The new Packaging and Packaging Waste Regulation (PPWR) doesn’t just set new rules for packaging design and recyclability. It also introduces a harmonised labelling system for both packaging and waste receptacles — a long-awaited step to eliminate the fragmented national systems that often confuse consumers and complicate compliance for companies operating across borders.
Under Articles 12 and 13, packaging will carry a standardised label indicating its material composition, while bins, containers and collection bags for packaging waste will carry matching pictograms. The objective is simple: make sorting easier and more consistent across the EU, and lay the foundation for better recycling performance.
Technical basis in the works
To implement this system, the European Commission has tasked its scientific arm — the Joint Research Centre (JRC) — with preparing the technical basis. Since 2024, the JRC has been developing the visual identity, application rules, and technical details of the new labels, with ongoing consultation of stakeholders across Europe.
The approach builds on the Nordic pictogram scheme, which uses harmonised colours, icons, and layout standards. These elements were tested through public surveys, expert consultations and workshops across the EU. Fost Plus actively participated, ensuring Belgium’s high-performing system was represented in the design discussions.
The second round of stakeholder consultations closed in June 2025. A final recommendation should be transmitted to DG Environment during the summer, with an Implementing Act expected in autumn 2025.
At the latest by 12 August 2026, the European Commission shall publish the final design of these labels and the technical specifications. Once adopted, economic operators will have two years to start applying them — and an additional three years to sell through packaging that does not yet carry the new label.
What needs to be labelled?
Starting from August 2028, most packaging placed on the EU market will be required to carry a harmonised pictogram showing what material it’s made from — such as plastic, aluminium, paper/cardboard, or glass. Some packaging types are exempt from this obligation, including transport packaging (except for e-commerce) and packaging under a deposit and return system (DRS).
But the new labelling rules don’t stop there. Several additional requirements apply under Article 12:
• Compostable packaging must include a label stating that it is compostable, that it is not suitable for home composting, and that it should not be discarded in nature.
• Reusable packaging must bear a reusability label and include a QR code or digital data carrier with information about the applicable reuse system (local, national or EU-wide), nearby collection points, and — if feasible — trip or rotation counts (or an average estimate).
• Claims about recycled content or biobased plastic content must follow a future harmonised format and methodology (to be adopted by 2026).
• Packaging that contains substances of concern will need to include a digital identifier indicating the name and concentration of the substances in each material layer. This rule enters into force from January 2030.
All required labels must be clearly visible, legible, and durable, affixed directly to the packaging. Where this isn’t feasible (for example, with very small items), the information may appear on grouped packaging or via a single digital code. The same information must also be accessible online before purchase, including in e-commerce settings.
Bins, containers and collection bags
To support the new system, waste receptacles — including public bins, private collection containers, and bags used for separate packaging waste collection — must display the same pictograms as the packaging they are intended to receive.
These labels must be clearly visible, legible and indelible, and may include more than one pictogram if multiple materials are collected together. Only receptacles used for deposit and return systems are exempt.
The Commission will define the technical specifications for bin and bag labelling in its upcoming Implementing Act (expected by August 2026). Member States must ensure that these requirements are in place by August 2028 or within 30 months of adoption, whichever is later.
Under the PPWR’s expanded extended producer responsibility (EPR) rules, the cost of labelling bins, containers and collection bags will be borne by producers. In other words, through the fees they pay to EPR schemes, producers will help fund the adaptation of local collection infrastructure to align with the new labelling system.
Industry reaction: risk of fragmentation
While industry players broadly support the idea of EU-wide labelling, the direction taken by the JRC design proposals has raised concern across the value chain. A coalition of 70 European associations recently issued a joint statement urging the Commission to reconsider key elements of the approach.
Their main concern: the proposed system’s heavy reliance on colours and multilingual text could actually lead to new market fragmentation, impose design burdens, and confuse consumers — especially if local flexibility is not allowed. Under Article 12, harmonised labelling is meant to simplify the landscape, but overly prescriptive visual requirements could undermine this goal.
Fost Plus perspective
Fost Plus supports the principle of European harmonisation to improve consumer clarity and ensure a well-functioning internal market. At the same time, it warns that the system must allow for practical implementation at national level.
Belgium’s blue PMD bag is one of the most recognisable and effective waste collection tools in Europe. “A sudden change in colour or visual identity could create confusion and weaken consumer motivation in the short term,” says Adriaan Lowet, Product & Campaigns Manager at Fost Plus, who represented Belgium in the JRC working groups. “Colour is a strong way to communicate, but it should still be possible to use neutral or colourless labels — so we don’t lose the clear recognition that systems like the blue bag have built over time.”
Fost Plus also highlights the challenge of including text on packaging in Belgium’s three official languages. While this may be manageable on bins or containers, applying the same requirement to all packaging formats is often impractical — especially where space is limited.
What does this mean for your business?
Whether you’re a brand owner, importer, distributor or packaging supplier, the implications are clear: packaging designs will need to be updated, digital systems developed, and product portfolios reviewed. Harmonised labels and QR codes must be implemented in line with EU requirements, and all claims about reuse or recycled content must follow standardised formats.
Need support in navigating the new labelling requirements?
Fost Plus offers guidance, tools, and strategic advice to help you stay compliant — and make this transition work for your business, your customers, and the environment. Contact our Customer Service or your account manager for more information.