The European Commission Joint Research Centre (JRC) published in January a technical proposal on harmonised waste sorting labels under the new Packaging and Packaging Waste Regulation (PPWR). While, according to Packaging Europe, the European platform on packaging, the proposed symbols prioritise the use of pictograms with text and colour and thus, representing a burden to harmonisation.
What the EU PPWR says on recycling symbols
Article 12 of the EU PPWR specifies that packaging shall provide information on its material to facilitate waste sorting. This provision applies from 12 August 2028 or 24 months from the date of entry into force of the implementing acts. In particular, the label (on both packaging and on receptacles) should be:
- harmonised on the Union market
- based on pictograms
- easily understandable, including for persons with disabilities
Interestingly, the PPWR mitigates obstacles across different EU countries by mandating harmonised labels based on pictograms indicating material composition, rather than national sorting destinations.
For compostable packaging as well as for packaging subject to deposit and return systems, additional provisions apply.
- Labels of compostable packaging (Article 9) have to indicate that the material is compostable, suitable for home composting, and that compostable packaging is not to be discarded in nature.
- Packaging subject to deposit and return systems (Article 12) has to be marked with a clear label and, in addition to the national label, may be marked with a harmonised colour label. However, this harmonised colour label may not lead to trade barriers for products from other Member States.
Lastly, from 12 February 2029 (or 30 months from the date of entry into force of the implementing act) reusable packaging has to bear a label informing consumers that the packaging is reusable.
JRC proposes symbols with text and colours
The JRC report proposes harmonised waste-sorting labels which include text and colour:
Packaging Europe criticizes the proposed symbols, highlighting that this system would require translation into national languages and the adaptation of production processes. According to the organisation, this undermines the objective of a having a system that seamlessly work across the Single Market.
Current regulations on recycling symbols in the EU
Currently, recycling symbols are not harmonised yet and Member States can implement their own rules.
More on the topic:
Are recycling symbols mandatory in the EU?
Industry position on harmonised waste-sorting labels
France referred to the Court of Justice for Triman logo
Triman logo: European Commission refers France to the EU Court of Justice
For guidance on recycling symbols or other product compliance matters, contact us here.
References:
Packaging Europe (2026). Packaging Labelling: the Test Case for a Truly Harmonized Single Market. Retrieved on 23/02/2026.
European Commission (2026). JRC technical proposal on EU harmonised waste sorting labels under the packaging and packaging waste regulation. Retrieved on 23/02/2026.
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