Under the PPWR, businesses face a host of new recycling and design requirements aimed at making all packaging sustainable. The regulation significantly raises recycling targets for EU Member States and introduces strict rules to ensure packaging is actually recyclable in practice. Here, we break down the key targets by material, the new design-for-recycling mandates (including a recyclability grading system), and the role of Extended Producer Responsibility (EPR) fees that will attach real costs to non-compliance. These changes mean that packaging producers, brands, and retailers must start planning now to meet the upcoming benchmarks – or risk penalties and higher fees.

Higher Recycling Targets by 2025 and 2030

The PPWR largely carries over the ambitious recycling quotas set in the EU’s Circular Economy Package, with some timelines adjusted. By December 31, 2025, each Member State must recycle at least 65% of all packaging waste by weight​. 

This overall goal is broken down by material type, recognizing the different challenges each material poses:

• Plastics: 50% recycling by 2025 (rising to 55% by 2030)​

Plastic has the lowest target due to difficulties in collection and reprocessing, but even achieving 55% will be a heavy lift compared to today’s rates.

• Glass: 70% by 2025 (75% by 2030)​
• Ferrous Metal (steel): 70% by 2025 (up to 80% by 2030)​
• Aluminium: 50% by 2025 (at least 60% by 2030)​
• Paper & Cardboard: 75% by 2025 (climbing to 85% by 2030)​
• Wood: 25% by 2025 (rising to 30% by 2030)​

These targets are significantly higher than what many countries achieved previously. By 2030, the overall packaging recycling target goes up to 70%​ , pushing EU nations to further improve collection and recycling systems. Recognizing that some countries might struggle, the regulation does allow limited exceptions – a Member State can postpone the targets by up to 5 years under specific conditions – but minimum levels still apply and the laggards cannot fall too far behind​.

For businesses, these targets translate into pressure all along the value chain. Packaging producers will need to supply materials that can be readily recycled to hit national quotas, and product brands must ensure their packaging choices align with these goals. Countries will likely strengthen recycling schemes (like improving collection infrastructure or deposit-return programs) to meet the numbers. In effect, if you’re a company operating in the EU, you can expect tougher enforcement of recycling outcomes – simply putting a recycling symbol on a package is not enough if, in practice, that package doesn’t end up recycled.

Design-for-Recycling Mandate (100% Recyclable Packaging by 2030)

A cornerstone of the PPWR is the requirement that by 2030 all packaging placed on the EU market must be recyclable in an economically viable way​. This is more than a slogan – the EU is developing strict criteria for “Design for Recycling” (DfR) that will grade packaging on its recyclability. Each packaging format will receive a recyclability performance grade (likely A to E, with A being best). If a package is made of materials or components that are not recyclable at scale, it will score poorly. Starting in 2030, packaging designs that are graded below a certain threshold (e.g. an EU-wide “D” or “E” grade) will incur financial penalties​. In practice, this means higher EPR fees for hard-to-recycle packaging – effectively making it costly to continue using formats that hinder recycling streams.

For example, suppose a beverage pouch is made of multi-layer plastic film that is technically recyclable only in theory but not collected or processed widely. Under the new framework, that pouch might be deemed <70% recyclable (a low grade), so producers using it would have to pay steep fees into national EPR programs. The clear incentive is to redesign packaging now – switch to mono-material films, eliminate unnecessary mixed materials (like metalized coatings or attached non-recyclable components), and ensure that whatever packaging you use can be easily sorted and reprocessed by 2030. By 2035, the bar rises even higher: packaging must be not only recyclable by design, but “recyclable at scale” in practice across most EU countries​. This aims to close the gap where something is technically recyclable but rarely actually recycled.

These design mandates are supported by upcoming harmonized standards. The European Commission will be issuing detailed criteria for recyclability (e.g. maximum allowed levels of certain additives, what packaging features automatically downgrade recyclability, etc.). Smart companies are anticipated to follow these developments closely and start applying the guidelines early. Those that innovate packaging to get an “A” recyclability grade could even turn it into a market advantage, promoting their products as fully recyclable and avoiding extra fees.

Recycled Content Requirements

Another new requirement is the introduction of minimum recycled content in plastic packaging. The PPWR breaks ground by legally mandating that manufacturers incorporate certain percentages of post-consumer recycled plastic into new packaging, with staged targets for different applications. For instance, by 2030 plastic beverage bottles must contain at least 30% recycled content, and by 2040 that minimum rises to 65%​. Other plastic packaging types have their own targets (e.g. 35% for other plastic packaging by 2030, going up to 65% by 2040)​. These requirements will drive demand for high-quality recyclate. For businesses, this has a dual effect: packaging procurement will need to source recycled polymers (potentially at higher cost or in tight supply), and it creates a strong reason to support recycling initiatives (since today’s waste is literally tomorrow’s packaging feedstock).

Extended Producer Responsibility (EPR) and Fees

The PPWR reinforces and sharpens EPR schemes, which make producers financially responsible for the end-of-life of packaging they put on the market. All EU countries already have EPR programs for packaging, but the new regulation will harmonize EPR fee modulation. Producers will pay lower fees for packaging that is easily recyclable and contains recycled content, and punitive higher fees for packaging that is difficult to recycle​. This “eco-modulation” of fees means that companies have a direct financial incentive to improve packaging sustainability. If a business stubbornly continues with a multi-material plastic sachet that cannot be recycled, it might find its EPR fees per unit are several times higher than those for a recyclable alternative. On the other hand, use of a fully recyclable PET bottle with 30% recycled content could yield fee discounts.

These fees are not trivial – they fund the collection, sorting, and recycling infrastructure needed to meet the PPWR’s targets. For companies that put large volumes of packaging on the market, the cumulative cost could be substantial if their packaging portfolio isn’t optimized for recyclability. Conversely, those who proactively shift to sustainable designs will see not only lower fees but also lower regulatory risk overall. It’s essentially a “polluter pays” principle in action: if your packaging pollutes (through non-recyclability or wastefulness), you pay more; if you design it to be part of the solution, you pay less.

Financial and Operational Implications

In light of these targets and requirements, businesses need to treat packaging sustainability as a core compliance issue. Supply chain adjustments are likely – companies may need to seek out new suppliers for recycled materials, invest in R&D for new packaging designs, or collaborate in industry consortia to develop recycling solutions for challenging packaging (for example, innovators are working on chemical recycling to handle mixed plastics, though its role remains debated). Product lines might need redesign: packaging formats that cannot meet the recyclability criteria by 2030 will have to be phased out. We may see a resurgence of more simplified packaging – e.g. single-material packaging or easily separable components – as brands aim for that 100% recyclability benchmark.

For small and medium-sized businesses, navigating these changes may be challenging, but support is expected in the form of EU guidelines and possibly technical assistance to transition to compliant packaging. It’s worth noting that the regulation’s benefits – reduced waste management costs in the long run and a more circular supply of materials – can offset some upfront expenses. Moreover, consumer expectations are evolving packaging sustainability is now a selling point, and companies that adapt quickly can enhance their brand image as environmentally responsible.

The PPWR’s recycling targets and design requirements are poised to transform business-as-usual in packaging. Regulators are setting a clear course: hit the targets, make packaging recyclable, use recycled content, or face consequences. In the next part of our series, we’ll explore another major facet of the PPWR – how it tackles single-use plastics and excessive packaging – essentially, the push to end wasteful packaging practices altogether.​