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RecyClass announced on 21 July 2026 that it has passed 500 recyclability evaluations. The timing is not incidental: the first PPWR enforcement begins the following month. For packaging buyers the number is less interesting as a milestone than as a signal — a body of comparable, documented assessments of how specific packaging constructions behave in real recycling streams now exists, and it is large enough to argue with.
What was announced
RecyClass chairman Paolo Glerean framed the milestone in terms of knowledge rather than volume: “The more than 500 evaluations conducted by RecyClass have contributed to a better understanding on how to tackle the key challenges of plastic packaging recyclability.”
The organisation positions the achievement as evidence of growing demand for robust scientific data to support recyclable packaging design and to help companies prepare for upcoming regulatory requirements. That framing is worth taking at face value: the evaluations are testing protocols applied to constructions, not a certification of the recycled content in a material.
Why it matters now
PPWR has applied since 12 August 2026. Its design-for-recycling requirement takes effect on 1 January 2030, and the delegated acts setting the criteria are due by 1 January 2028. Between those dates sits an awkward period: the obligation is visible, the criteria are not yet written, and packaging development cycles are long enough that waiting until 2028 to start is not a strategy.
Recyclability assessment schemes fill that gap in practice, if not in law. They do not pre-empt the delegated acts and cannot guarantee alignment with whatever the Commission ultimately adopts. What they do provide is a defensible basis for design decisions taken before the criteria exist — and a documented record showing that the decision was informed rather than arbitrary.
What an evaluation does and does not tell you
Three distinctions are worth holding onto, because they are routinely blurred in supplier presentations.
Recyclability is not recycled content. An evaluation says how well a construction behaves in a recycling stream. It says nothing about how much recycled material that construction contains. The two are separate PPWR obligations and separate lines in a specification.
Recyclability is not waste status. The draft EU end-of-waste criteria for plastics, consulted on until 26 January 2026, address when material ceases to be waste. That is a legal-regime question, unrelated to how a package behaves in a sorting line.
An evaluation describes a construction, not a batch. Change the label adhesive, the barrier layer or the pigment and the assessment may no longer describe what you are buying. This is the most common practical failure: a valid evaluation cited for a product that has since been reformulated.
How to use this in supplier conversations
- Ask which construction the evaluation covers — down to the layer structure, adhesive and decoration — and compare it with the current specification, not the one from the tender.
- Ask when it was carried out. Protocols evolve; an old assessment may reflect superseded test conditions.
- Treat the result as input to design, not as a compliance certificate. The binding criteria will come from the delegated acts due by 1 January 2028.
- Record the reasoning. If a construction is chosen now and criteria change later, the ability to show what was known at the time is worth more than the assessment itself.
The wider context
Five hundred evaluations is a large number for an assessment scheme and a small number relative to the packaging portfolio of the European market. It indicates that the design-for-recycling question has moved from a sustainability topic to a technical one with test protocols behind it — which is the necessary precondition for the 2030 requirement to be enforceable at all.
It also lands in a market where the material side is moving the other way. Circular production growth in Europe fell to 1.2% in 2024 and EU recycling capacity contracted by roughly one million tonnes by the end of 2025. Better-designed packaging is necessary. It is not, on its own, sufficient.
Frequently asked questions
How many recyclability evaluations has RecyClass carried out?
More than 500, as announced on 21 July 2026, weeks before the first PPWR enforcement began in August 2026.
Does a recyclability evaluation prove compliance with PPWR?
No. The design-for-recycling requirement applies from 1 January 2030 and the criteria are to be set in delegated acts due by 1 January 2028. An evaluation is a technical input to design decisions, not a compliance certificate.
Is recyclability the same as recycled content?
No. Recyclability describes how a packaging construction behaves in a recycling stream. Recycled content describes how much recycled material it contains. They are separate obligations under PPWR.
Read next
- Post-consumer recyclate (PCR): what it is and how rPET, rHDPE and rPP are produced
- Food-grade rPET certification: EFSA, FDA, ASTM, ISO
- ISCC PLUS and mass balance: how the system actually works
Sources: Resource Recycling, report of 21 July 2026 on RecyClass passing 500 recyclability evaluations, including the statement by chairman Paolo Glerean; Regulation (EU) 2025/40 (PPWR); Plastics Europe, “The Circular Economy for Plastics 2026”.