Harmonisation of Recycling Labelling in the EU

Towards a Unified Circular Economy Framework

The European Union is moving decisively towards harmonising packaging and recycling labelling as part of its ambitious Packaging and Packaging Waste Regulation (PPWR). This regulatory reform aims to simplify and unify how packaging is designed, labelled, and recycled across the 27 Member States — reducing waste, improving recyclability, and creating a truly circular economy for packaging by 2030.

Under the new framework, all packaging must be recyclable by design by 2030, and recyclable at scale by 2035.The European Joint Research Centre (JRC), CEN and ECHA will develop a scoring methodology to classify packaging recyclability into grades A to D, influencing EPR (Extended Producer Responsibility) fees:

• Grade A – fully recyclable

• Grade B – recyclable with some limitations

• Grade C – low recyclability

• Grade D – non-recyclable

By 2028, the Commission will define Design for Recycling (DfR) criteria through a Delegated Act, and by 2030, Member States will need to demonstrate an EU-wide recycling rate above 55% for packaging formats, confirming that recyclability is not just theoretical but proven “at scale”.

Key challenges remain, such as:

• Balancing packaging minimisation with recyclability at scale.

• Ensuring small packaging is captured by sorting processes.

• Developing biobased and chemical recycling technologies with sufficient readiness levels.

• Maintaining product functionality and shelf life, particularly for complex or composite materials.

Harmonised Labelling for Waste Sorting

Perhaps one of the most visible changes for consumers will be the new harmonised labelling system for packaging and waste sorting.The goal is to ensure clear, consistent, and recognisable symbols across the EU, helping citizens dispose of packaging correctly, regardless of where they live or travel.

The Joint Research Centre (JRC) is finalising the study that underpins the system.

The labelling scheme will include:

• Pictograms on packaging and waste receptacles.

• Distinction between coloured labels and black-and-white labels:

  • Coloured versions may be voluntary on packaging, but mandatory on waste bags and bins.

  • Black-and-white versions with no text are an alternative preferred by some industry stakeholders

    
    

    

  

• Use of “meta-labels” on collection bins in case of co-mingled waste systems.

• Specific symbols for composite packaging (e.g., fibre-based materials with plastic layers), separable components, and special categories such as textiles or hazardous waste.

Consumer research conducted by the JRC has shown that sorting performance improves when both colours and text are used, as people recognise colour first and text second.

An Implementing Act for the labelling system is expected to be adopted by 12 August 2026, while a Ramboll study running until July 2026 will support additional labelling areas such as reusable packaging, recycled content, bio-based materials, and digital formats. We help your brand stay compliant with EU packaging regulations and keep ahead of upcoming targets — reach out for tailored support.

Project Process and Stakeholder Engagement

The harmonisation process is extensive and participatory. Between 2024 and 2025, the European Commission will conduct:

• Multiple participatory design workshops with experts and industry.

• Stakeholder consultations and citizen surveys.

• Behavioural experiments (May–June 2025) to validate the effectiveness of proposed labels.

• A final report expected by July 2025, which will inform the Technical Proposal and User Manuals for the harmonised labelling system.

  
  

  

The Visual Identity: Full Label Sets

Two complete sets of labels are being developed:

• A coloured version, where each material stream (paper, plastic, glass, metal, composite, etc.) is represented by a distinct hue.

• An opaque white version, a minimalist alternative designed for universal legibility and high-contrast printing.

Both sets will cover common packaging types and waste streams, including residual and hazardous waste, ensuring comprehensive coverage.

Implementation and Transition

As summarised by the European Commission, the harmonised labelling initiative is not only about improving recycling outcomes but also about providing legal certainty for businesses investing in sustainable packaging systems.Designing detailed secondary legislation remains complex — the Commission must strike a balance between regulatory precision and administrative feasibility.

Stakeholders, including national authorities and industry representatives, will be closely involved through the expanded Waste Expert Group.The European Commission has also pledged to ensure a proportionate and smooth transition, making use of the regulatory empowerments provided under the PPWR.

A Step Towards True Circularity

Wolfgang Trunk highlighted at the Sustainability in Packaging conference in Barcelona in October 2025, that the harmonised recycling labelling system marks a crucial milestone in Europe’s circular economy journey. By ensuring that all packaging is designed for recyclability, made with recycled materials, and labelled consistently for citizens, the EU is building the foundations for a waste-free future, one where sustainability is not a voluntary act, but a harmonised standard across the Member States.