The Packaging and Packaging Waste Regulation (PPWR) is fundamentally changing what must — and may no longer — appear on packaging. Two changes are already coming your way in the short term. Not everything is set in stone yet, but what we know today partly determines the choices you'd be wise to make now when reprinting.
Green Dot Transition
The iconic Green Dot logo, which currently indicates that a manufacturer contributes financially to an EPR (extended producer responsibility) scheme, may no longer be used as such on packaging from 12.02.2027. In Belgium, Fost Plus is the licensee of the Green Dot logo for household packaging, which means that its members are authorised to use the logo. As a result of the European ban, the Fost Plus Board of Directors has decided to terminate the licence agreement with ProEurope. In view of the notice period, Fost Plus members are contractually in order until the legal deadline of 12.02.2027. The contracts with members will be amended accordingly.
At the same time, the PPWR provides an alternative: "Such (EPR scheme contribution) identification shall be achieved only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology".
Although ProEurope provides such a QR code with its Green Dot logo embedded, called the DigiDot, Fost Plus – like some of the EPR organisations in our neighbouring countries – will not be taking out a licence for it. We are working in partnership with the standards body GS1. GS1 is developing the successor to the traditional barcode. This should make it possible to incorporate all functionalities into a single digital tag, so that no additional QR codes are required on the label.
GS1 investigates how the digital marker can contain the right information In accordance with the PPWR, such as
- The presence of substances of concern in the packaging (from 12.08.2028)
- The proportion of recycled material in the packaging (from 12.08.2028)
- Information on collection points for reusable packaging (from 12.02.2029)
The producer’s membership of a recognised EPR organisation (from 12.02.2027) can eventually be incorporated into the digital marker.
Members who still wish to use the DigiDot must enter into an agreement with ProEurope themselves.
What needs to be labelled?
From 12.08.2028, packaging placed on the EU market must carry a harmonised label indicating the material (plastic, aluminium, paper/cardboard, glass). A number of types are exempt, including transport packaging (except for e-commerce) and packaging covered by a deposit-return system.
In addition, further requirements apply:
- Compostable packaging receives a label indicating that it is compostable, and does not belong in nature.
- Reusable packaging receives a reusability label plus a digital data carrier with information on the reuse system and nearby collection points.
- Claims about recycled or bio-based content must follow a future harmonised format and methodology (to be adopted by 2026).
All labels must be clearly visible, legible and durable, and must appear directly on the packaging. For very small items, the information may be provided on the grouped packaging or via a digital code. That same information must also be available online before purchase, including in e-commerce.
Towards European sorting pictograms
To help consumers sort, sorting instructions in pictogram form will appear on the packaging. The same pictograms will appear on the waste receptacles, so that sorting also works across borders. The definitive pictograms and any colour code will be laid down in an implementing act, scheduled for 12.08.2026. Fost Plus had a seat at the table in the JRC working groups that prepared these labels and is closely following the further process.
In Belgium, the blue PMD bag is a fixture in every household. A change of colour would risk a major impact on recognisability, sorting behaviour and therefore collection rates. "Colour is a powerful communication tool, but it must remain possible to use neutral or colourless labels, so that we don't lose the recognisability the blue bag has built up over the years," says Adriaan Lowet, Brand Strategy & Campaign Manager at Fost Plus. Belgium therefore advocates the option of applying pictograms in black and white. Fost Plus also points to the practical challenge of fitting text in the three official national languages onto every packaging format.
That concern is more widely shared: a coalition of European sector federations warned the Commission that overly prescriptive labels, heavily based on colour and multilingual text, could in fact cause new fragmentation and consumer confusion. Read the full joint statement.
The waste receptacles too
Bins, collection containers and bags for separate collection will receive the same pictograms as the packaging they are intended for — with multiple pictograms where several materials are collected together. Only receptacles for deposit-return systems are exempt. Important for members: through the EPR fees, producers help bear the cost of labelling and adapting this local collection infrastructure. Reusable packaging and packaging covered by a deposit each receive their own specific harmonised label.
How much time do you have?
After the implementing act is published (scheduled for 12.08.2026), you have two years to apply the labels, plus a further three years to keep selling products with the old packaging. So there is a transition period — but the direction is set.
Our advice: be careful with print runs when reprinting until all provisions are anchored. We don't yet have all the details to definitively adjust labels, and we understand this creates uncertainty. For specific questions about the provisions on labels, you can contact your sector federation. We will keep you informed about the development of the GS1 barcode.