The European Commission has missed a deadline to adopt detailed rules for harmonised recycling labels under the EU’s new Packaging and Packaging Waste Regulation (PPWR), prolonging uncertainty for businesses preparing to redesign packaging.
The PPWR required the Commission to adopt implementing acts by 12 August setting out a harmonised label and specifications for labelling requirements and formats, including digital labelling. A separate implementing act establishing a methodology for identifying the material composition of packaging using digital marking technologies was due on the same date.1
The deadline coincided with the date on which the PPWR, Regulation (EU) 2025/40, generally became applicable across the EU. The regulation entered into force in February 2025 and replaces the previous Packaging and Packaging Waste Directive with directly applicable rules intended to reduce packaging waste and improve recyclability.
Under Article 12, packaging will ultimately have to carry a harmonised, pictogram-based label providing information on its material composition to help consumers sort waste. The requirement is due to apply from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
Waste receptacles will also have to carry corresponding labels identifying the material-specific fractions they collect. The Commission was required to establish specifications for these labels by 12 August 2026.
UK recycling labelling organisation OPRL said it did not expect the delay to be lengthy, but since warned that businesses would face a demanding implementation programme once the details were confirmed.
Jude Allan, Managing Director of OPRL, said: “While any delay to the start of implementation leaves brands with a slightly longer period of uncertainty, the timeline – once the Act is announced – still allows two years’ implementation time. Once the EU’s plans are clear, the UK can also move forward with plans for its own mandatory label under pEPR.
“Like many areas of legislation, the final outcome may look simple, but OPRL’s experience over the last 17 years shows how complicated and nuanced the process can be. In the case of PPWR, legislators have had to consider areas like sorting capability across multiple members states, and how to address language issues.”
The European Commission’s June guidance on the PPWR confirmed that the Article 12 labelling regime is intended to be fully harmonised. Once applicable, member states will not be able to retain additional national sorting instructions alongside the EU harmonised labels, except in relation to deposit and return schemes.2
OPRL said the final system is anticipated to follow proposals developed by the European Commission’s Joint Research Centre (JRC), using standardised pictograms to represent material composition, with corresponding symbols on waste receptacles.
The delay also has implications for packaging policy in the UK. Mandatory recycling labelling was removed from the first stage of the UK’s packaging extended producer responsibility (pEPR) regime, in part to avoid imposing requirements that could subsequently conflict with EU rules. OPRL says Defra has previously indicated that it would consider options for mandatory UK labelling once there was greater certainty over the EU approach.3
OPRL is developing an EU labelling tool intended to help brands apply the new requirements once the final specifications are known.
Allan added: “Whatever the process, the bottom line is, that if we don’t communicate with consumers around recycling, we cannot expect them to do the right thing.”
Notes
[1] Regulation (EU) 2025/40, Articles 12 and 13, Regulation on packaging and packaging waste, Official Journal of the European Union. Regulation (EU) 2025/40 on EUR-Lex; [2] European Commission, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste, June 2026. European Commission PPWR guidance on EUR-Lex; [3] OPRL, What are the mandatory requirements for labelling under Extended Producer Responsibility for Packaging (pEPR)? OPRL states that mandatory UK recycling labelling has been put on hold and that Defra intends to consider options once there is greater certainty about the EU approach. OPRL guidance on UK mandatory labelling
