Summary:

The JRC has published a non-binding but influential technical proposal setting out the evidence-based design for EU-wide harmonised, material-based waste-sorting labels under the PPWR, which will inform the Commission’s forthcoming implementing acts expected by August 2026. This will be a major milestone in tackling FESI’s longtime concerns about internal market fragmentation caused by divergent national labelling systems.

More information:

On 13 January, the European Commission’s Joint Research Centre (JRC) published the attached comprehensive technical proposal on EU harmonised waste-sorting labels intended to support the preparation of the forthcoming implementing acts under Articles 12(6) and 13(2) of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR).

The JRC document provides the scientific, technical and behavioural evidence base for the design and implementation of an EU-wide system of harmonised waste-sorting labels for packaging and corresponding waste receptacles. While the proposal is not legally binding, it is explicitly intended to inform the content, structure and technical parameters of the implementing acts that the European Commission is required to adopt under the PPWR.

The proposal develops a material-based EU labelling framework, as required by the PPWR, with the objective of improving consumer sorting behaviour while reducing internal market fragmentation caused by divergent national labelling systems. A major and longtime concern FESI has been addressing at all levels possible. A central design principle is the “matching approach”, whereby the same label appears on packaging and on the corresponding waste receptacle.

From a technical and regulatory perspective, the report sets out detailed guidance on, inter alia:

• the granularity of labels, identifying which packaging materials require distinct labels, including plastics (rigid and flexible), paper and cardboard, glass (by colour), metals, composite packaging, compostable packaging (home and industrial), hazardous packaging and residual waste;
• systemic rules for multi-component and multi-material packaging, including how different components should be identified without undermining consumer clarity;
• the visual and functional parameters of the labelling system, covering pictograms, colour use, text and language requirements, accessibility features, label size and positioning on both packaging and waste receptacles;
• the treatment of special and legally sensitive cases, such as compostability claims, contamination risks and the residual waste stream;
• the interaction with other EU labelling and information obligations, including deposit return schemes, recycled content information, reuse-related labelling and the use of digital information carriers (e.g. QR codes).

The proposal must be seen in the broader political context of the PPWR, which entered into force in February 2025 and forms a key pillar of the EU’s Circular Economy Action Plan. One of the regulation’s core objectives is to remove internal market barriers created by fragmented national labelling schemes, while improving the effectiveness of separate collection and recycling across Member States.

The JRC report clearly signals a top-down harmonisation approach through an EU implementing act, while also acknowledging the political sensitivities and practical challenges involved—particularly the coexistence with existing national systems, the costs of transition, and the need for effective consumer communication and education.

Next steps:

According to the PPWR, the European Commission must adopt the implementing acts on harmonised waste-sorting labels by 12 August 2026. The JRC proposal will serve as a key technical input for DG Environment as it prepares draft implementing measures.

In the coming months, stakeholders can expect:

• internal Commission work on drafting the implementing acts, drawing on the JRC proposal;
• potential targeted consultations or informal stakeholder exchanges as the policy process advances;
• increasing clarity on transition periods, technical specifications and enforcement arrangements as the implementing acts take shape.

FESI will continue to monitor developments closely and keep members informed of relevant policy discussions, consultation opportunities and implications for the sector.

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