Recyclability certification – a new requirement under the PPWR

The PPWR recycling certificate is a colloquial term for the documents that companies will need to hold in order to demonstrate that their packaging is suitable for recycling. In practice, the PPWR does not constitute a single, simple document called a „recycling certificate”. Instead, it introduces an obligation to assess the packaging’s compliance, prepare technical documentation and issue a declaration of conformity. From 2030, packaging will have to meet recyclability criteria, and its class will be designated as A, B or C; packaging with a recyclability rating below 70% will be treated as technically non-recyclable. Industry sources analysing Annex II of the PPWR indicate the following thresholds: Class A from 95%, Class B from 80%, Class C from 70%, and below 70%, technically unsuitable for recycling. (clarity.eco)

For businesses, the most important thing is that the statement „this packaging is recyclable” will no longer be sufficient. Companies will have to provide data on the material, components, weight, recyclability, recycled content, labelling and suppliers. An external certification body can assist with the assessment, but responsibility for the packaging’s compliance still lies with the relevant economic operator.

Is PPWR really introducing a recycling certificate?

The PPWR does not use a simple model: one item of packaging, one mandatory recycling certificate issued by the authority. The mechanism is more complex. The Regulation introduces a conformity assessment, technical documentation and a declaration of conformity, which are intended to confirm that the packaging meets the requirements of the PPWR.

In its draft guidelines of 2026, the European Commission states that the conformity assessment procedure may be carried out by the manufacturer or by another body acting on their behalf, such as a laboratory or a certification body. At the same time, the declaration of conformity must be drawn up by the manufacturer or its authorised representative, and the manufacturer remains the party bearing legal responsibility for the conformity of the packaging. (environment.ec.europa.eu)

In practice, the „PPWR recycling certificate” will most often refer to a set of supporting documents: a recyclability assessment, technical documentation, data from suppliers and a declaration of conformity, rather than a single, universal document.

This is an important distinction. A company may use a certification body or a laboratory, but it cannot shift all responsibility onto an external consultant. An external assessment is intended to help demonstrate compliance, but it does not replace the company’s own packaging management process.

What is a recyclability assessment?

An assessment of recyclability involves analysing whether, after use, packaging can be effectively collected, sorted and subjected to material recycling in a way that yields secondary raw materials of an appropriate quality.

It is not just about the main material. The entire packaging unit is assessed, which also includes:

– labels,
– adhesives,
– closures,
– coatings,
– laminates,
– colourings,
– prints,
– safety features,
– product residues,
– the ability to separate the components.

The European Commission emphasises that one of the main objectives of the PPWR is to ensure that all packaging on the EU market is recyclable in an economically viable manner by 2030 (environment.ec.europa.eu)

Recyclability does not mean that the packaging can, in theory, be put in a yellow, blue or green bin. It means that its design and material make it possible to produce a useful secondary raw material.

Packaging recyclability classes – A, B and C

The PPWR sets out recyclability performance grades. These are intended to indicate what proportion of the packaging, calculated by weight, is suitable for recycling in accordance with the design-for-recycling criteria.

Recyclability class	Recyclability level	Practical significance
Class A	at least 95%	top-of-the-range; packaging best designed for recycling
Class B	at least 80%	a safe design level, particularly with a view to 2038.
Class C	at least 70%	the minimum acceptable level in the first stage
Below 70%	below 70%	packaging that is not technically recyclable

Studies on PPWR indicate that, from 2030, Class C will be the minimum compliance threshold, whilst from 2038 onwards, only Class A or B packaging will be permitted. (clarity.eco)

Companies should not design packaging that is „on the borderline” of Class C. Class B is a safer business objective, as it offers greater resilience to any future tightening of requirements.

What about the A–E classification?

In some market materials, you may come across grades A–E. This approach is sometimes used in consultancy tools or working systems to illustrate a broader spectrum of risk: from packaging that is very well designed for recycling to packaging that is entirely problematic.

In the current PPWR, however, the most important categories are formally Classes A, B and C, and the threshold below 70%, at which packaging is treated as technically non-recyclable. Legal and industry sources describing the PPWR specifically refer to classes A, B and C in the context of Annex II and Article 6. (khlaw.com)

Therefore, in practical business communication, the extended A–E model may be used as a tool for internal prioritisation, but compliance documentation should refer to the official requirements of the PPWR and the final implementing acts.

Who will issue the certificate or assessment of recyclability?

It depends on what we mean by „certificate”. Under the PPWR, the declaration of conformity and the technical documentation are of key importance. The packaging manufacturer or the relevant entity responsible for the packaging must carry out a conformity assessment or have one carried out. They then draw up a declaration of conformity.

The European Commission states that the conformity assessment may be carried out by the manufacturer or by a third party acting on their behalf, such as a laboratory or a certification body. However, the declaration of conformity remains a document drawn up by the manufacturer or an authorised representative, who bears responsibility for the conformity of the packaging. (environment.ec.europa.eu)

In practice, the following may take part in the process:

– packaging manufacturer,
– a supplier of packaging materials,
– importer,
– brand owner,
– a research laboratory,
– a certification body,
– technical adviser,
– an industry organisation or a recyclability assessment scheme,
– the company’s quality and compliance department.

An external certificate may enhance the credibility of the documentation, but it does not exempt a company from having its own process for checking packaging and data from suppliers.

Declaration of conformity versus recycling certificate – how do they differ?

A declaration of conformity is a formal statement by the manufacturer that the packaging in question meets the requirements of the PPWR. In accordance with the guidance on Article 39 and Annex VIII of the PPWR, the declaration of conformity is a written statement by the manufacturer, and the technical documentation serves as the evidence supporting that declaration. (tanso.de)

An external certificate, on the other hand, is a document issued by an independent body which may confirm a specific aspect, such as an assessment of recyclability, material compliance, the result of a laboratory test, the content of recycled material, or compliance with a specific methodology.

Document	Who prepares it?	Function
Technical documentation	manufacturer / responsible company, based on suppliers’ data	a body of evidence demonstrating compliance
Declaration of Conformity	manufacturer or authorised representative	a formal declaration of conformity of the packaging with the PPWR
External certificate	laboratory, certification body, certification scheme	independent verification of a selected characteristic or assessment
PPWR Audit Report	technical adviser / auditor	assessment of risks and gaps, and action plan

Conclusion: a certificate may form part of the documentation, but it does not replace the entire compliance pathway.

When do companies need to prepare the documents?

The PPWR came into force on 11 February 2025 and, in principle, will apply from 12 August 2026. The European Commission confirms these dates in its explanatory documents on the implementation of the Regulation. (environment.ec.europa.eu)

From 12 August 2026, the importance of declarations of conformity and technical documentation will increase, whilst the full criteria for recyclability and the A/B/C classes will be linked to the implementation phases of Design for Recycling. The European Commission states that detailed criteria for assessing recyclability are to be adopted in delegated acts by 1 January 2028, and that from 2030 all packaging must be designed with recycling in mind. (measurlabs.com)

For businesses, this means two parallel paths:

– 2026: prepare documentation, data from suppliers and the declaration of conformity process,
– 2030: ensure that packaging meets the required recyclability standard.

What data will be required to assess recyclability?

An assessment of recyclability requires technical data. A general declaration from the supplier to the effect that „the material is recyclable” is not sufficient.

The company should collect at least:

– a description of the packaging and its intended use,
– main material,
– the weight of the entire packaging unit,
– the mass of the individual components,
– type of plastic or material,
– the composition of labels, closures, adhesives, coatings and barriers,
– information on substances of concern,
– information on the recycled content,
– the results of tests or assessments of recyclability,
– information on whether the components can be separated,
– an assessment of sortability,
– labelling information,
– suppliers’ declarations,
– integration with sales markets and ERP systems.

Studies on PPWR documentation indicate that the technical documentation for packaging should include, amongst other things, a description of the packaging, the materials and design, evidence of compliance with substance restrictions, an assessment of recyclability, information on the recycled content, and measures to minimise packaging. (bpc.works)

What does the certification or assessment process look like in practice?

It is worth dividing the process into several stages. This ensures that the company does not treat certification as a one-off document, but as part of its packaging management system.

1. Packaging inventory

The first step is to draw up a list of all packaging types: unit, bulk, transport, dispatch and promotional. You need to assign suppliers, materials, weights and sales markets to each of them.

2. Classification by PPWR category

Packaging must be assigned to the appropriate material and functional categories. A PET bottle is assessed differently from barrier-coated paper packaging, which in turn is assessed differently from multi-material packaging.

3. Identification of problematic components

The most common sources of risk are labels, adhesives, laminates, coatings, dark dyes, full sleeves, small components and product residues.

4. Assessment of recyclability

At this stage, it is determined what proportion of the packaging is actually suitable for recycling and which category it can be assigned to.

5. Supplementing the technical documentation

The company collects specifications, suppliers’ declarations, test reports, material data and design justifications.

6. Issuing a declaration of conformity

Once the evidence has been gathered, the manufacturer or the relevant body draws up a declaration of conformity. This is a formal document which should be supported by technical documentation.

7. Update following a change of supplier or project

A certificate, report or declaration should not be regarded as a document that is valid „forever”. A change in the material, label, adhesive, colourant or supplier may require a reassessment.

Certification bodies – when are they needed?

An external certification body will be particularly useful where a company uses high-risk packaging or requires independent verification for a B2B client, retail chain, marketplace or regulatory body.

This applies in particular to:

– multi-material packaging,
– plastic packaging,
– packaging that comes into contact with food,
– packaging made from recycled material,
– packaging with barriers and coatings,
– packaging exported to many EU markets,
– products sold to large retail chains,
– packaging bearing environmental declarations.

Various assessment and certification schemes operate in Poland and the EU, including sector-specific schemes relating to the recyclability of plastics or paper. One example is certification under schemes such as RecyClass, which is used to assess the recyclability of plastic packaging; some certification bodies are already promoting such services in the context of the PPWR. (src.org.pl)

At the same time, it is important to bear in mind that the final PPWR criteria will be set out in delegated and implementing acts. Therefore, a company should choose methodologies that can be linked to the PPWR requirements, rather than simply relying on a marketing claim that a product is „recyclable”.

Classes D and E as an internal risk map

Although the formal PPWR uses the A/B/C thresholds and a limit below 70%, companies may use the extended A–E scale for internal risk assessment. This model is practical because it allows packaging that is only marginally problematic to be distinguished from that which requires urgent redesign.

An example of a working interpretation:

The working class	Operational significance
A	packaging designed very well with recycling in mind
B	safe packaging, but one that requires monitoring
C	minimum compliance level, risks after 2038.
D	packaging below the PPWR threshold, requiring a redesign
E	a high-risk package, which is unlikely to be sustainable in its current form

Such a breakdown can help the management board and operational departments to set priorities. However, compliance documentation should refer to the official PPWR classes and thresholds.

Multi-material packaging and certification of recyclability

Multi-material packaging will be one of the most challenging categories. It often combines paper, plastics, aluminium, adhesives, coatings and barrier layers. Such solutions protect the product, but may reduce its recyclability rating.

The risk increases when:

– the materials are permanently bonded,
– the consumer cannot separate the components,
– the sorting plant does not recognise the predominant material,
– the adhesive contaminates the recycling stream,
– the coating reduces the quality of the recyclable material,
– the packaging does not have a stable recycling route,
– the supplier is unable to provide the specifications.

Companies implementing such solutions should carry out a detailed analysis multi-material packaging and check whether the current design stands a chance of achieving Class A or B.

Recycling certification versus marketing claims

A recyclability certificate or assessment report should not be treated as a tool for arbitrary marketing communications. If a company wishes to state on its packaging that a product is „suitable for recycling”, „recyclable” or „designed for recycling”, it should have documentation to substantiate the scope of such a claim.

The following passwords are particularly risky:

– „100% recyclable”, if this does not apply to the entire unit,
– „eco”, unless it refers to a specific feature,
– „green packaging”, if there is no evidence,
– „recycled”, unless the proportion of recycled material is specified,
– „for sorting”, if the instructions do not correspond to the contents,
– „biodegradable”, if there is no confirmed recycling route.

The more specific a company’s environmental statement is, the stronger the evidence it should have.

Recyclability certification and BDO, EPR and sales in the EU

Assessing recyclability does not happen in a vacuum. In Poland, it must be linked to the BDO, data on packaging weight, reporting and fees. When selling abroad, EPR schemes such as LUCID in Germany also come into play.

The company should check whether the data used to assess recyclability is consistent with:

– the packaging label,
– BDO,
– supplier documentation,
– a declaration of conformity,
– signage,
– EPR reporting,
– documentation for retail chains,
– the marketplace’s requirements.

In this area, it is worth combining PPWR audit z environmental audit and compliance with packaging obligations in EU markets.

How can you prepare your company for certification or a suitability assessment?

Preparations should not begin with the choice of a certification body. First, you need to organise your internal data.

1. Create a packaging label

Each package should have its own data sheet detailing the material, weight, components, supplier, function and sales market.

2. Collect the documents from your suppliers

Suppliers should provide specifications, material declarations, and information on recycled content, substances of concern and recyclability.

3. Identify high-risk packaging

Start by analysing high-volume products, plastics, laminates, export packaging and solutions with environmental declarations.

4. Carry out a recyclability assessment

The assessment should indicate whether the packaging can be classified as Class A, B or C, and which factors lower the score.

5. Plan the redesign

If the packaging is below 70% or close to the Class C threshold, a design change plan must be drawn up.

6. Prepare the compliance documentation

Reports, certificates, supplier declarations and test results should be included in the technical documentation for the packaging.

7. Establish an update procedure

Any change to the supplier, material, adhesive, label or grammage should automatically trigger a review of the documentation.

If a company does not have an in-house technical or environmental team, a practical solution is comprehensive environmental consulting for companies, which enables the integration of PPWR, documentation, BDO, EPR and supplier requirements.

The most common mistakes made by companies

The first mistake is to treat the certificate as an end in itself. The aim is to ensure that the packaging and documentation are in order, and the certificate can only be one piece of evidence of this.

The second mistake is to assess only the main material. The label, adhesive, closure or coating may lower the grade of the entire packaging unit.

The third mistake is relying on a general statement from the supplier. The phrase „this material is recyclable” is no substitute for technical data.

The fourth error is the lack of a link to BDO and EPR. The data used for certification should be consistent with environmental reporting.

The fifth mistake is designing for Class C. From 2038 onwards, Class C may not be sufficient, so Class B is a safer target.

The sixth mistake is using the A–E classes in documentation without checking whether they comply with the official PPWR requirements. The A–E scale may be useful internally, but compliance documents should be based on the regulations.

FAQ - Frequently asked questions

Does PPWR require a recycling certificate?

The PPWR requires proof that packaging complies with the regulations, including recyclability requirements. In practice, this means technical documentation, a conformity assessment and a declaration of conformity. An external certificate may serve as supporting evidence, but it does not replace the entire documentation.

Who issues the certificate of recyclability?

The assessment may be carried out by the manufacturer, a laboratory, a certification body or a certification scheme acting on behalf of the manufacturer. The declaration of conformity is drawn up by the manufacturer or an authorised representative, and the manufacturer bears legal responsibility for the conformity of the packaging. (environment.ec.europa.eu)

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% is considered technically non-recyclable. (clarity.eco)

Are Classes D and E officially recognised by the PPWR?

Not as a primary formal table of recyclability classes. In the current PPWR, the key classifications are A/B/C and the threshold below 70%. The designations D/E may appear in market tools as an internal risk scale, but compliance documentation should refer to the official requirements.

Is the certificate sufficient to ensure that the packaging complies with the requirements?

Not always. A certificate may confirm a specific characteristic, such as recyclability, but the company must still hold full technical documentation, data from suppliers, a declaration of conformity and ensure compliance with the PPWR requirements.

How do you start preparing for recyclability certification?

It is best to start with a packaging audit: gather data on materials, weights, components, suppliers and sales markets. Next, assess recyclability, identify high-risk packaging and prepare technical documentation.

Get expert support to help you prepare for the PPWR

Recyclability certification will not simply be a formal addition to the packaging. It is part of a comprehensive compliance system: packaging design, technical documentation, data from suppliers, recyclability assessment, declaration of conformity, BDO and EPR.

If you wish to prepare your packaging for assessment of its recyclability and compliance with PPWR requirements, please use PPWR audit or select Eko-Pro technical and environmental consultancy. You can also go to the tab Contact Eko-Pro and describe your packaging, materials and current level of documentation.