How Industry Can Get Ahead of Europe’s New Plastic‑Packaging Recyclability Rules

The Hague 13 April, 2026 – Europe’s Packaging and Packaging Waste Regulation (PPWR) is about to redraw the map for every company placing plastic packaging on the EU market. Framed as one of the most complex regulatory packages ever attempted, the PPWR will begin applying from 12 August 2026 and tighten considerably through 2030, 2035 and beyond. For industry, the message is unmistakable: the era of optional recyclability is over. The era of mandatory, provable recyclability has begun.

To help producers and importers of plastic packaging prepare for this watershed moment, Producer Responsibility Organisations (PROs) from six* European countries have put together a deceptively simple service: the Design for Recycling: No Regrets 

The philosophy behind these No Regrets is easy to comprehend: every packaging starts with design. Yet, notably for plastic packaging, the implications from the upcoming EU regulation reach far beyond design teams. Manufacturers will be legally responsible for ensuring that every packaging unit they place on the market meets strict recyclability criteria under Article 6 of the PPWR.

A New Compliance Reality

Article 6 of the PPWR prescribes that all packaging that is placed on the market must be recyclable. This requirement starts from the application date yet will be accompanied with extra obligations starting in 2030.

The PPWR introduces a structured, score‑based recyclability assessment that will grade packaging A, B or C, with C allowed only until 2038. The European Committee for Standardization (CEN) develops technical criteria and 'traffic light tables' to determine recyclability by material type, which will lead to final requirements by 2027-2028 at the latest. Unfortunately, at present there is no full consensus among industry experts on what is ranked green, yellow or red when compared with similar ranking in guidelines from highly regarded guidelines from Recyclass, Cotrep or Verpact.

Our Design for Recycling No Regrets assists market parties, brand owners and packaging producers by indicating on which criteria there is consensus and on which not. As a result, market parties can validate which packaging design decisions are safe to pursue and – alternatively – which need to be pursued with caution. Using these No Regrets is a no regret option in the current period of uncertainty.

What Industry Should Do Now

So although at present not all assessment details are clear, our core message is that companies do not need to wait for every detail to be finalised. In fact, waiting would be a mistake. The PPWR already provides enough clarity for companies to begin redesigning packaging with confidence.

1. Get insight in your portfolio of packaging and the composition of each packaging system
Map your packaging portfolio and the composition of each package.
2. Follow the emerging “traffic‑light” design criteria.
Check the International Design for Recycling No Regrets to check on which green and red elements there is consensus across major industry guidelines and draft CEN standards.
3. Prioritise compatibility in multi-component packaging.
If a packaging consists of more than one element, like a cap on a bottle or a film on a tray, packaging designers should focus on each separate element and the compatibility with the predominant material (the bottle or the tray). In the end, this ensures optimal recycling.
4. Minimise inks, adhesives, barriers and coatings.
Even when using “green” materials, excessive constituents can degrade recyclate quality and lower recyclability scores.
5. Ensure sortability.
Design choices such as full‑body sleeves can disrupt NIR sorting and jeopardise recyclability grades.
6. Engage suppliers immediately.
Do not wait – you can already take confident action on your packaging designs today.

“Let's be clear: the PPWR is not just another compliance hurdle—it is a structural shift toward a circular packaging economy. Companies that act now will not only avoid regulatory shocks but also gain a competitive edge as recyclability becomes a market expectation, a legal requirement and a cost‑saving opportunity through lower Extended Producer Responsibility fees. We thank our five European sister agencies for their cooperation in designing the Design for Recycling Analysis Playbook that supports our industry to timely prepare for drastic change in European packaging regulation”. says Hester Klein Lankhorst, CEO of Verpact.