New EU Requirements for Packaging Labelling

New sorting labels

PPWR introduces (in Article 12) new harmonised sorting labels for all packaging placed on the European market. The goal is a common labelling system that makes it easier for consumers to sort packaging correctly, based on the material from which the packaging is made.

This means that today’s Nordic packaging labels must be replaced with new common European labels over the coming years.

According to the plan, the harmonised labelling requirements will apply from 12 August 2028. Packaging produced or imported into the EU before the deadline may be sold for up to three years.

 

When will the final sorting labels be ready?

The EU’s Joint Research Center (JRC) has developed proposals for the new packaging labels. Various drafts have been circulated for consultation among Member States and tested with consumers. In January, the JRC submitted its final proposal to the European Commission, which will prepare an implementing act.

The final proposal for the labels will be presented in the implementing act, and changes may occur compared with the JRC’s proposal. The act must be reviewed and approved by a committee of representatives from EU Member States. The goal is to finalise the process by 12 August 2026, which means the labelling requirement would apply 24 months later, i.e., on 12 August 2028. If the process is delayed, the deadline will also shift.

 

What the proposed sorting labels look like

The proposed labelling system is largely inspired by the existing Nordic sorting labels but with some changes to visual design and colour usage.

PROPOSAL: This is the sorting label proposed by JRC. Screenshot: Publications Office of the European Union.

NPA recommends that our affiliated producers continue using the symbols from the Nordic signage system to label packaging until the European Commission has adopted a decision on the new labelling.

You can find the symbols for the Nordic signage system here

 

Overview of the requirements

PPWR regulates sorting labels for packaging. The same symbols will also be used on waste containers and collection systems, but these follow separate timelines and requirements. Since PPWR only applies to packaging, today’s waste labels for the collection of other waste types will not be covered by the new requirements.

 

Requirements for size and colours

In addition to the labels themselves, there will be requirements regarding size, text, and colour usage. As today, the use of colours is recommended, but flexibility for black and white versions is being discussed.

 

What will happen to the Green Dot symbol?

From 12 February 2027, the Green Dot symbol may only be used within a QR code or an equivalent digital solution that clearly explains producer responsibility.

The Green Dot is a financing symbol administered by PRO Europe, showing that a company has fulfilled its legally required producer responsibility for packaging. It is a collective trademark and voluntary to use. It has historically been recommended to signal that companies take financial responsibility for recycling but is not a requirement.

However, studies show that many interpret the symbol as an indicator of recyclability. PPWR therefore requires that labels indicating that a company has fulfilled its producer responsibility, if used, must be clear and unambiguous, and may only be displayed through a QR code or similar open digital marker.

PRO Europe is working on an updated version of the Green Dot that will meet the new requirements while also providing sorting information to consumers. The proposal is not yet final.

As a member of PRO Europe and license holder in Sweden, NPA will share their final proposal with our affiliated producers as soon as it becomes available.
NPA’s interpretation is that the requirement applies to packaging or packaged products made available for the first time on the European market after 12 February 2027.

As NPA interprets it, packaging or packaged products placed on the European market before 12 February 2027 will be exempt from the requirement.

 

What happens next?

From 12 August 2026:

• Packaging must be marked with an article number.
• Packaging must be marked with contact information.
• Packaging may not be labelled with tags, symbols, or similar that risk misleading or confusing consumers or other end users regarding the packaging’s sustainability characteristics, other packaging properties, or how the packaging waste should be handled.

From 12 February 2027, it is voluntary to label packaging covered by extended producer responsibility schemes. If labelling is used – for example, the Green Dot – it may only appear as a symbol within a QR code. It is no longer permitted to use a separately printed symbol to show that a fee has been paid to a PRO. The symbol must be clear and unambiguous and must not mislead consumers regarding recyclability or reusability.

From 12 August 2028 (or 24 months from the adoption of relevant implementing acts), additional requirements will apply regarding harmonised sorting instructions. These requirements apply to all packaging types except transport packaging.Transport packaging used in e commerce is included in the requirement and must be labelled.

From 12 August 2028 (or 24 months from the adoption of relevant implementing acts), additional requirements will also apply regarding labelling of substances of concern. This requirement applies to all packaging types.

 

Other packaging labelling requirements

PPWR also contains additional labelling requirements:

• Packaging containing hazardous substances must be labelled with a standardised digital data carrier, for example a QR code.
• Packaging included in deposit systems must have a clear label showing this by 1 January 2029.
• Compostable packaging must be labelled as compostable by 12 August 2028 (with a three year transition period).
• Reusable packaging must be labelled so that it is clearly distinguishable from single use packaging from 12 February 2029.

PPWR also opens the possibility for harmonised labelling of recycled and bio based content in packaging. Proposals are being developed but have not yet been submitted to the Commission.

Labelling of bio based or recycled content is voluntary, but if companies choose to communicate this they must, from 12 August 2028 (or 24 months from the adoption of relevant implementing acts) use the harmonised labels.

---

Disclaimer

The information presented here constitutes NPA’s interpretation of PPWR based on currently available material. PPWR is interpreted by the Swedish Environmental Protection Agency (Naturvårdsverket) and the European Commission, and ultimately by Swedish and European courts and the Court of Justice of the EU. As additional material is expected during 2026, including a Swedish ordinance and guidelines from the European Commission, these assessments may change. Each actor handling packaging is ultimately responsible for its own legal assessment.