PPWR Readiness: Phase 4 Monitor 2035-2038

Phase 4 of PPWR spans 2035 to 2038 and raises the bar from "recyclable in principle" to "recycled in practice." Packaging will need to prove that the collection, sorting, and recycling infrastructure for its material stream actually exists at scale across the EU, and from 2038, only the top two Design for Recycling grades will be allowed on the market at all. It's the furthest-out phase in the checklist, but it's also the one where today's material choices have the longest lead time to correct if they turn out to be at risk. Below is the full Phase 4 section from Simvia's 5-step PPWR readiness checklist: recycled-at-scale feasibility and Grade C ban preparation.

4.1 Recycled-at-scale feasibility

From 2035, packaging must not only be recyclable by design but also recycled at scale, meaning collection, sorting, and recycling infrastructure must exist in practice across the EU for that specific material stream. This is a stricter test than recyclability alone and will affect some material streams that are technically recyclable but not yet widely processed.

Ask yourself:

Have you assessed whether the material streams used in your packaging are currently collected and recycled at scale across the EU, not just technically recyclable in principle? Yes / No / Partially

For any formats where recycled-at-scale infrastructure is currently limited, are you monitoring developments in collection and sorting capacity that could affect their status by 2035? Yes / No / Partially

4.2 Grade C ban preparation

From 2038, only packaging graded A or B will be permitted on the market. Grade C packaging (minimum 70% recyclable by weight) will lose market access. The grading methodology will be published in 2028, giving companies a roughly ten-year window to redesign at-risk formats.

Ask yourself:

• Have you flagged packaging formats that are likely to be at risk of a Grade C or below rating based on their current material composition and recyclability performance? Yes / No / Partially

• For high-risk formats, have you identified what redesign or material substitution would be needed to reach Grade A or B? Yes / No / Partially

  
  

Phase 4 is a monitoring phase, not an action phase, but that doesn't mean it can wait. A ten-year runway sounds generous until you consider that material substitution and infrastructure development happen on a similarly long timescale. The two questions that matter most are whether you know which material streams are at real risk (not just recyclable on paper) and whether you're tracking EU collection and sorting capacity as it develops, since that's what determines whether a "recyclable" material stays viable through 2038.

Download the full PDF checklist to work through Phases 1, 2, 3 and 5, and calculate your overall PPWR readiness score.