Recyclability, recycled content, minimisation and empty space: the four design requirements of the PPWR and why they conflict

Anyone who wants to place compliant packaging on the market from 2030 has to meet up to four requirements at the same time, three of which may only apply later, depending on the Commission's legal acts: it must be recyclable and achieve a performance grade, contain a minimum percentage of recycled content in its plastic parts, be reduced to the minimum necessary for its functionality and, as grouped, transport or e-commerce packaging, comply with an empty space ratio of no more than 50 per cent. Each of these requirements is manageable on its own. The problem is that they get in each other's way.

More recycled content can impair recyclability, because recycled material is often coloured and colours are listed in Table 4 of Annex II as a parameter for design for recycling. Less material means thinner film, which may require an additional barrier layer, and barrier layers are the classic recycling killer. Less empty space means smaller cartons, which reduces stackability on the pallet and can force more secondary packaging. And Annex IV expressly names recycled content, recyclability and re-use as performance criteria to be taken into account in minimisation and even allows additional weight or volume for them, so it requires a justified trade-off rather than minimisation at any cost.

Anyone who works through these requirements one after the other optimises their way into a dead end. This article therefore first sets out what already applies today and what does not, then goes through the four requirements with their actual deadlines, shows the conflicts using concrete cases and ends with the data model that serves all four.

Part 1: What already applies today, and what expressly does not

Precision pays off here, because two widespread statements are wrong.

Correct: Article 6(1) has applied since 12 August 2026. All packaging placed on the market must be recyclable. The Commission's reasoning is that the paragraph sets no deadline of its own and therefore becomes applicable on the general date of application.

Wrong: the claim that recyclability must therefore be assessed now and stated in the declaration of conformity. The Commission guidance expressly states that, until the delegated act under Article 6(4) enters into force, manufacturers do not have to carry out the conformity assessment procedure under Article 38 and Annex VII with regard to recyclability. Until the date of application of Article 6(2)(a), that is until 1 January 2030 or 24 months after the delegated act enters into force, whichever is later, manufacturers must, according to the guidance, comply in substance only with the requirements of the old Packaging Directive and the associated harmonised standards, such as EN 13430:2004. Anyone who writes a recyclability class into their declaration of conformity today is declaring something for which the assessment method does not even exist yet. What belongs in the declaration and what does not is explained in PPWR declaration of conformity: template and mandatory content under Annex VIII.

Also correct, but rarely mentioned: A similar bridge applies to minimisation. Under Article 70(1)(b), the existing minimisation requirements and the associated conformity standard remain in force until the end of 2029. Article 10(1) and (2) only apply from 1 January 2030, and EN 13428:2004 can continue to be used for guidance until a new or updated standard is available.

And a national obligation that is already binding today: Under the German Packaging Law Implementation Act (VerpackDG), producers of single-use plastic beverage bottles made mainly of PET may only make them available in Germany if they consist of at least 25 per cent by mass of recycled plastics (Section 45 VerpackDG). From 1 January 2030, the value of 30 per cent applies to all single-use plastic beverage bottles. The 25 per cent target under paragraph 1 can also be met on the basis of the total mass of bottles made available in Germany in a calendar year, which must be documented in a verifiable manner and presented to the competent state authority on request.

In summary: for the design requirements, 2026 is a data year. The main task is data collection, not assessment under the future PPWR methods. The bridges described in this part still apply, however: the existing minimisation requirements until the end of 2029, for which EN 13428:2004 still gives rise to the presumption of conformity, and, in the Commission's view, the recycling requirements of the old Packaging Directive until the new design criteria apply. In addition, a recycled content target already applies today to single-use PET beverage bottles, in Germany under Section 45 VerpackDG.

Part 2: The four requirements in detail

Recyclability (Article 6)

The Regulation defines recyclability in two stages. Packaging is considered recyclable if, first, it is designed for material recycling so that the resulting secondary raw materials can substitute primary raw materials and, second, when it becomes waste, it can be collected separately, sorted and recycled at scale without affecting the recyclability of other waste streams.

Each stage has its own deadline. Design for recycling applies from 1 January 2030 or 24 months after the delegated act enters into force, whichever is later. The recycled-at-scale requirement applies from 1 January 2035 or five years after the relevant implementing act enters into force, again whichever is later.

Recyclability is assessed in performance grades under Table 3 of Annex II:

From 2035, a second dimension is added: whether the material is actually recycled at scale. The thresholds for this derive from the definition in Article 3(1), point (39), and the assessment is based on the quantity of material actually recycled from each packaging category.

The Commission is to lay down the criteria themselves in a delegated act by 1 January 2028, per packaging category under Table 1 of Annex II and on the basis of the parameters in Table 4. These parameters can already be read today and tell you fairly precisely what will matter. The table lists eleven parameters, ranging from additives through labels, sleeves, closures, adhesives, colours, material composition, barriers and coatings, and inks and lacquers to product residues and ease of dismantling, each with an explanation of why the parameter affects recycling. In addition, four aspects have to be considered: the separability of any component, whether manually by end users or in processing plants, the efficiency of sorting and recycling processes, the foreseeable evolution of sorting and recycling technologies, and the preservation of the functionality of secondary raw materials.

Four more points complete the picture, and two of them are regularly reported incorrectly.

Assessment is per packaging unit, but separate components are assessed individually. Under Article 6(9), compliance with the criteria is assessed separately for each separate component of a packaging unit. Integrated components that can become separated from each other as a result of mechanical stress during transport or sorting are also assessed separately. All components must be compatible with the established collection, sorting and recycling processes and must not hinder the recyclability of the main body of the packaging. For the data model, this means that data is recorded per component, even though the performance grade is ultimately expressed per packaging unit in terms of weighting.

The five-year rule is not a general transitional period. Article 6(10) concerns innovative packaging only. From 1 January 2030, such packaging may still be made available on the market for up to five years from the end of the calendar year in which it was placed on the market, even though it does not meet the requirements of paragraph 2. To use this, the economic operator must notify the competent authority before placing the packaging on the market, include technical details on its innovative nature and submit a timeline showing how the recycled-at-scale requirements will be met in future. If the authority does not consider the packaging to be innovative, the normal criteria apply. If it does, it informs the Commission. Anyone who plans to use this rule as a buffer for ordinary, non-compliant packaging is planning on the wrong basis.

The exemptions in paragraph 11 are broader than is usually reported. Article 6 does not apply to immediate packaging of medicinal products for human and veterinary use, to their outer packaging where this is necessary to preserve the quality of the medicinal product, to contact-sensitive packaging of medical devices and in vitro diagnostic medical devices, to contact-sensitive packaging for infant formula, follow-on formula, processed cereal-based food and baby food, and food for special medical purposes, to packaging used for the transport of dangerous goods or to sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax. For the last group, however, paragraph 8 continues to apply, so fee modulation still takes effect. The Commission will review these exemptions by 1 January 2035.

Recyclability becomes a cost issue. Article 6(8) links extended producer responsibility (EPR) fees to the performance grade. Fees must be modulated 18 months after the delegated acts under paragraph 4 and the implementing acts under paragraph 5 enter into force, on the basis of harmonised criteria that the Commission adopts together with the design for recycling criteria (recital 35). Member States may also apply further criteria, such as recycled content or reusability (recital 129).

Recycled content (Article 7)

This is where the arithmetic starts. The target applies from 1 January 2030 or three years after the implementing act under Article 7(8) enters into force, whichever is later. It relates to each plastic part of packaging placed on the market, per packaging type and format under Table 1 of Annex II, calculated as an average per manufacturing plant and year. Recital 41 clarifies that "manufacturing plant" means a single industrial facility where packaging is manufactured.

Which target applies is determined in two steps: first contact sensitivity, then polymer.

Only recycled content recovered from post-consumer plastic waste counts, in other words post-consumer material. Under Article 7(3), this waste must also have been collected in the Union, or in a third country in accordance with equivalent standards, and, where applicable, recycled in installations covered by the Industrial Emissions Directive or subject to equivalent rules. Post-industrial recycled material does not count towards the target.

In practice, four rules decide whether a component enters the calculation at all:

The five per cent threshold. Plastic parts representing less than five per cent of the total weight of the packaging unit are exempt (Article 7(5)(b)). The term "plastic parts" is to be interpreted in line with the definition of composite packaging.

Adhesives, paints and printing inks do not count as plastic, regardless of their share of the weight. This considerably eases the burden on printed packaging.

The scope covers the plastic parts of sales, grouped and transport packaging. A metal closure is not covered in any case.

Health protection takes precedence. Plastic packaging that comes into contact with food is exempt where the recycled content poses a threat to human health and results in the packaged products not complying with Regulation (EC) No 1935/2004. According to the Commission guidance, this exemption applies directly but must be substantiated in the technical documentation: for each plastic part of five per cent or more, the polymer must be specified, and it must be shown that Annex I to Regulation (EU) 2022/1616 does not list a suitable recycling technology for that polymer and that no recycling technology for it is available at an industrial scale. In addition, there are the exemptions in Article 7(4) for immediate packaging of medicinal products for human and veterinary use, for their outer packaging and for packaging of supplies and components for the manufacture of medicinal products, in both cases only where necessary to preserve the quality of the medicinal product, for contact-sensitive plastic packaging of medical devices and in vitro diagnostic medical devices, for compostable plastic packaging, for contact-sensitive plastic packaging of food for infants and young children and of food for special medical purposes, and for packaging used for the transport of dangerous goods.

An important caveat: by 1 January 2028, the Commission will assess under Article 7(12) whether derogations from the targets in paragraph 1, points (b) and (d), are needed for specific plastic packaging, in particular where suitable recycling technologies are not authorised or not sufficiently available in practice. For contact-sensitive non-PET packaging, this is a realistic scenario. Plan for the target, but keep an eye on this assessment.

There is a fee logic here as well, but only as an option: under Article 7(7), EPR fees may be modulated according to recycled content, and recital 42 expressly names this modulation as an incentive instrument.

Minimisation of weight and volume (Article 10)

From 1 January 2030, manufacturers and importers must ensure that the weight and volume of packaging are reduced to the minimum necessary to ensure its functionality, taking account of shape and material. Packaging that does not comply with the performance criteria in Annex IV, and packaging with characteristics that aim only to increase the perceived volume, such as double walls, false bottoms and unnecessary layers, must not be placed on the market.

Part A of Annex IV lists the performance criteria to be weighed in minimisation: product protection, packaging manufacturing processes, logistics, packaging functionality, information requirements, hygiene and safety, legal requirements, recycled content, recyclability and re-use. Part B describes the assessment methodology and the determination of the minimum volume. The technical documentation must describe the calculation and the assessment of the results, identify for each criterion in Part A the design requirement that prevents a further reduction in weight or volume, and list the test results, studies or investigations used.

Article 10(2) provides two exceptions to these bans: under point (a), designs protected under Regulation (EC) No 6/2002 or Directive 98/71/EC and shape marks under Regulation (EU) 2017/1001 or Directive (EU) 2015/2436, and under point (b), products and beverages with a geographical indication protected under Union law, such as wine or spirit drinks, or covered by a quality scheme under Regulation (EU) 2024/1143. The designs and trade marks must have been protected before 11 February 2025, and the exception only applies where the requirements of Article 10 would alter the novelty or individual character of the design or deprive the trade mark of its distinctive character. Anyone with a bottle shape protected before 11 February 2025 can therefore keep it only where the requirements of Article 10 would alter its novelty or individual character as a design or deprive it of its distinctive character as a trade mark.

This is precisely the decisive point in practice: Annex IV requires not minimisation at any cost but a documented trade-off. Anyone who can demonstrate that a thinner film endangers product protection or impairs recyclability has met the criterion. Anyone who documents nothing has not, even if the packaging is objectively lean.

Empty space (Article 24) and format restrictions (Article 25)

Article 24 is the most misunderstood of the four, because it contains two empty space rules with different dates and reference bases, plus an exemption rule.

Rule 1, from 2030 at the earliest: 50 per cent for grouped, transport and e-commerce packaging. Economic operators who fill such packaging must comply with a maximum empty space ratio of 50 per cent, from 1 January 2030 or three years after the implementing act enters into force, whichever is later. Empty space here is the difference between the total volume of the grouped, transport or e-commerce packaging and the volume of the sales packaging it contains. The ratio is the empty space in relation to this total volume. Space filled with filling material such as paper, air cushions, bubble wrap, foam, wood wool or polystyrene chips counts as empty space. The obligation falls on whoever uses or fills the packaging, not on the carton maker.

Rule 2, from 12 February 2028: the minimum necessary for sales packaging. Two years earlier than rule 1 and with a different yardstick: anyone who fills sales packaging must ensure that empty space is reduced to the minimum necessary to ensure the packaging functionality, including product protection. Here, empty space is the difference between the total internal volume of the sales packaging and the volume of the packaged product. Filling material counts as empty space here too. There is no percentage limit, only the minimisation requirement. According to the Commission guidance (section 11), this empty space is assessed using the standard EN 13428:2004, which is to be updated in line with Annex IV, and the obligated party is the manufacturer, who carries out the conformity assessment for it and draws up the technical documentation and the EU declaration of conformity.

For products that are subject to settlement during transport, or where headspace is needed to protect the food product, two concessions apply: compliance is assessed on the basis of the pack-fill level at the time of filling, and air between or within packed foodstuffs and protective gases are not considered empty space.

Exemptions from rule 1. Anyone who uses sales packaging as e-commerce packaging, or who uses reusable packaging within a re-use system, is exempt from rule 1 but must meet the requirements of Article 10. The Commission is to lay down the calculation methodology for rule 1 in an implementing act by 12 February 2028, which is expressly to take into account irregularly shaped products, packaging containing several sales units, liquid products, contents that are easily damaged, small products that can be damaged by larger ones, and the minimum space for shipping labels.

By 12 February 2032, the Commission will review the empty space ratio and the exemptions and assess whether empty space ratios should also be set for sales packaging of toys, cosmetics, do-it-yourself kits and electronic products.

This is complemented by Article 25: from 1 January 2030, certain packaging formats may no longer be placed on the market for the uses listed in Annex V. These include single-use plastic grouped packaging that bundles goods at the point of sale for multiple purchases (for example shrink wrap around tins), unless it is necessary to facilitate handling, single-use plastic packaging for less than 1.5 kilograms of fresh fruit and vegetables, and single-use plastic packaging for food and beverages filled and consumed within the premises in the HORECA sector. According to the Commission guidance (section 17), composite packaging, including paper-based packaging, containing 5 per cent or more plastic is also covered by the bans under points 1 to 4 of Annex V. Member States may grant micro-enterprises an exemption for the formats under point 3 of Annex V where there is no technically feasible alternative. What else applies to small businesses is explained in Micro-enterprises, small businesses and online retail.

Part 3: Where the requirements collide

The Regulation resolves these conflicts only in part. In Annex IV, it expressly requires recycled content, recyclability and re-use to be factored into minimisation, even allows additional weight or volume for them under point 8 of Part A and leaves the remaining trade-off to the manufacturer. Four conflicts come up regularly in our conversations.

Recycled content versus recyclability. Post-consumer recycled material is often grey or coloured. Using it meets the target under Article 7 but may impair sortability and thus the performance grade under Article 6. The basis for this is set out in the text of the Regulation: Table 4 of Annex II lists colours as a parameter in its own right and explains that heavily dyed materials in paper or plastics can cause sorting problems and can downgrade the quality of secondary raw materials. The solution usually lies in the choice of material, not the quantity: mono-material with light-coloured recycled material beats a composite made from virgin material.

Minimisation versus product protection and recyclability. A thinner film more often needs a barrier layer, and barrier layers made from a different polymer turn a mono-material into a composite. Less weight can therefore cost a performance grade. Annex IV permits precisely this trade-off, but requires it to be documented.

Empty space versus logistics. Smaller cartons lower the empty space ratio but at the same time reduce stackability and pallet utilisation. Annex IV names logistics as a performance criterion, but that only applies to minimisation under Article 10. No logistical justification gets you past the 50 per cent limit in Article 24(1). When in doubt, it helps to calculate the empty space per shipping unit and align the carton size grid accordingly.

Filling material versus breakage protection. Filling material counts as empty space under both empty space rules. Anyone who ships fragile goods must therefore introduce better-fitting carton sizes. Documenting the necessity only helps for sales packaging under Article 24(4), not against the 50 per cent limit. The implementing act under Article 24(2) is expressly to take into account contents that are easily damaged. How far that will go remains open.

Part 4: The data model that serves all four

The practical consequence of all this is unspectacular but decisive: by 2030 you need not a finished assessment but a complete data set. Anyone who records the following fields per component and per packaging unit today can address each of the four requirements as soon as the legal acts supply the methods. Anyone who does not have them will have to record an entire product range from scratch in 2029, under time pressure and with the same suppliers, who will then all be asked at the same time.

Per component:

Per packaging unit:

That sounds like a lot. Per component there are eleven fields, seven of which you need anyway for the technical documentation under Annex VII, and per unit there are seven, three of which come from the ERP system. In our experience, the volume data is the part that is missing.

Part 5: The roadmap to 2030

2026 and 2027: collect data. Build up component data, measure volumes, involve suppliers. When requesting recycled content figures, ask for the source and method at the same time, because a percentage without provenance is worthless later on. A template for this is available in Model letter to upstream suppliers.

2028: read the legal acts and close gaps. The delegated act on design for recycling is due by 1 January 2028, the implementing act on the empty space calculation by 12 February 2028, and by 1 January 2028 the Commission will assess whether additional derogations from the recycled content targets are needed. From then on, you will know which of your packaging achieves which grade. At the same time, the obligation for sales packaging under Article 24(4) begins on 12 February 2028, regardless of everything else.

2029: redesign and document. For packaging below 70 per cent recyclability, there is no general transitional period, because Article 6(10) applies only to innovative packaging. At the same time, every changeover has a lead time, from tooling changes to requalifying the filling line. In parallel, put the trade-offs under Annex IV in writing.

2030: declare. Only then do the performance grade, recycled content rate and minimisation belong in the declaration of conformity and the technical documentation, including empty space for sales packaging according to the Commission guidance. The 50 per cent limit for grouped, transport and e-commerce packaging, by contrast, is an obligation of those who fill or use such packaging.

What you should decide now

Three key decisions cannot be postponed to 2029, because they depend on investment cycles.

Mono-material or composite. Anyone who procures a new film line or a new tool in 2027 is locking in the performance grade for the next ten years. The parameters in Table 4 of Annex II are known, even if the weighting is still missing.

Secure your supply of recycled material. Post-consumer recycled material of the required quality is scarce, and from 2030 everyone will be asking for it at the same time. Recital 42 expressly mentions that Member States may maintain existing systems granting priority access to recycled material, at market prices and in line with the quantity of packaging that the economic operator makes available in the Member State concerned. Check whether such a system exists in your sales markets and whether you or your supplier can obtain access through it.

Carton size grid. Anyone who has twelve shipping carton sizes today will hardly be able to comply with the empty space ratio. Switching to a finer grid or to variable-height cartons is a logistics decision with a long lead time, not a compliance project.

How Polygon One helps

To be clear: Polygon One does not contain an assessment engine for recyclability. The method for it only arrives with the delegated act, and until then any class calculation would be guesswork. In the platform, the recyclability class is a declared value: you state what you have determined, and Polygon One reproduces it in the documentation. Likewise, recycled content is for information only today, with a comparison against the Article 7 target but without a verdict.

What the platform does is hold the data model from Part 4: components with material, polymer, mass, function, contact sensitivity, recycled content including source and method, plus the packaging unit with its properties. Where data is missing, the platform flags this on the component instead of inventing values. Data that has not been recorded appears in the technical documentation explicitly as not recorded. The fields for 2028 and 2030 do not block completeness for 2026.

This is deliberately less than some providers promise, and it is the honest state of play: you can build up the data today, but nobody can deliver the assessment today. If you would like to see how far your master data will carry you towards 2030, book a demo or read on at the product page for the PPWR module.

Frequently asked questions

When does recyclability become mandatory?

Article 6(1) has applied since 12 August 2026. The performance grades under Article 6(3) apply from 1 January 2030 or 24 months after the delegated act, whichever is later. Until that act enters into force, the conformity assessment for recyclability does not have to be carried out.

Is there a five-year transitional period?

Only for innovative packaging. Article 6(10) allows it to be made available for up to five years from the end of the calendar year in which it was placed on the market, but requires a notification to the competent authority before placing on the market, technical details on its innovative nature and a timeline for future compliance. There is no such period for ordinary packaging.

What recyclability classes are there?

Grade A from 95 per cent, grade B from 80 per cent, grade C from 70 per cent. Below that, packaging is considered technically non-recyclable. From 2038, grade C packaging may no longer be placed on the market.

How high must the recycled content be?

From 1 January 2030 or three years after the implementing act under Article 7(8) enters into force, whichever is later, the targets are 30, 10, 30 or 35 per cent depending on the packaging, and from 1 January 2040 they are 50, 25, 65 or 65 per cent. The decisive factors are contact sensitivity, polymer and whether the packaging is a single-use plastic beverage bottle, and the share is calculated per packaging type and format as an average per manufacturing plant and year.

Does post-industrial recycled material count towards the target?

No. Article 7 requires recycled content recovered from post-consumer plastic waste.

What is the empty space ratio?

For grouped, transport and e-commerce packaging, it is the ratio of empty space to total volume, with a maximum of 50 per cent from 1 January 2030 or three years after the implementing act enters into force, whichever is later. Filling material counts as empty space. For sales packaging, a minimisation requirement with a different reference base applies from 12 February 2028, without a percentage value.

Does the empty space rule also apply to my shipping cartons in online retail?

Yes, e-commerce packaging falls under the 50 per cent rule. The only exceptions are sales packaging that is itself used as e-commerce packaging and reusable packaging within a re-use system, in which case Article 10 applies.

Do I have to make my packaging lighter by 2030?

You must reduce weight and volume to the minimum necessary for functionality and document this trade-off using the criteria in Annex IV. Product protection, logistics and recyclability must expressly be taken into account.

Which packaging formats will be banned in 2030?

Those listed in Annex V, including single-use plastic grouped packaging that bundles goods at the point of sale for multiple purchases and is not necessary to facilitate handling, single-use plastic packaging for less than 1.5 kilograms of fresh fruit and vegetables and single-use plastic packaging for consumption on the premises in the HORECA sector.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22 January 2025), Articles 6 to 10, 24, 25 and 70, Annexes II (Tables 1, 3 and 4), IV and V and recitals 33 to 35, 41, 42, 44, 50 and 129. Commission guidance C(2026) 3702, published as Commission Notice C/2026/3084 (OJ C of 10 June 2026), sections 6, 7, 10, 11 and 17. Commission FAQ on the PPWR, 2nd edition (August 2026), section V, questions 2, 3, 5, 6 and 7. Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG), BGBl. 2026 I No 207, Section 45. This article describes the legal position as at September 2026 and does not replace legal advice.