging are all important factors.

A full sleeve on a PET bottle can make it difficult to identify the material at the sorting facility, particularly if it covers a large part of the packaging or is made of a different material to the body of the bottle. In design for recycling, the label is not merely a graphic element. It is a component that influences the recyclability rating.

Adhesives and adhesive bonds

Adhesives may be neutral in terms of recycling, or they may contaminate the recycling stream. The PPWR points out that adhesive residues can reduce the quality of recyclable materials, whilst washable adhesives can help to separate the label or component from the main body of the packaging.

For businesses, this means they need to liaise not only with the packaging manufacturer, but also with the supplier of labels, adhesives and ancillary materials.

Colours and dyes

Heavily coloured materials can make sorting more difficult and reduce the quality of the recycled product. This applies in particular to dark plastics, heavily coloured paper and materials which, once processed, reduce the value of the recycled material.

From a design perspective, the safest materials are usually natural, transparent or easy to identify within the sorting system. This does not mean that colour is prohibited, but it does mean that its impact on recycling must be assessed.

Material composition

The PPWR states that preference is given to single-material products or combinations of materials that allow for easy separation and a high recovery rate of secondary raw materials.

Multi-material packaging may be functional, but it is often more difficult to recycle. If a company uses laminates, coatings, windows, multi-layer trays or packaging that combines paper, plastic and metal, it should carry out a detailed assessment. A good starting point is an analysis multi-material packaging, as these are the ones that most often highlight the conflict between protective function and recyclability.

Barriers and coatings

Barriers protect the product from moisture, oxygen, grease, light or loss of flavour. The problem arises when the coating prevents the material from being separated effectively or reduces the quality of the recycled material.

Example: Paper packaging with a barrier layer that is difficult to separate may look environmentally friendly, but in practice it may end up in a lower-value recycling stream. In Design for Recycling, it is not the appearance of the material that counts, but how it behaves in the actual recycling process.

Prints, varnishes and paints

Printing is important for branding, product identification and compliance with information requirements. However, it can affect sorting, the cleanliness of the recycling stream and the quality of the recycled material. The PPWR points out that inks and varnishes containing problematic substances can hinder recycling, and the release of inks can contaminate the recycling stream.

From PPWR’s perspective, marketing cannot design packaging in isolation from recycling considerations. Graphics, colour schemes and finishes should be assessed alongside the material.

Latches and small components

Caps, lids, valves, seals, membranes, tags and small safety components can affect sorting, separation and recycling. Small components can also get lost during the sorting process.

Good eco-design means that components are compatible in terms of materials, can be separated, or are designed so as not to interfere with the processing of the main material.

Product residue and ease of emptying

The packaging should be easy to empty. Product residues can make sorting more difficult, cause contamination and reduce the quality of recycling. PPWR points out that the packaging design should allow the contents to be emptied easily, and that the packaging should be completely empty when disposed of.

This is particularly important for cosmetics, household cleaning products, viscous products, semi-liquid foods and products in tubes.

How do you design packaging that complies with the PPWR?

Design in accordance with the PPWR should begin with the predominant material and the packaging unit as a whole. It is not enough to assess the body of the packaging. Every component that ends up in the waste stream must be taken into account.

1. Determine the predominant material

The PPWR provides that the ‘Design for Recycling’ criteria will be established on the basis of the predominant material and the packaging category. Annex II lists categories including, amongst others, glass, paper and cardboard, metal, PET, PE, PP, PS, EPS, other plastics, wood, textiles and ceramics.

Example: for a PET bottle, the main material stream will be PET, but the label, adhesive, cap and colouring agent may lower the rating of the entire unit.

2. Limit the number of materials

The more materials there are, the greater the risk of problems with sorting and recycling. Single-material products are not always feasible, but they should be the benchmark.

A good design question is: is every material in the packaging essential, or does it merely enhance the appearance, the premium feel or the convenience of production?

3. Design components as a system

The body, label, closure, adhesive and print should all be designed together. A fault in any one component may lower the grade of the entire package.

Example: a bottle may be made from recyclable PET, but a full PVC sleeve or unsuitable adhesive can impair sorting and the quality of the recycled material.

4. Check that the data can be sorted

The packaging must be identified and directed to the correct waste stream. The colour, shape, size, material, label and any elements that visually interfere with identification are all important factors.

Very small packaging, heavily coloured plastics, labels covering the entire sleeve and unusual combinations of materials may require further analysis.

5. Assess the quality of the recyclable material

The PPWR assumes that recycling should result in secondary raw materials of sufficient quality to replace virgin materials. It is therefore not merely a matter of „processing waste”, but of preserving the value of the material.

If the recycling process results in a low-quality material that is contaminated, difficult to reuse, or suitable only for low-value applications, the packaging may receive a lower rating.

6. Avoid problematic substances

Problematic substances may hinder reuse and recycling. The PPWR provides that the criteria will be able to identify undesirable substances and limit their presence in packaging or components if they have a negative impact on circularity.

For companies, this means they need to work with suppliers of paints, varnishes, adhesives, barrier coatings and processing aids.

7. Document the assessment

Design for Recycling requires data. A company should have material documentation, component specifications, data from suppliers, an assessment of recyclability and a justification for the chosen design solutions.

This is where it comes in handy PPWR audit, which enables packaging to be assessed in terms of its design, composition, recyclability, labelling and compliance with environmental and legal requirements.

Recyclability criteria – a practical checklist

Companies can start with a simple checklist. Whilst this will not replace the final methodology set out in the delegated acts, it does allow high-risk packaging to be identified at this stage.

Design for Recycling Checklist

Is the packaging made from a single predominant material?
Can the components be easily separated by hand or at a processing plant?
Doesn’t the label cover too much of the packaging?
Is the label material compatible with the main recycling stream?
Is the adhesive washable or suitable for recycling?
Does the packaging contain any dark or problematic colourings?
Are coatings and barriers necessary, and are they compatible with recycling?
Do the prints and varnishes contain any substances that make recycling difficult?
Don’t the fasteners and small components get lost during the sorting process?
Is it easy to empty the product from the packaging?
Does the recycled material obtained have any real practical value?
Does the company have documentation confirming the assessment?

If there are negative responses to several points, the packaging should be reviewed before placing the next order or redesigning it.

Example: a compliant and a problematic PET bottle

A PET bottle can serve as a good example of the difference between a claim and genuine ‘Design for Recycling’.

A problematic option:

– dark or opaque PET,
– a full-sleeve design covering the body,
– a label made of a material that is incompatible with the PET stream,
– adhesive that is difficult to remove,
– a coloured cap made of a different material, without an assessment of compatibility,
– prints and coatings that make recycling more difficult.

The better design option:

– transparent or easily sortable PET,
– limited label space,
– labels and adhesive selected to suit the recycling process,
– a closure compatible with the processing system,
– no unnecessary embellishments,
– documentation from component suppliers.

Key takeaway: Packaging made from the same primary material may receive different ratings if the components and the way they are assembled differ.

Example: paper packaging with a barrier layer

Paper packaging is often automatically assumed to be better for the environment. At PPWR, such a simplification is risky.

A paper box with a grease-proof coating, a plastic window, a high-gloss varnish and a durable adhesive may be difficult to recycle. If the layers cannot be separated and the coatings contaminate the paper stream, the packaging may receive a lower rating than a simpler single-material alternative.

That is why eco-design is not simply a matter of replacing plastic with paper. It involves designing packaging to suit the actual recycling stream.

Design for Recycling and multi-material packaging

Multi-material packaging is one of the most challenging areas of PPWR. It often combines high functionality with low separability. It protects the product, extends its shelf life, provides barrier properties and enhances its appearance, but can make recycling more difficult.

Not every multi-material package will automatically be non-compliant. The risk increases when:

– the materials are permanently bonded,
– separation is not possible for the user or the sorting plant,
– laminate does not have a stable recycling stream,
– the barrier reduces the quality of the recyclable material,
– the proportion of problematic components is high,
– The packaging requires a special processing route, which does not exist in practice.

Companies using such solutions should carry out a technical assessment multi-material packaging and check whether there is a simpler alternative material.

Design for Recycling and e-commerce

In e-commerce, ‘Design for Recycling’ applies not only to product packaging but also to shipping packaging. Cardboard, tape, labels, plastic film, packing material and returnable packaging together form a system that should be easy to sort and recycle.

The most common problems in e-commerce are:

– boxes that are too big,
– an excess of fillers,
– a combination of several materials in a single parcel,
– tapes and labels that are difficult to separate,
– plastic envelopes with additional labels and printing,
– no information is available on the weight and material of the packaging.

Online shops should combine design for recycling with an analysis of empty space and packaging requirements. A good starting point is e-commerce audit and analysis Packaging in e-commerce: BDO and LUCID, particularly when selling abroad.

Design for Recycling and recycled content

Recyclability and recycled content are two different PPWR requirements. The first refers to whether packaging can be effectively recycled after use. The second refers to the proportion of recycled material contained in new packaging.

Packaging may contain recycled material but still be difficult to recycle. It may also be well designed for recycling but fail to meet the required PCR content for plastic packaging.

Therefore, design in accordance with PPWR should combine:

– Design for Recycling,
– recycled content,
– minimising weight and volume,
– reducing the use of problematic substances,
– correct signage,
– technical documentation,
– the responsibilities of BDO, EPR and foreign systems.

It is worth combining the broader material context with this approach circular economy, because PPWR requires packaging to be designed with its entire life cycle in mind, rather than just the purchase of the material.

How can a company prepare to meet the ‘Design for Recycling’ criteria?

The best preparation starts with a review of the packaging portfolio. The company should identify which formats are critical to sales, which have high volumes, which involve multiple materials, and which can be easily redesigned.

1. Create a packaging map

The list should include unit packaging, bulk packaging, transport packaging and e-commerce packaging. For each type of packaging, data should be collected on the material, weight, components, suppliers, sales market and function.

2. Assign the PPWR category

The packaging must be assigned to one of the categories listed in Annex II: glass, paper, metal, PET, PE, PP, films, EPS, other plastics, wood, textiles or other. This is the starting point for further assessment.

3. Assess the problematic components

The greatest attention must be paid to labels, adhesives, sleeves, dyes, coatings, laminates, closures and product residues.

4. Specify the target class

It is not worth designing packaging to meet only the minimum 70% standard. A safer target is Class B, and in some categories Class A, if this is technically and economically feasible.

5. Set out the requirements for suppliers

Procurement specifications should include requirements relating to materials, dyes, adhesives, labels, coatings, recycled content, separability and documentation.

6. Test the project before implementation

A change in packaging may affect product protection, shelf life, appearance, logistics and customer complaints. Tests should cover both the functionality of the packaging and its recyclability.

7. Document your decisions

A company should have a design justification, material documentation and data from suppliers. A lack of documentation can be just as problematic as a poor packaging design.

In practice, it’s worth combining PPWR audit z environmental audit, in order to assess not only the packaging design, but also the consistency of the company’s documentation, responsibilities and processes.

Who within the company should be responsible for Design for Recycling?

Design for Recycling is not the responsibility of a single department. It requires collaboration across several areas of the company.

R&D and the technology department are responsible for the design and functionality of the packaging. The procurement team negotiates materials and suppliers. Quality assesses product safety. Marketing designs the graphics and environmental communications. Logistics checks transport arrangements and durability. Compliance analyses legal requirements. Finance assesses costs and the impact on charges. The management board should approve the strategic direction.

The greatest risk arises when the marketing department designs the packaging, the procurement team chooses the cheapest material, and the compliance team only finds out about the decision after production has been approved.

If a company does not have an in-house environmental team, a good solution is comprehensive environmental consulting for companies, including an analysis of regulations, packaging, documentation and risks.

The most common mistakes in the design of recyclable packaging

The first mistake is to assess only the main material. In PPWR, the entire packaging unit counts – including the label, adhesive, closure, colourant and coating.

The second mistake is switching from plastic to paper without assessing its recyclability. Paper with a barrier layer or laminate can be problematic.

The third mistake is designing for Class C. From 2038, Class C will no longer be sufficient to place packaging on the market.

The fourth error is the lack of data from suppliers. A declaration that „the packaging is recyclable”, without any specifications or evidence, does not constitute a sound basis for compliance.

The fifth mistake is to ignore the actual recycling infrastructure. From 2035 onwards, what will matter is not only whether packaging can be recycled, but whether it is actually being recycled on a large scale.

FAQ - Frequently asked questions

What does ‘Design for Recycling’ mean at PPWR?

At PPWR, ‘Design for Recycling’ means designing packaging so that, after use, it can be collected, sorted and recycled, and so that the resulting recycled material is of a quality sufficient to replace virgin material.

What recyclability categories does the PPWR provide for?

The PPWR specifies classes A, B and C. Class A denotes a recyclability rate of at least 95%, class B at least 80%, and class C at least 70%. Packaging with a recyclability rate below 70% will be treated as technically non-recyclable.

Since when has packaging had to be designed for recycling?

From 2030, packaging will have to meet the ‘Design for Recycling’ criteria, and from 2035, the requirement for large-scale recycling will be added to the assessment. The PPWR also stipulates that, from 2038, only Class A or B packaging will be permitted.

Is paper packaging always better than plastic packaging?

No. Paper packaging with a coating, laminate, varnish or a plastic window may be difficult to recycle. PPWR assesses the actual recyclability of the entire packaging unit, rather than the appearance of the material itself.

What is the main factor that reduces the recyclability of packaging?

The most common issues include permanent bonds between different materials, full sleeves, unsuitable adhesives, dark dyes, difficult-to-handle coatings, problematic substances, small components that get lost during sorting, and product residues.

How do you go about redesigning packaging to comply with the PPWR?

It is best to start with a packaging audit: identify the main material, components, PPWR category, current recyclability risks and the target class. Next, draw up requirements for suppliers and test new solutions.

Redesign your packaging with the experts

At PPWR, ‘Design for Recycling’ transforms packaging design from a marketing exercise into a matter of legal, technical and environmental compliance. Packaging must protect the product, whilst at the same time enabling it to be sorted, recycled and turned into high-quality secondary raw materials.

If you wish to redesign your packaging in accordance with the PPWR, please use PPWR audit or select Eko-Pro technical and environmental consultancy. You can also go to the tab Contact Eko-Pro and describe the current packaging, materials and planned design changes.