The European Commission’s Joint Research Centre has developed a proposal to harmonize waste sorting labels under the Packaging and Packaging Waste Regulation – recommending unified pictograms, colour-coded symbols and receptacles, and more.
The proposal was prepared by the Joint Research Centre for the Directorate-General for Environment and designed to support the Packaging and Packaging Waste Regulation within the framework of the European Green Deal and the Circular Economy Action Plan 2.0.
Over 250 stakeholders and 25,000 EU citizens were consulted via workshops, behavioural experiments, and online surveys. The Joint Research Centre also conducted its own desk research to inform the final outcome.
Its proposal sets out to address the challenges of fragmented national labelling systems, recycling inefficiencies, and internal market barriers.
Among its suggestions is the use of unified, intuitive pictograms to help consumers sort their packaging waste effectively. Reportedly, EU citizens showed a strong preference for this approach – especially when packaging labels and their corresponding waste receptacles were colour-coded consistently.
Notably, a behavioural experiment found that 44% of participants struggled with black-and-white labels – but those with colour blindness and visual or cognitive impairments showed a marginal preference for achromatic labels. The proposal highlights the importance of accessibility considerations when taking this approach, and that colour-coding should complement on-pack pictograms and text, not replace them.
Digital data tools, such as QR codes, are suggested as an accessible solution – accounting for disabilities, but also providing on-pack instructions in multiple languages, or providing the relevant region- or country-specific guidance. They may also be useful for packaging with limited labelling space.
On-pack specifications should also differentiate home-compostable and industrially compostable packaging, the proposal continues. These could include the relevant pictogram, the inclusion of the on-pack text “DO NOT THROW IN NATURE” in the relevant language(s), and an optional DNTIN label for industrially compostable waste, positioned beside the waste-sorting label.
The proposal clarifies that multiple labels may appear on one pack to account for different components (e.g. a plastic tray with a cardboard sleeve). Receptacles themselves may also specify that multiple materials can be deposited in the same bin – sometimes through meta-labels, or labels that encompass two related materials by using two pictograms in a single symbol.
It is acknowledged that meta-labels may cause confusion if the consumer does not understand the relationship between the individual material labels on-pack and the meta-label on the receptacle. The proposal cautions that the use of combined labels should be ‘selective’ and ‘well-justified’ with sufficient user guidance provided – and that meta-labels should never appear on packaging itself.
Labels should also identify materials that count as residual waste under local sorting rules, the proposal suggests. This is considered a ‘fallback category’ for packaging innovations whose optimal sorting route is not yet established.
The proposal also identifies several challenges that must be overcome in the regulatory phase. These include the clarity and space efficiency of on-pack labelling for multi-component packaging; similarly, the comprehensiveness and user-friendliness of labelling for composite packaging; and the acknowledgement of different national practices when harmonizing colour and text requirements across the EU.
Granularity is also identified as a complication. While more on-pack sorting instructions is helpful in theory, the proposal acknowledges that raising granularity could increase labelling requirements and risk confusing consumers. Lower label granularity could also be justified if industrial sorting technologies can achieve similar or better separation outcomes than consumers, but this is not a guarantee across the continent.
National DRS indicators also must be implemented without confusing or contradicting existing sorting instructions. On this note, the implementation of new packaging requirements introduces costs related to redesigning, printing, and adapting packaging, labels, and systems – an outcome that would inevitably hit SMEs the hardest. Transitional periods, clear user guidelines, and targeted support measures are recommended.
Additionally, the proposal also admits that certain aspects rely on the ‘best available’ evidence and ‘expert’ judgements over ‘definitive’ and ‘empirical’ proof.
In conclusion, the proposal recommends a top-down harmonization approach via an EU implementing act. Stakeholders are encouraged to engage continuously in the process, remain flexible for future updates, and undertake targeted communication and education campaigns to ensure long-term success.
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