The European Commission has missed its self-imposed deadline to harmonize the Packaging and Packaging Waste Regulation’s labelling requirements for recycled content, reusable packaging, and consumer sorting via implementing acts – potentially resulting in a time crunch for businesses to comply.
The Packaging and Packaging Waste Regulation has officially applied since 12 August. The Commission initially said it would adopt implementing acts to solidify labelling requirements by the date of application.
One implementing act was set to establish a harmonized label and the specification of labelling requirements and formats, as per Article 12 of the Regulation. This was set to include digital labelling and account for the specific circumstances of composite packaging, as well as packaging designed specifically for an individual Member State’s deposit return system.
Another implementing act would also set out a methodology for identifying a pack’s material composition – including composite packaging and integrated or separate packaging components – through standardized, open digital marking technologies.
While the exact content of these measures is yet to be confirmed, the requirements are expected to follow the Joint Research Council’s proposal of a standardized pictogram-based label to represent a pack’s material composition. In this case, waste receptacles would bear similar pictogram-based labels to help consumers sort their waste directly.
So far, the Commission is yet to adopt the implementing acts. While recyclability and labelling scheme OPRL does not expect a long delay, it warns of a ‘very tight’ timeline to comply, as packaging producers will be left with 24 months to apply the harmonized labels to their packaging.
“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,” says OPRL managing director Jude Allan. “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. 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.
“Recent OPRL research demonstrates the importance of clear communication with consumers to achieve the necessary levels of recycling. So we are pleased to see that brands are still likely to be able to include instructions next to the PPWR label.
“OPRL’s latest research shows conclusively that consumers respond positively to calls to action. In our survey, 78% of respondents said they would be likely to rinse packaging that included a call to action, compared with 51 per cent where no action was recommended. Positive actions all make a difference to the quality of the material being recycled, which is what we are all working to achieve.”
OPRL is in the process of developing a ‘simple’ and ‘intuitive’ labelling tool to help brands adapt to the upcoming requirements.
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