Is your packaging truly “recyclable”? What was once an environmental slogan is fast becoming a market-entry threshold. The EU PPWR has set a clear timetable: from 1 January 2030, packaging placed on the EU market must achieve at least Grade C (recyclability ≥ 70% by weight); packaging below Grade C may not be placed on the market. China is following suit — GB/T 48042-2026, General Rules for the Design Assessment of Easy-to-Recycle and Easy-to-Regenerate Plastic Products, was published on 30 July 2026 and takes effect on 1 February 2027, giving China’s “easy-to-recycle, easy-to-regenerate” assessment of plastic products its first national standard. CIRS Testing has launched an integrated “assessment + testing” service backed by its CMA & CNAS dual-accredited laboratory — one submission, dual compliance.

I. EU PPWR: Recyclability Grading

Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) entered into force on 11 February 2025 and applies in full from 12 August 2026. Article 6 of the Regulation requires all packaging placed on the EU market to be recyclable, and establishes a weight-based grading of recyclability performance (Annex II, Table 3):

Timetable Note | The Grade C threshold applies from 1 January 2030, or 24 months after the entry into force of the “Design for Recycling (DfR)” delegated act, whichever is later; that delegated act must be adopted by 1 January 2028 at the latest. Before then (from 12 August 2026), recyclability is assessed under Article 6(1) PPWR, and Commission guideline C(2026) 2151 final confirms that the harmonised standard EN 13430:2004 may continue to serve as the assessment basis. Note also: CEN has published the EN 18120 series on recycling design for plastic packaging under mandate M/584 (Part 1 released in April 2026, with polymer-specific volumes setting out evaluation procedures for recyclability and sortability), but as the DfR delegated act has not yet been adopted, this series cannot yet serve as a basis for presumption of PPWR conformity.

In addition, Article 5(4) carries over the requirement of Article 11 of 94/62/EC: the combined concentration of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr(VI)) in packaging or packaging components must not exceed 100 mg/kg. Recyclability assessments must therefore always be accompanied by heavy-metal testing.

II. China: GB/T 48042-2026 Fills the Standards Gap

Published on 30 July 2026 and effective from 1 February 2027, GB/T 48042-2026 is China’s first national standard for assessing the “easy-to-recycle, easy-to-regenerate” (“dual-easy”) design of plastic products. It applies to plastic products (including packaging and components), but not to degradable plastics, nor to plastic waste classified as hazardous after disposal and unsuitable for resource recovery.

The standard was led by the China Plastics Processing Industry Association and the China National Resources Recycling Association and jointly drafted by 35 organisations including Mengniu, Dow, P&G, PepsiCo, SF Express and Meituan. It establishes a two-tier quantitative indicator system: five first-tier indicators — main components, auxiliary components, recycling and sorting, regeneration and utilisation, and environmental friendliness & safety — are broken down into second-tier indicators and scored item by item under (normative) Annex A; weights are determined under Clause 6.2, scores calculated under Clause 6.3, and results determined under Chapter 7. Normative references include GB 38507 (ink VOCs), GB 33372 (adhesive VOCs), GB/T 38295 (limits for Pb, Cd, Cr(VI) and Hg) and SN/T 2928.1-2011, while Annex B provides a recommended materials table for direct comparison in material selection. Supporting evidence may come from corporate self-assessment or be issued by a third-party body.

The standard is currently voluntary, but its indicator system closely mirrors the PPWR’s “design for recycling” philosophy and is expected to be progressively referenced by green public procurement, EPR and other policies — its shift from “recommendation” to “threshold” is only a matter of time.

III. Other Markets and Materials: Different Systems Apply

Beyond the EU and China, the UK, South Korea, California and other jurisdictions have also established their own recyclability assessment systems, most of them directly tied to EPR fees or market access. Moreover, assessment methods are strongly material-dependent — plastics and paper-based packaging follow entirely different technical routes. If your packaging is sold into multiple markets, the table below can serve as a compliance planning reference:

Material Note | The table above is largely based on weight-based recyclability rates for plastic packaging; paper-based packaging generally follows a laboratory repulping route (pulping → screening → handsheet formation → stickies measurement). The mainstream EU approach is the CEPI Harmonised European Laboratory Test Method (currently Version 3, published in February 2025, with an accompanying 4evergreen assessment protocol supplementing EN 13430 for paper-based materials); China’s counterpart is GB/T 43588-2023, Test Method for Recyclability of Paper, Paperboard and Paper Products (effective 1 July 2024; Method A applies to packaging paper and paperboard products, Method B to printed or unprinted paper products, and neither applies to nappies, sanitary towels and similar products). The same packaging tested under different methods may yield inconsistent conclusions.

Compliance Note | California’s SB 343 and SB 54 are currently under legal challenge, with enforcement of some provisions stalled — always refer to the latest official status; the unified PPWR recyclability test method is expected to be clarified only once secondary legislation is adopted, and no single officially designated method exists yet; the RecyClass rating widely used by European industry has been revised in line with the PPWR, dropping D / E / F and retaining only Grades A / B / C (≥95 / 80 / 70%), but it remains a voluntary self-assessment and does not constitute official EU proof of compliance; North America’s APR Design® Guide and ISO 18604:2013 (to be used together with ISO 18601) are voluntary methodologies frequently cited as technical bases by the regulations above; Canadian EPR advances through provincial legislation, with no nationwide recyclability assessment methodology as yet.

IV. Putting Assessment into Practice in Six Steps: From Sample Submission to Report

Recyclability assessment is not a case of “send a sample and wait for the result”, but a closed loop of “define the system → build the BOM → assess the design → conduct testing → calculate the grade → improve the design”. The process below works for both EU export and domestic compliance — only the first step varies according to the target market:

Efficiency Tips | Dark colours and carbon black (undetectable by NIR), PVC, inseparable multi-layer laminates, main and auxiliary components made of different and hard-to-separate materials, and non-washable inks and adhesives are the five most common score-reducers — all issues that are cheapest to fix at the design stage and most expensive to remedy after mass production. In addition, any change of material, supplier or structure should trigger re-assessment.

Common test items and pass criteria for Step ④:

Final report outputs: recyclability rate (weight-based calculation) + recyclability performance grade (A / B / C) + EN 13430:2004 conformity conclusion (with ongoing follow-up of the EN 18120 series) + improvement recommendations for non-conformities.

V. Why Choose CIRS TESTING?

A dual evidence chain of “assessment + testing” Most providers offer only desk-based “assessment” unsupported by measured data. Beyond the assessment framework (functional unit definition → system boundary delineation → item-by-item evaluation → recyclability calculation → grade determination), CIRS adds laboratory test data (heavy metals, composition analysis, etc.) and issues conclusions under the ILAC-G8 decision rules; every assessment conclusion is tagged with both “document review” and “laboratory testing” as evidence sources, forming a complete evidence chain.

Dual-track capability across Chinese and European standards CIRS commands both assessment systems:

The international background of CIRS Group Founded in 2007, CIRS Group brings 19 years of testing and compliance experience, with branches in Ireland, the USA, the UK, South Korea, Japan and multiple Chinese cities. CIRS TESTING holds CMA & CNAS dual accreditations, operates a 10,000+ m² laboratory equipped with precision instruments such as LC-MS/MS, GC-MS and ICP, and has served 30,000+ domestic and international enterprises across e-commerce, food contact, electrical & electronics, and cosmetics & personal care sectors. Full-chain PPWR compliance support is available: recyclability assessment + heavy metal and restricted substance testing + technical documentation + DoC + EPR + Authorised Representative (AR).