Packaging that is "recyclable" in the ordinary sense of the word can still be barred from the EU market in 2038. Article 6 of Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — replaces the word with a grade, A, B or C, and sets two dates that sort the market: 1 January 2030, when only graded packaging may be placed on the market, and 1 January 2038, when grade C falls away. A coated paper pack is usually decided between those two dates by two variables: coating weight and coating formulation.
What the grades measure
The grade comes from a design-for-recycling assessment under Annex II of the regulation, and it is expressed as a share of the packaging's material that a real recycling stream can recover.
Grade A — 95% or more recyclable.
Grade B — 80% or more.
Grade C — 70% or more.
Below 70% — treated as technically non-recyclable.
Recyclability is not a property of the material alone. It is a judgement about whether the pack can be collected and sorted into a real stream and whether the recovered material can substitute a primary raw material — which is why the same paper with a heavier coating can land in a different grade.
The two dates, and the one in between
| Date | What changes | What it means for a coated paper pack |
|---|---|---|
| 1 January 2030 | Only packaging graded A, B or C may be placed on the EU market; anything below 70% is prohibited | A pack that cannot be repulped at all stops being sellable, regardless of how good its barrier is |
| 1 January 2035 | A "recycled at scale" assessment is added, based on the weight actually recycled per packaging category | Being technically recyclable is no longer sufficient on its own — the stream has to exist in practice |
| 1 January 2038 | Only grades A and B remain; grade C is barred | The 70–80% band is a transitional home, not a destination |
Two timing details are easy to miss. The design-for-recycling requirement applies from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later — so the effective date depends on secondary legislation still being adopted. And the recycled-at-scale requirement follows the same pattern against its own implementing acts. The direction of travel is fixed even where the exact date is not.
Where a paper pack loses its grade
- Coating weight. A thin aqueous coating on a fibre substrate generally stays in the paper stream. Past a certain coat weight the furnish behaves less like paper and more like a laminate, and the recoverable share drops.
- Coating chemistry. A water-based system and an extruded plastic film can deliver a similar grease barrier and land in different grades, because only one of them repulps with the fibre.
- Non-fibre components. Windows, handles, dispensers, labels and their adhesives are all counted. A pack is graded as a whole, not by its main material.
- Colour and printing. Heavy ink coverage and certain pigments affect what the de-inking and repulping stage can recover.
This is the trade-off the white paper on PFAS-free packaging calls the regrettable substitute: a coating that answers the PFAS question while pushing the pack below the grade its market requires. Both questions have to be answered by the same construction.
FAQ
Does a paper pack automatically pass?
No. Fibre-based packaging usually has a good starting position, but the grade is assessed on the finished pack, including coatings, adhesives and any non-fibre components.
Is compostability an alternative route?
Not for Article 6. Recyclability and compostability are separate tracks with separate evidence, and a compostable coating does not by itself improve a recyclability grade.
When should a buyer ask for the grade?
At specification, not at delivery. The grade is set by the construction — base paper, coating weight and formulation — and changing any of them after qualification means requalifying.
What standard is the assessment built on?
The harmonised design-for-recycling standards being developed by CEN under the EN 18120 series. Until the delegated acts are in force, the practical reference is the recyclability testing the mill and converter already run, plus the destination market's own scheme rules.
Browse the range
The full regulatory background is set out in our PFAS-free packaging white paper. For grades built to keep the fibre stream open, start from the water-based barrier coating paper and the water-based coated cupstock board, or browse the materials library by base paper. Tell us the destination market, the food type and the converting line, and we will confirm the construction and the documentation you need. Compliance documentation is provided offline on request; we do not publish certificate numbers online.
More in this series: how PFAS is tested in food packaging · the 100 mg/kg heavy-metal sum · EPR and the authorised representative