PPWR harmonised labels: Technical proposal by the Joint Research Centre (JRC)
Is this the most exciting news of the year so far? We believe so! Published by the Joint Research Centre (JRC) on Tuesday 13 January 2026, we now have the first look at the technical proposal for harmonised packaging labels for PPWR.
A 247-page technical proposal isn’t for everyone, so we have pulled out the key takeaways to consider while we wait for the final stance later this year.
I only supply packaging in the UK. How will this affect me?
In the original draft of the UK’s Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, there was the inclusion of mandatory recycling labelling. Due to Northern Ireland being obligated under the EU’s PPWR (Packaging and Packaging Waste Regulations) and the labelling requirements within, mandatory labelling was ultimately removed from the UK regulation. This will be introduced at a later date to align with the PPWR and avoid unnecessary trade barriers and costs.
We are expecting the UK Government to assess this guidance and consult on UK labelling later in 2026, with the aim of reintroducing mandatory labelling into the UK regulations. In the present political climate, we expect a harmonisation across the UK and EU. With potential packaging design changes and lead times, it is therefore worth UK businesses being aware of the requirements and potential design changes to make sure everything runs smoothly once the EU and UK come to final decisions on labelling requirements.
Key takeaways and considerations
Overview of the labels
Here (Figures ES 1) we have the proposal laid out by the JRC for harmonised labels under PPWR. The labels are available in colour (JRC’s preferred option), or in monochrome and with text (preferred) or without text. This gives producers flexibility with different packaging materials, colours, sizes and styles where colour and text might not be suitable.
Figure 37 shows variations of the labels in colour and in opaque and transparent black/white and white/black.
Due to inclusion of text on the labels, there is also the need to either have multiple packaging versions for each Member State that a producer sells into or have dual language text as shown in Figure 24.
These labels will be reflected in the labels applied to waste receptacles, with the ‘meta-labels’ being available for receptacle labelling to denote multi-material co-collection where necessary (Figure 16).
This should deliver an easy game of symbol matching across all EU Member States (Figure 12).
Label placement and extra information
For packaging formats with multiple components, there were a couple of options presented to the research participants (Figure 28).
Findings from the research revealed a difference of thought between products, expressing concerns about:
- limited space and practicality of labelling individual components, and
- consumers who preferred labels to be linked explicitly to each component.
Therefore, the JRC proposes flexibility to allow producers to choose from the three labelling approaches, with a preference to Figure 28b and 28c. This stands in contrast to what we currently see in the UK which more closely resembles Figure 28a.
There is a proposed option for additional information alongside the label to help consumers correctly identify and dispose of packaging in accordance with local sorting rules.
Examples of ancillary information include:
- “separate before sorting”,
- “clean before sorting”,
- the mandatory “do not throw in nature” label for compostable packaging.
Proposals for this additional information is laid out in Figure 23, where we can see two format examples.
The regulations require that compostable packaging must be labelled to indicate it is compostable, along with information that compostable packaging must not be discarded in nature. Figure 31 outlines the proposal for this additional information, though the JRC does note that since the principle of matching packaging and waste receptacle labels (previously in Figure 12) communicates correct disposal behaviour, the need for this additional information label is open to discussion when finalising the labelling in the implementing act.
QR codes
In the regulations, there is also the requirement for supplementary information to be provided through a QR code or other digital carrier to ensure a consistent and accessible approach across the EU (Figure 30).
When looking at packaging redesign and space to place labels, this QR code and other ancillary information is something that you will need to consider. Though in circumstances where the nature or size of the packaging doesn’t allow for labelling, the relevant labels can be placed on ‘grouped’ packaging, e.g., the outer packaging containing many sales units to supply to a consumer such as a multipack box containing beverage cans or snack bars, and where that isn’t suitable, then the information should still be accessible via a QR code.
To recap, we’ve run through:
- What the labels look like and their variations
- How they relate to labels waste receptacles
- Label placement for packaging with multiple components
- And ancillary information and QR codes
Additional technical points to note
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The hazardous waste symbol is to be used in addition to the material label and not a replacement to it as the label does not refer to a material, but to a characteristic of the packaging. |
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The residual waste symbol differs from the other labels in that it represents a destination instead of a material. While the PPWR requires all packaging to be recyclable by 2030, differing recycling systems and capabilities across Member States may create inconsistencies in the meantime, meaning a material recyclable in one country may not be recyclable in another. If you look to the UK, we don’t currently have the recycling infrastructure for materials such as cork, so questions remain as to whether this material receives a cork material label, residual label, or both. |
If you’re wondering why there are three different fibre-based composite (FBC) labels, the proposal (above) includes a design for beverage cartons, and then a separate design for both FBC A (85-95% fibre) and FBC B (50-85% fibre) which should aid sortation and collection due to the different complexities of FBC recycling.
And finally, Figure 62 outlines where there is a difference in material categorisation between Member States, such as fibre limits and categorisation of FBC packaging. This also links back to packaging which may be treated as recyclable in one country but residual waste in another.
Final thoughts
This is a technical proposal from the JRC; however, this journey is far from complete. As you can see, there are still issues and decisions to debate before we see a final consensus, especially in the UK. The key takeaway is that these labels are coming, and businesses will need to allocate space on their packaging to accommodate them. For those supplying into multiple Member States, additional considerations apply, such as whether to use separate packaging for each State or multilingual packaging/labels.
With a range of regulatory changes abound and the related costs involved in that, fortune really favours the prepared.
As the environmental landscape continues to change, keeping abreast of legislative change is a challenge. However, Beyondly remains a proactive and trusted partner, guiding businesses through times of change and uncertainty.
From PPWR readiness assessments, to packaging screening and analysis; our team of compliance, packaging and data experts are here to help you navigate the complexities and prepare as the legislation evolves. Take a look at our expert solution to PPWR readiness and get in touch with our friendly team at [email protected] or 01756 794951 to discover how Beyondly can support you on your journey to PPWR compliance.
Source: All images are from the JRC proposal document and reused under a Creative Commons licence. You can download the full proposal on the Europa.eu website here, in multiple languages.
