Design for recycling under PPWR means designing packaging, including its components, to work with established collection, sorting and recycling processes proven in operation. The aim is to recover material of sufficient quality to replace primary raw materials. That connection between design and usable recovered material runs through Article 3’s definition and Article 6’s requirements in Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation.
For a brand commissioning paper cartons or gift boxes for EU sales, the finished construction becomes the starting point. Board, wrapping paper, surface protection, glue and an insert each perform a useful job. Their combination also determines how easily the materials can be separated and recovered after the packaging has served its purpose.
Start with the material that comes out of recycling
In paper recycling, water and mechanical action help release fibres from paper and board. Screening and cleaning stages separate unwanted material from the fibre suspension. The useful result depends on both the amount of fibre recovered and its quality. A layer removed during processing may carry otherwise usable fibre away with it; adhesive residues or other contaminants may reduce the recovered pulp’s suitability for making new paper.
This makes the intended recycling route significant. A successful trial using specialist separation equipment answers a question about that process. The packaging must also be compatible with collection and sorting that can deliver it to an appropriate recycling operation. PPWR’s definition of design for recycling already refers to established operational processes, so practical compatibility belongs in the design judgment from the beginning.
Recycled content describes the material entering a new package; recyclability describes what can happen after use. A rigid box made with recycled greyboard may still have a difficult combination of surface film, adhesive and bonded insert. Choosing recycled board addresses one aspect of material use. Evaluating the completed box establishes whether those fibres can usefully circulate again.
Work through the construction of a gift box
Consider a skincare gift box holding two glass jars. Its greyboard body is wrapped in printed paper, a protective film covers the wrap, and a foam insert is bonded into the base. The customer values a clean surface, a firm opening movement and jars that arrive without knocking together. Design for recycling brings the recovery of the materials into those same development decisions.
The board and surface treatment need to be considered together. A film can provide useful resistance to scuffing, while affecting fibre release, separation and the quantity of material rejected during recycling. A possible alternative is a different wrapping paper with a suitable protective varnish. That alternative needs evaluation for both surface performance and recycling behaviour. Descriptions such as “water-based” give information about a coating, but its formulation, applied amount and behaviour in the relevant process still matter. Annex II explicitly identifies coatings, material combinations and recovered-material yield as assessment considerations.
Adhesive is part of the construction’s recycling behaviour. Glue keeps the wrap flat, the corners secure and the insert in position. During recycling, adhesive residues can affect the purity of recovered material; tacky particles can also create problems in papermaking. The useful questions concern the actual formulation, amount and placement, and whether the adhesive separates effectively or remains compatible with the process. Reducing an unnecessary area of bonding may help, provided the remaining bond still performs its packaging function.
The insert changes both protection and separation. Permanently bonding foam to the base makes the materials harder to separate. A lift-out tray can make separation easier, while leaving the tray’s own collection and recycling route to be assessed. A folded paperboard insert is another possibility. For two glass jars, its folds, supports and retention features must keep the jars apart and stable. Reproducing the outline of a foam cavity in paper alone may provide very different support.
At CMIC, we can develop these alternatives around the same product and presentation brief: adjust the insert structure, compare surface treatments, specify the bonding arrangement and produce samples for evaluation. A useful starting preference is to reduce incompatible, permanently bonded layers while retaining the protection the product needs. Comparing complete samples shows the consequences for appearance, fit, assembly and recycling assessment together, before a construction becomes the production specification.
Include the body and its components in the assessment
Article 6(9) requires the assessment to account for the main body and its components. Article 3 distinguishes components by their role in the package, whether they need to be removed, and how they are normally discarded. Applied to the gift box, the rules work as follows:
- Integrated components function as part of the packaging unit. They do not need to be separated for the unit to perform its function and are normally discarded at the same time as the body. A bonded foam insert that supports the jars and stays with the box through use and disposal illustrates this category. The box’s assessment includes the insert and its attachment.
- Separate components need to be completely and permanently removed and are normally discarded before and separately from the main body. Imagine a tear-off retaining panel that must be removed to release the jars and is discarded while the box remains in use. That panel receives its own assessment.
- Integrated components that can separate under mechanical stress during transport or sorting also require a separate assessment. Being supplied attached does not remove this requirement.
A lift-out tray can make it easier to send the box and tray into their appropriate material streams. If the tray continues to support the jars during use and is normally discarded at the same time as the box, it can still be an integrated component; easier removal alone does not make it a separate component under PPWR. The design improvement is easier separation, while the assessment still has to cover the tray and its effect on the box. Across all these arrangements, every component must be compatible with established collection, sorting and recycling processes and must not hinder the recyclability of the main body.
Understand the grades—and the separate question of scale
PPWR’s percentages express the recyclability performance of a packaging unit after the relevant design-for-recycling criteria have been applied and weighted. That assessment concerns the finished construction’s ability to be sorted and recycled into secondary raw materials of sufficient quality to replace primary materials. It follows the criteria for the relevant packaging category: Annex II distinguishes paper/cardboard packaging from composite packaging in which paper/cardboard predominates.
| Grade | Weighted design-for-recycling assessment result for the packaging unit |
|---|---|
| A | 95% or higher |
| B | 80% to below 95% |
| C | 70% to below 80% |
| Below the minimum | Below 70%; considered technically non-recyclable under this framework |
A Grade A result would mean that the assessed packaging unit achieves at least 95% under its category’s design-for-recycling rules. It describes the recycling performance of the complete construction covered by that assessment. The detailed method for deriving the percentage remains to be established through the Article 6(4) delegated acts. These must specify how to calculate and express the result, including material-specific criteria and sorting efficiency, and the conditions for each packaging category to meet each grade. The thresholds and broad assessment parameters are already set in Annex II; the detailed calculation is the part still to come.
For the gift box, knowing that 95% of its weight is paper would establish its composition. A grade also depends on whether the construction allows that material to be recovered at the required quality. Two boxes with the same paper content can behave differently if their coatings or bonded inserts affect separation and fibre recovery. Material weights and relevant test results therefore inform the assessment, but neither a paper-content percentage nor a laboratory fibre-yield percentage can be read directly as a PPWR grade.
Recycling at scale adds evidence about what happens to the packaging category in practice. Its assessment uses actual quantities placed on the market and recycled, supported by a chain of custody and downstream verification. Article 3’s definition sets an EU-level threshold of 55% for materials other than wood, including paper/cardboard. That is a category-level recycling threshold, distinct from a packaging unit’s design grade or its recycled-content percentage. A laboratory result for one box cannot establish this wider infrastructure and recycling performance.
Read the dates with their conditions
As of September 2026, the detailed EU design-for-recycling criteria and grading methodology remain forthcoming. The grade thresholds and assessment parameters are already in the regulation. Article 6 requires the Commission to adopt the detailed design criteria through delegated acts by 1 January 2028, and the recycling-at-scale methodology through implementing acts by 1 January 2030. The dates for applying the resulting requirements are:
| Date | What applies |
|---|---|
| 12 August 2026 | PPWR generally applies, including Article 6(1)’s general recyclability requirement. The detailed design-for-recycling grading follows the later timetable below. |
| 1 January 2030, or 24 months after the relevant delegated acts enter into force, whichever is later | The detailed design-for-recycling requirement and the rule permitting market placement only within grades A, B or C apply. |
| 1 January 2035 | Article 6(2)(b)’s condition concerning separate collection and sorting into appropriate streams without affecting other streams’ recyclability applies. |
| 1 January 2035, or five years after the relevant implementing acts enter into force, whichever is later | The recycled-at-scale requirement applies. |
| 1 January 2038 | Market placement requires Grade A or B; Grade C no longer qualifies under the general rule. |
Ordinary paper gift boxes and folding cartons have no general exemption because of their material or presentation function. Article 6(11) lists specific exceptions, including defined medical applications and packaging used to transport dangerous goods. There is also a limited route for qualifying innovative packaging under Article 6(10), with notification and technical-evidence conditions. These provisions require the actual application to qualify.
Make the evidence match the finished construction
Voluntary design guidance can help identify risks and compare alternatives. Laboratory testing can show how a specified sample behaves under a stated recycling method. Both can contribute useful development evidence, while the statutory grade must follow the applicable PPWR assessment rules. A repulping test, for example, may provide evidence about fibre recovery and output quality under its test conditions; it does not establish collection, sorting and recycling at scale across the EU.
For the skincare box, useful evidence identifies the board and wrapping paper, the finish and its application, the adhesive, and the insert and attachment method. It also records what was tested, which components were included or removed, the method used and the recycling process represented. This makes it possible to connect a result to the box being ordered. A report covering bare board has a narrower scope than an evaluation of the converted, finished construction.
Article 6(9) requires compliance with the detailed recyclability requirements to be demonstrated in the technical documentation set out in Annex VII as those requirements become applicable. Keeping the material specification, assembly details and relevant evaluation results connected during development creates a useful basis for that assessment. It also makes unresolved questions visible while the design can still be changed.
That connection needs to survive production changes. A replacement wrapping paper, a different coating or a revised glue application can alter the construction represented by earlier evidence. Article 15(4) requires manufacturers to account for changes that may affect conformity and to reassess where necessary. Recording the actual production specification therefore supports both consistent packaging quality and a meaningful compliance assessment.
The same EU market requirements apply to packaging manufactured in China. The supply arrangement needs to establish the relevant manufacturer and importer responsibilities, with supporting information available from packaging and material suppliers. Coordinating that information alongside sampling helps the businesses responsible for conformity connect their assessment to the packaging actually supplied.
If you are developing or revising a box for EU sales, we can begin with your product, an existing sample or drawing, and the presentation you want to preserve. Through our EU packaging solutions, CMIC can develop alternative constructions and coordinate suitable evaluation. The comparison can then address the whole job: protecting the product, creating the intended opening experience and recovering useful material after use.
