PPWR 12 – What Happens to Packaging After It Becomes Waste?

“It is recyclable” does not answer the right question

A packaging supplier tells its customer:
“The packaging is recyclable.”
The customer asks:
“Where?”
The answer is:
“Technically, it can be recycled.”

But PPWR forces industry to go further. Is the packaging actually collected? Is it correctly identified and sorted? Is there sufficient industrial capacity to recycle it? Can the resulting material re-enter the economy at a relevant scale?

This is the distinction at the heart of PPWR 12:
recyclable by design
versus
recycled at scale.

From design to secondary raw material

• PPWR 04 examined whether packaging can be recycled from a technical perspective.
• PPWR 09 showed how packaging must communicate sorting information.
• PPWR 11 explained who registers, reports and finances the EPR system.
• PPWR 12 follows what happens after the packaging becomes waste:
design → market → collection → sorting → recycling → secondary raw material.

Material can be lost at every stage. That is why 100 tonnes of packaging placed on the market does not automatically mean 100 tonnes recycled.

Recyclable by design – the first stage

Article 6 introduces harmonised design-for-recycling criteria and recyclability performance grades A, B and C. From 1 January 2030, or 24 months after the entry into force of the relevant delegated acts if that date is later, packaging may no longer be placed on the market unless it achieves at least grade A, B or C.

This first stage essentially answers the question:
“Was the packaging designed so that it can be recycled?”

The detailed methodology and design-for-recycling criteria must be established through the delegated acts foreseen by the Regulation. For companies, the practical conclusion is clear: 2030 is not merely a reporting deadline. It becomes a market-access threshold for packaging that does not achieve the minimum recyclability level.

Recycled at scale – the second stage

From 2035, PPWR adds another condition. It is no longer enough for packaging to be designed correctly. It must also be capable of being:

• separately collected;
• sorted into relevant waste streams;
• actually recycled at scale.

The requirement starts to apply from 1 January 2035, or five years after the entry into force of the implementing acts establishing the methodology for recycling at scale, if that date is later.

The difference between 2030 and 2035 is therefore fundamental:
2030: was the packaging designed for recycling?
2035: is the packaging also actually recycled at scale?

2038 – the threshold becomes stricter

From 1 January 2038, Article 6 raises the minimum recyclability threshold. Packaging may no longer be placed on the market unless it falls within grade A or B.

Grade C, accepted during the previous stage, will no longer be sufficient. This is not merely a market expectation or indicative milestone, but a date explicitly set out in the Regulation.

PPWR therefore builds recyclability in stages:
2030 – A, B or C
2035 – design for recycling + recycling at scale
2038 – only A or B.

What does “at scale” actually mean?

The concept does not mean that somewhere in Europe there is a laboratory or recycler technically able to process a certain packaging format.

For recycling to count at industrial scale, there must be a real chain:
collection,
sorting,
recycling capacity,
sufficient volumes,
and outputs capable of becoming usable secondary raw material.

Packaging may become problematic if it is collected only in small quantities, if sorting systems cannot identify it reliably, if recycling technology exists but industrial capacity is too limited, or if the resulting material cannot be efficiently used as secondary raw material.

The exact methodology for assessing “recycled at scale” still has to be established through the acts foreseen by PPWR. For this reason, it is not prudent for a company today to declare definitively:
“This packaging is PPWR recyclable at scale for 2035.”

Collection is the first gate

Packaging that never enters an appropriate collection stream cannot become recycled material, no matter how well it was designed. Article 48 establishes the framework for return and collection systems, while Article 49 concerns mandatory collection.

Member States organise the overall collection architecture, while producers and producer responsibility organisations participate in financing and, depending on the national system, in operating it through the EPR mechanisms discussed in PPWR 11.

For companies, the distinction matters. A converter cannot control national collection infrastructure. But it can control whether the packaging it designs is compatible with the real infrastructure into which it will enter.

Separate collection

Separate collection aims to keep materials in sufficiently clean streams for sorting and recycling. Collection quality directly affects:

• stream purity;
• sorting yield;
• material losses;
• quality of recycled material;
• the possibility of using recyclate in higher-value applications.

In industrial terms, the issue is simple:
a well-designed material collected in a contaminated stream may lose much of its recycling value.

The 90% target – not for all packaging

PPWR does not require 90% collection of all packaging. Article 50 establishes a separate-collection target of at least 90% per year by weight, by 1 January 2029, for the relevant beverage-packaging categories.

At the centre of this requirement are:

• single-use plastic beverage bottles with a capacity of up to 3 litres;
• single-use metal beverage containers with a capacity of up to 3 litres.

The Regulation also provides exclusions for certain beverage categories, as well as conditions under which a Member State may avoid introducing a DRS if it can already demonstrate very high separate-collection performance and fulfils the conditions set by the Regulation.

The correct message is therefore:
90% is a specific target for certain beverage packaging, not a general target for all packaging.

DRS does not mean recycling

A deposit-return system can create a very valuable material stream. Packaging is returned through a controlled circuit, contamination may be lower and traceability is improved.

But: returned ≠ recycled.

After collection, the material still needs to be prepared, sorted and recycled. Only then does it become secondary raw material. DRS can solve the collection problem very effectively. It does not solve the entire recycling problem on its own.

Romania – SGR as a practical example

The Romanian deposit-return system is a very good example of the difference between collection and recycling. SGR creates controlled streams for eligible PET, metal and glass beverage packaging. This can improve the quality of material available for recycling. But SGR remains one stage of the chain. After return, the material still needs to be sorted, prepared and recycled. The existence of SGR therefore does not replace the recyclability-at-scale assessment required by PPWR.

Recycling targets – what Member States must achieve

Article 52 establishes recycling targets at Member State level. By 31 December 2025, at least 65% of all packaging waste must be recycled. The minimum material-specific targets are:

• plastic: 50%;
• wood: 25%;
• ferrous metals: 70%;
• aluminium: 50%;
• glass: 70%;
• paper and cardboard: 75%.

By 31 December 2030, the overall target rises to at least 70%. The minimum material-specific targets become:

• plastic: 55%;
• wood: 30%;
• ferrous metals: 80%;
• aluminium: 60%;
• glass: 75%;
• paper and cardboard: 85%.

These are Member State targets for the performance of the overall system. They do not mean that each individual company must personally recycle 55% of the plastic it places on the market.

National targets and market access are not the same thing

This is one of the most important distinctions in PPWR 12. A national recycling target answers:
“How much must a Member State's system recycle?”

A packaging recyclability requirement answers:
“Can this specific packaging continue to be placed on the EU market?”

The first is a performance obligation for the national system. The second becomes a conformity requirement for the packaging itself. Confusing the two can lead to poor technical and commercial decisions.

Sorting – the link between collection and recycling

Packaging that has been collected may still be lost during sorting. This is where apparently small design decisions have a real impact:

• material colour;
• sleeves and labels;
• adhesives;
• multilayer structures;
• caps and components;
• very small packaging formats;
• compatibility with optical identification systems.

Good design should not only be recyclable in principle. It should have a realistic chance of being identified and separated in existing sorting facilities.

Labelling helps the flow, but does not prove recyclability

PPWR 09 examined harmonised packaging labels and waste-receptacle labels. Their role is to reduce sorting errors at source. But a correct symbol does not automatically turn difficult-to-recycle packaging into recyclable packaging. Labelling supports the system. Design and infrastructure ultimately determine what can happen to the material.

Recycling capacity matters as much as technology

The fact that a recycling process technically exists does not automatically mean that packaging is recycled at scale. There must also be:

• sufficient volumes;
• sufficient industrial installations;
• collected and sorted material streams;
• a market for the recycled output.

Across Europe, PET bottle streams, rigid polyolefin packaging, flexible films and multilayer structures are at very different levels of recycling-infrastructure maturity. This article does not assign PPWR recyclability grades to these formats today. Future classification must be based on the official methodologies.

What does recycling actually produce?

The objective is not simply to reduce waste volumes. Recycling must produce secondary raw material of sufficient quality to substitute virgin raw material where technically possible. This links PPWR 12 directly to PPWR 05.

If recycling produces low-quality material, its use in higher-requirement packaging applications becomes difficult. If it produces a clean and stable stream, integrating recycled content becomes considerably easier.

Food contact – stream quality becomes critical

For sensitive applications such as food contact, control of the waste stream becomes even more important. Contamination, material mixing and lack of traceability can limit the use of recycled material in food-contact applications. Controlled collection systems may therefore have additional industrial value: not only higher volumes, but also better-quality material.

Who controls what?

A company can directly control:

• packaging design;
• materials;
• components;
• supplier specifications;
• labelling;
• quality of technical data.

A company can influence:

• contractual requirements;
• selection of EPR partners;
• collection partnerships;
• sources of recycled material.

National systems, PROs and waste operators control much of the collection, sorting and treatment infrastructure. The Member State sets the overall framework and must meet the national targets.

This distinction matters:
a company is not responsible for every weakness in national infrastructure, but it must design its packaging so that it can function within the real system.

Who pays for collection?

PPWR 11 explained the role of EPR. Through this mechanism, producers finance the relevant costs of packaging-waste management. This is where the economic connection between design and end-of-life becomes visible. A decision that appears inexpensive at the design stage may become more costly later if it reduces recyclability and influences EPR contributions through eco-modulation mechanisms.

Every arrow can represent a loss

The real chain is:
placed on the market → becomes waste → collected → sorted → sent to recycling → actually recycled → secondary raw material.

Losses can occur at every stage. Materials collected together may be contaminated. Some material may be rejected during sorting. The recycling process itself may generate additional losses.

That is why:
collected quantity is not the same as recycled quantity.

Where is recycling actually measured?

European methodology does not automatically treat collected weight as recycled weight. Recycling calculations relate to the amount of waste actually entering the recycling operation after the relevant preparation and sorting losses have been removed, in accordance with the applicable rules.

For companies, the principle matters more than the formula:
collection is the beginning of the process, not the final result.

Export of packaging waste

Waste exported outside the Union may, under the conditions set by EU law, count toward recycling targets only where it can be demonstrated that treatment takes place under conditions compliant with the applicable requirements.

The simple fact that waste has left the EU does not mean that it has been recycled.

Chemical recycling – methodologies will still matter

Chemical recycling is one of the areas where companies should avoid absolute conclusions. The fact that a chemical technology can process a certain waste stream does not automatically mean that the packaging fulfils the PPWR recyclability-at-scale requirement.

But the opposite conclusion should not be assumed either. The exact treatment depends on the relevant methodologies and implementing acts. Until then, categorical commercial claims should be treated cautiously.

Compostable and recyclable are not synonyms

Compostable packaging follows a different end-of-life route from conventional material-recycling streams. Likewise, “biodegradable” does not automatically mean “recyclable”. These concepts should not be used interchangeably, either technically or commercially.

What does this mean for a converter?

The question:
“Can I process this polymer?”
is no longer enough.

Converters increasingly need to ask:

• Which collection stream will the packaging enter?
• Can it be identified and sorted in real facilities?
• Is it compatible with existing recycling streams?
• Does it comply with design-for-recycling criteria?
• Does it have a realistic chance of being recycled at scale in the target markets?

The converter does not control the entire system. But the design it produces directly influences how the packaging behaves within that system.

What should a converter ask the customer?

• In which Member States will the packaging be sold?
• Which collection stream is expected?
• Is it covered by a DRS?
• Is it household, commercial or industrial packaging?
• Which labels, sleeves, adhesives or caps will be added?
• Is the packaging designed according to a specific DfR guideline?
• Is recycled-content integration planned?
• Could any component interfere with sorting?
• Is a reuse system relevant?

What should a brand owner ask the supplier or PRO?

• Which recycling stream is the packaging designed for?
• Which components may create sorting problems?
• What evidence supports the recyclability claim?
• Which methodology was used?
• Is it compatible with the direction of the emerging PPWR criteria?
• How is the packaging reported under EPR?
• Is it covered by a DRS?
• Which future design changes could affect its recyclability grade?

Material or design changes must be reassessed

A new sleeve, a different adhesive, an added barrier layer, a different pigment, a new cap or a move to a multilayer structure can change how packaging behaves during sorting and recycling. Not every change automatically makes the packaging non-compliant. But any change that may affect recyclability should be reassessed. This is the same change-control logic discussed in PPWR 10.

Some practical cases

PET beverage bottle in a DRS
Controlled collection flow, mature sorting infrastructure and a well-developed PET recycling route. The company controls design and components; the system controls the actual return and collection rate.

HDPE detergent bottle
Usually enters standard rigid-plastics collection and sorting streams. Colour, label and cap can influence sorting and recycling.

PP yoghurt cup
Small format may create higher losses in some sorting facilities. Design, label and lid should be assessed together.

PET tray
Colour, barrier layers and lidding materials can change compatibility with rigid PET recycling streams.

Flexible PE pouch
Mono-material design may help, but flexible-film recycling infrastructure is not equally mature across all European markets.

Multilayer pouch
The combination of materials can create significant sorting and recycling difficulties. No definitive PPWR grade should be assigned today without the official methodology.

Paper/cardboard box with plastic elements
Compatibility depends on the proportion, separability and behaviour of additional components within the fibre-recycling stream.

Industrial HDPE drum
B2B flows may be more controlled and homogeneous than household streams, which can facilitate material recovery.

Reusable transport crate
It enters the recycling stream only at the end of its useful life. Durability does not remove the need for end-of-life recyclability.

E-commerce packaging
Tapes, labels, void-fill materials and combinations of materials can influence sorting and recycling efficiency.

Common misunderstandings

• “If packaging is recyclable by design, PPWR is solved permanently.” False. From 2035, recyclability at scale also becomes relevant.
• “If a recycling technology exists, the packaging is recycled at scale.” False. Real infrastructure and volumes matter.
• “If packaging is collected, it is recycled.” False.
• “DRS means recycling.” False. DRS is a collection mechanism.
• “The 90% target applies to all packaging.” False.
• “Every company must personally meet the national recycling target.” False. Article 52 targets apply to Member States.
• “If I pay EPR, my packaging is recyclable.” False.
• “A recycling symbol proves compliance.” False.
• “Reusable packaging never becomes waste.” False. It eventually reaches end-of-life.
• “Chemical recycling automatically solves PPWR recyclability.” Needs qualification; the relevant methodology remains essential.

What can companies do now?

WHAT I CAN DO NOW

• Map the real collection route for each packaging format in the relevant markets.
• Check whether the current design is compatible with the main sorting and recycling streams.
• Identify components that may affect recyclability.

WHAT I CHECK NOW

• Compatibility with current design-for-recycling guidelines.
• Differences between the markets where the packaging will be sold.
• Whether the packaging enters a DRS or another dedicated collection stream.

WHAT I ASK SUPPLIERS

• Data on material and component composition.
• Information on sorting and recycling behaviour.
• Notification of relevant material or design changes.

WHAT I ASK THE PRO OR SYSTEM OPERATOR

• Which collection stream does the packaging enter?
• How is it sorted?
• Which problems frequently arise for this packaging format?

WHAT I ASK CUSTOMERS

• Target markets.
• Expected collection stream.
• DRS status.
• Final components that will be added to the packaging.

WHAT I MONITOR

• Delegated acts establishing design-for-recycling criteria.
• The methodology for recyclability at scale.
• Implementation of the 2030, 2035 and 2038 stages.
• Development of real collection and recycling infrastructure in key markets.

WHAT I WOULD NOT DO YET

• I would not assign a definitive PPWR recyclability grade before the official methodology is available.
• I would not assume that one Member State's infrastructure represents the whole EU.
• I would not claim “recycled at scale” simply because a recycling technology exists.
• I would not assume that participation in a DRS guarantees final recycling.

Conclusion

Yesterday the question was:
“Can this material be recycled?”
Then:
“Was this packaging designed for recycling?”

PPWR now adds a much harder question to avoid:
“Does the real system actually recycle it at scale?”

This is the shift from theoretical recyclability to measurable performance. A company cannot control every collection, sorting or recycling facility in Europe. But it can control the design with which its packaging enters that system.

That is why the practical rule for the coming years is simple:
Design for the real system, not only for the laboratory.

Official Sources

• Regulation (EU) 2025/40 on packaging and packaging waste – in particular Article 6, Articles 48–50, Articles 52–54 and Annex II.
• Directive 2008/98/EC on waste, where relevant to the calculation and management of recycling flows.
• European Commission Communication C(2026) 3702 – guidance document for Regulation (EU) 2025/40.

Context Sources

• Official information on the Romanian deposit-return system, used solely for the practical SGR example.