How do I determine whether my packaging qualifies as recyclable under PPWR?

Regulation (EU) 2025/40 (PPWR) classifies packaging into four recyclability grades since 12 August 2026 onwards: A (highly recyclable), B (recyclable), C (recyclable with limitations), and D (not recyclable). Grade D is generally prohibited for new packaging; grades A and B are subject to labelling obligations and future levy advantages.

Classification is carried out by recognised conformity assessment bodies. The leading ones are:

- RecyClass (plastic packaging, pan-European system): Your supplier or you as the entity placing goods on the market apply for a RecyClass assessment, which is based on the sorting and recycling infrastructure of the respective countries. - CEPI (paper and cardboard packaging): Certification scheme for fibre-based packaging. - National systems: Existing systems such as the German minimum-standard procedure of the Zentrale Stelle Verpackungsregister (ZSVR) may be recognised as equivalent under PPWR as long as the European Commission has not yet adopted uniform criteria by means of an implementing act.

What your supplier must demonstrate: a valid conformity certificate issued by an accredited body, the material composition (including additives, dyes, and coatings), as well as information on closures and labels — as these are fully taken into account in the assessment.

If you are acting as your own importer or first importer: where no supplier evidence exists, the burden of proof rests with you. Technical documentation in accordance with Annex VII of the PPWR is mandatory in this case.

For a binding assessment of your specific packaging type, please contact your local Chamber of Commerce and Industry (IHK) or a specialist packaging law consultant.