Packaging labelling under the PPWR – new recycling and sorting symbols

The labelling of PPWR packaging is intended to standardise the way in which consumers are informed about how to sort packaging waste correctly across the European Union. The new regulations provide for harmonised pictograms on packaging and corresponding markings on waste collection bins, bags or containers. The European Commission points out that the PPWR is intended to lead to new labels providing clear information on how to sort waste so that it can be reused in the manufacture of new products.

For businesses, this means they will need to organise their labels, graphic designs, material data, supplier documentation and environmental procedures. It is not enough simply to add a random recycling symbol. The labelling will have to correspond to the actual composition of the packaging and the future EU format for pictograms.

Why is PPWR changing the labelling on its packaging?

Until now, packaging labelling in Europe has been fragmented. Companies operating in several markets have had to take into account national labelling systems, different sorting instructions and varying expectations from recycling organisations. For consumers, this meant confusion: different symbols in France, different ones in Italy, different ones in Poland, and yet others on imported products.

The PPWR is intended to reduce this fragmentation. The aim is to establish a system in which consumers see consistent labelling on packaging and corresponding labelling on waste bins. In January 2026, the European Commission’s Joint Research Centre (JRC) published a technical proposal for harmonised waste sorting labels for packaging and containers in the EU; this work is intended to support future implementing acts for Articles 12 and 13 of the PPWR.

The new PPWR labelling is intended to shift the decision on waste sorting from relying on consumers’ guesswork to clear, consistent instructions visible on the packaging and container.

What will be labelled in accordance with the PPWR?

The new system is primarily intended to cover consumer packaging, as well as bins, bags or containers used for the collection of packaging waste. Industry and implementation sources indicate that the standardised labels are to be based on the material composition of the packaging and are designed to assist with sorting into the correct waste stream, such as paper, plastics, glass or metal.

In practice, labelling may relate to, amongst other things:

– paper and cardboard packaging,
– plastic packaging,
– glass containers,
– metal packaging,
– multi-material packaging,
– compostable packaging,
– reusable packaging,
– e-commerce packaging,
– bins, bags and containers for the collection of packaging waste.

However, the final pictograms should not be designed on the basis of conjecture. The specific formats, colours, layout and rules for use will be set out in implementing acts and official specifications.

When will the new recycling and waste sorting symbols become mandatory?

The PPWR came into force in February 2025 and, in principle, will apply from 12 August 2026. However, the requirements for harmonised labelling have separate transition periods. Industry implementation guidelines indicate that, from 12 August 2028, packaging placed on the EU market must bear harmonised material labelling, with exceptions including, amongst others, parts of transport packaging and packaging covered by a deposit-refund scheme.

In practice, companies should approach the schedule in three stages:

Stage	What does this mean for the company?
2026	Preparation of data, procedures, responsibilities and label checks
2027–2028	Updating graphic designs following the publication of the final specifications
from 2028/2029	The use of harmonised markings in accordance with the PPWR and its implementing acts

Key takeaway: companies should not wait until the final quarter before the requirement comes into force. Changing labels may require approvals, print tests, packaging updates, the use up of stock, and coordination with B2B customers.

Will the new pictograms replace the national symbols?

Ultimately, the PPWR aims to reduce the fragmentation of national labelling systems and create a coherent EU-wide system. The European Commission emphasises that the new labels are intended to help citizens and tourists sort packaging waste correctly across the EU.

This is very important for exporting companies. Nowadays, packaging sold in several countries often has to comply with various local labelling requirements. Harmonisation is intended to reduce barriers and minimise the need to produce multiple versions of labels.

This does not, however, mean that all local differences in waste management practices will disappear immediately. The collection system in individual countries may still have national elements, but the label on the packaging is intended to guide consumers in a more consistent manner.

Companies selling products outside Poland should combine their analysis of labelling with compliance with packaging obligations in EU markets, as the PPWR does not automatically override national EPR, registration and reporting obligations.

How to label PPWR packaging – a practical guide

At this stage, the safest approach is to prepare the company to label products based on data rather than graphics. The final pictograms will be finalised, but the company should already know what material is actually contained in the packaging.

1. Determine the material composition of the packaging

The first step is to determine what the packaging is made of. This applies not only to the main material, but also to labels, closures, adhesives, coatings, inserts, windows and additional security features.

Example: a box may be described as being made of paper, but if it contains a plastic window, laminate and permanent adhesive, its labelling should not oversimplify its actual composition.

2. Determine the waste stream

The pictogram is intended to help consumers dispose of packaging in the correct bin. To do this, the company must determine which waste stream is appropriate for the packaging in question or its components.

3. Check whether the pack contains several components

If packaging consists of several components, it may require more detailed instructions. Example: a glass jar, a metal cap and a paper label should not be treated as a single, homogeneous material.

4. Check whether it can be recycled

The sorting label does not replace an assessment of recyclability. Packaging may be correctly labelled for a specific waste stream, but may still pose problems from a ‘Design for Recycling’ perspective if it contains difficult-to-recycle coatings, laminates or adhesives.

In such cases, it is worth combining the signage inspection with PPWR audit and analysis multi-material packaging.

Labelling of multi-material packaging

Multi-material packaging will be one of the most challenging areas. Consumers need clear instructions, but companies must base these on the actual composition of the product and how its components can be separated.

The greatest risk relates to packaging such as:

– a cardboard box with a plastic window,
– a paper tray with a plastic barrier,
– paper-plastic laminates,
– packaging combining aluminium and plastic,
– doypack bags, sachets and multilayer packaging,
– tubes made from several different types of material.

In such cases, labelling should be based on a technical assessment rather than the material’s marketing name. If the packaging looks like paper but behaves like a composite during recycling, incorrect labelling may mislead the consumer.

The greatest risk with PPWR labelling will be a simple statement on the packaging that does not correspond to the product’s complex material composition.

Labelling of e-commerce packaging

E-commerce businesses should analyse not only the product packaging but also the shipping packaging: cardboard boxes, envelopes, tape, courier labels, plastic film, void-fill material and return packaging. The PPWR also covers e-commerce packaging, and the Commission’s technical guidance indicates that harmonised sorting labelling applies to e-commerce, although it excludes certain transport packaging and packaging covered by a deposit-refund scheme.

An online shop should check:

– are the cardboard box and the filling material labelled consistently,
– do the tapes and labels make recycling more difficult,
– does the customer know how to separate the components,
– do returnable containers come with clear instructions,
– whether the data on materials is consistent with the BDO and EPR,
– Do overseas sales require any additional information?.

In this area, it is worth combining signage with e-commerce audit and analysis Packaging in e-commerce: BDO and LUCID.

Labelling of reusable packaging

Reusable packaging will need to be clearly labelled as intended for reuse. Industry sources indicate that reusable packaging is to be given a special label and a digital data carrier, such as a QR code, containing information about the reuse scheme and collection points.

For businesses, this means that it is not enough simply to write „reusable packaging”. They need to have a system in place for returns, cleaning, quality control, refilling, tracking and informing the user.

If a company implements refill or reuse models, it should combine labelling with analysis circular economy, as the label will be merely the visible part of the entire operating system.

Labelling of compostable packaging

Compostable packaging requires particular care. Consumers often confuse the terms „biodegradable”, „compostable”, „bio” and „eco-friendly”. Incorrect labelling can lead to packaging being disposed of in the wrong bin or to littering the environment.

Implementation guidelines for the PPWR indicate that compostable packaging is to be labelled with information on its compostability, alongside a message stating that it should not be released into the natural environment.

In practice, the company should check:

– whether the packaging is suitable for industrial or home composting,
– whether they have the relevant supporting documents,
– does the local collection scheme accept this type of material,
– doesn’t the message suggest that the packaging can be discarded in the environment,
– isn’t the use of the word „organic” misleading?.

Is a QR code enough to replace a label?

QR codes and other digital data carriers will be an important part of the PPWR, but it should not be assumed that they will replace all printed labelling. Studies on labelling requirements indicate that some information may be provided digitally, but certain information and symbols will still need to be physically displayed on the packaging.

The safest rule is this: a QR code may supplement the labelling, but should not be treated as the default alternative to the mandatory pictogram until the final implementing acts set out the precise rules.

A QR code can be particularly useful for:

– reusable packaging,
– information about the refund system,
– user manual,
– information on recycled content, if declared,
– documentation for B2B clients,
– multilingual information.

What should you avoid doing on recycling labels?

The greatest risk associated with PPWR relates not only to the absence of labelling, but also to misleading labelling. Implementation sources indicate that the PPWR restricts the use of labels, marks or symbols that could mislead users as to the environmental characteristics of the packaging.

Companies should avoid:

– general „eco” terms without any explanation,
– symbols suggesting recycling, where the packaging is difficult to recycle,
– the use of multiple competing trademarks on a single label,
– instructions that do not correspond to the actual contents,
– the „100% recyclable” declaration, which has no technical basis,
– national designations that may conflict with the future EU system,
– graphics suggesting compostability without certification,
– information on recycled material without confirmation of its proportion or source.

A recycling label is not the place for wishful marketing messages. In the PPWR, labelling must be consistent with the material, the documentation and the actual method of waste management.

How can you prepare your business for the new PPWR labelling scheme?

It is best to start by organising the data before the final pictograms are incorporated into the graphic designs.

1. Carry out an inventory of packaging

The company should compile a list of all packaging types: unit packaging, bulk packaging, transport packaging, e-commerce packaging, returnable packaging and promotional packaging. For each type of packaging, the material, components, sales market and current labelling must be specified.

2. Check the material documentation

Without data from the supplier, it is not possible to label the packaging correctly. We need specifications, the weights of the components, the types of materials, information on recycled content and any coatings.

3. Assess the current labels

It is necessary to check whether the current labelling is contradictory, out of date or misleading. This applies in particular to exported packaging that features several national labelling schemes.

4. Make space in the layout

The new labelling must appear on the packaging in a legible form. It is worth setting aside space for future pictograms now, to avoid a costly redesign of the entire label.

5. Link the labelling to the packaging approval procedure

Any new label should be approved not only by the marketing department, but also by the person responsible for environmental matters, compliance or PPWR.

6. Update your data in BDO and EPR systems

A change in labelling is often due to a change in material, component or supplier. This may affect the data reported in BDO or in foreign EPR systems. In Poland, a good point of reference is an analysis BDO packaging, and in the case of exports EU services.

7. Carry out a pre-print audit of the new labels

The most costly mistake is printing a large batch of packaging with labelling that will need to be changed later. That is why, before updating the labels, it is worth carrying out PPWR audit or wider environmental audit.

Checklist for the marketing and compliance departments

Before approving a new label, it’s worth going through a simple checklist.

1. Do we know the exact composition of the packaging material?
2. Does the label correspond to the actual sorting stream?
3. Does the packaging contain any parts that need to be separated?
4. Are these environmental claims supported by documentation?
5. Do the symbols used conflict with the future EU system?
6. Doesn’t a QR code replace information that should be physically visible?
7. Does packaging sold abroad meet the EPR requirements?
8. Does the layout leave space for future PPWR pictograms?
9. Has the label been checked by the compliance department, and not just by the marketing department?
10. Has the change to the labelling been linked to the BDO documentation and supplier data?

Example: what might the implementation of signage in a company look like?

A cosmetics manufacturer sells its products in Poland, Germany and the Czech Republic. The packaging consists of a plastic bottle, a self-adhesive label, a pump and an individual cardboard box. Prior to the PPWR, the company used several symbols: the recycling symbol, the material code, instructions in Polish and additional markings required by selected markets.

Following the analysis, the company draws up a component map:

– bottle: plastic,
– pump: several components made from different materials,
– label: material and adhesive,
– cardboard box: paper/cardboard,
– protective film: plastic.

On this basis, a new layout can be prepared that will be ready for harmonised PPWR labelling. At the same time, the company recognises that the biggest problem is not the pictogram itself, but the pump and the label — components that also affect recyclability.

Conclusion: the implementation of signage often reveals design issues that the company had not previously identified.

Signage and environmental procedures

PPWR will ensure that packaging labelling becomes part of a company’s environmental procedures. It should not be designed solely by a graphic designer or a branding agency.

The procedure should specify:

– who approves the new packaging,
– who checks the material composition,
– who is in contact with the supplier,
– who assesses environmental labelling,
– who is responsible for BDO and EPR,
– who updates the documentation,
– who keeps track of changes to the regulations,
– who archives versions of labels and declarations.

If a company does not have such a process in place, it is worth making use of comprehensive environmental consultancy for businesses or ongoing environmental management, in order to implement checks on packaging, labels and documentation.

The most common mistakes companies make when labelling packaging

The first mistake is to design a label without knowing the contents of the packaging. The design must not take precedence over the product information.

The second mistake is copying symbols from other markets. Just because a symbol works in France or Italy does not mean it will be compatible with the target PPWR system.

The third mistake is the overuse of general environmental buzzwords. Terms such as „eco”, „organic”, „green”, „environmentally friendly” and similar expressions need to be substantiated.

The fourth mistake is to ignore bulk packaging and e-commerce. Labelling does not apply solely to the packaging visible on the shelf.

The fifth mistake is the lack of a label approval procedure. If the marketing, procurement and compliance departments are not working with the same data, the risk of error increases.

FAQ - Frequently asked questions

Is PPWR introducing new recycling symbols?

Yes. The PPWR is intended to establish a harmonised labelling system to help consumers sort packaging waste. The new labels are to be linked to the markings on waste collection bins or bags.

When will the new packaging labelling become mandatory?

The most commonly cited deadline for harmonised material labelling of packaging is 12 August 2028, subject to the deadlines set out in the implementing acts. Some of the requirements, particularly those relating to reusable packaging, have their own timetable.

Will e-commerce packaging also be labelled?

Yes, e-commerce packaging should be analysed in terms of labelling, material and sorting instructions. The Commission’s technical documents indicate that the harmonised labelling system covers e-commerce, although it excludes certain types of transport packaging and packaging covered by a deposit-refund scheme.

Is a QR code sufficient in place of the symbol on the packaging?

This should not be assumed. A QR code may provide additional information, but some of the labelling will need to be physically displayed on the packaging. The final scope will depend on the implementing acts and the type of information.

How should multi-material packaging be labelled?

First, the actual composition and the feasibility of separating the components must be determined. The labelling should be based on the predominant material, any additional components and the appropriate sorting stream. In the case of composite packaging, it is advisable to carry out a technical assessment before approving the label.

Can we still use our own eco-labels?

Caution is required. The PPWR restricts the use of labelling that could mislead consumers regarding the environmental characteristics of packaging. Proprietary symbols, slogans and claims should be supported by documentation and must not conflict with the harmonised EU system.

Implement the correct environmental procedures with Eko-Pro

Labelling packaging in accordance with the PPWR will not be a simple graphical change. It is a process that requires material data, supplier documentation, label checks, consistency with the BDO and EPR, and an internal packaging approval procedure.

If you want to prepare your company for the new waste sorting pictograms and avoid errors on labels, take a look at PPWR audit, environmental audit or find out our full range of services for businesses. You can also go to the tab Contact Eko-Pro and describe what packaging and labels your company uses.