Grade B and Grade C: The Middle of the Scale, and C's Expiry Date
B (80-94 percent) is the long-term home of well-designed complex packaging. C (70-79) is legal from 2030 and gone from 2038. Who lives at each grade, what it costs per year, and how to plan the C exit.
The short answer
Grade B - 80 to 94 percent recyclable - is where good complex packaging lands: units with a sound main material and real-world complications, a pump dispenser on a mono bottle, a board pack with a plastic window, a laminate whose layers the criteria partially credit. Grade C - 70 to 79 percent - is the concession tier: lawful from 2030, charged the highest fees of any lawful grade, and abolished from 1 January 2038, when the floor rises to B. A C-grade unit placed in the early 2030s is therefore a product with a known legal expiry inside a normal design life.
The strategy follows directly: design to B as the floor, hold C only for existing lines with an exit plan, and never tool a new C without a dated route out of it.
Who lives at B, and why B is respectable
B's population is the honest complexity of packaging: barrier needs that require a second material, dispensing functions that need springs and seals, safety closures, portion formats. The criteria are built to recognise partial recyclability rather than demand purity, and B is the grade that recognition produces when the design is disciplined - the main material dominant, the additions separable or tolerated, the disruptions avoided. Brands should resist reading B as failure. In fees it sits one step from the best price; in law it has no expiry; in the at-scale era it will describe most of what actually recycles. The design conversation B deserves is optimisation at the margins - a label adhesive changed, a window removed, a spring made separable - each worth points and occasionally a grade boundary.
C's economics: the annual meter
C's problem is not only its 2038 expiry; it is the meter running until then. Eco-modulated fees place C at the expensive end of lawful grades each year, and retail scorecards increasingly treat C as a listing conversation. A line held at C for the full 2030-2038 window pays eight years of premium fees plus a forced redesign at the end, against the single redesign cost of moving early. The exit analysis should therefore be run per line with real numbers - fee differential, volume trend, tooling age - because for declining lines near tooling end-of-life, riding C to a planned discontinuation can be the rational course, while for growing lines it almost never is. The error is not holding C; it is holding C unexamined.
Planning the C exit
A C exit plan has three elements. The diagnosis: which features cost the points between this unit and B - from the assessment's sensitivity list, ranked by cost to fix. The trigger: the commercial event the redesign rides on (retooling, relaunch, supplier change, range review), because redesigns attached to scheduled events cost a fraction of standalone projects. And the backstop date: the last responsible moment to execute, worked back from January 2038 through tooling and stock run-out, which for slow cycles lands in the mid-2030s - closer than the headline year suggests. Lines whose sum of the three elements shows no viable route to B are exit candidates themselves, and learning that in 2027 is a gift the assessment was designed to give.
How B and C read in the market before 2030
The market is grading ahead of the law. Retail scorecards in several states already request recyclability evaluations by recognised protocols, and brand sustainability reporting converts them into portfolio percentages. A range that will sit at B and C in 2030 is therefore visible, in draft, to its largest customers by 2027 or so. The commercial management of the middle grades is consequently a communications task as much as an engineering one: know the portfolio's grade distribution before your customers present it to you, hold the sensitivity lists for the C population, and be able to say - per line - whether the position is a decision (priced, planned, exiting on schedule) or a discovery. Customers forgive grades; they do not forgive surprises.
Primary sources on the record
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Official Journal text on EUR-Lex.
- European Commission, packaging waste topic page - guidance and act progress.
- European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, text on EUR-Lex - the directive the PPWR repeals and replaces.
Legal status: Article 6 of Regulation (EU) 2025/40; design-for-recycling criteria by delegated acts due by 1 January 2028. Application position for this topic: B and C lawful from the grading date; C removed from 1 January 2038.