On 13 January 2026, the European Commission's Joint Research Centre (JRC) published a proposal for EU-wide harmonised waste sorting labels and waste collection systems or waste separation labels. The title of the document is ‘JRC technical proposal on EU harmonised waste sorting labels under the packaging and packaging waste regulation’.
What is the JRC proposal on EU-wide harmonised waste sorting labels about?
The document sets out a comprehensive conceptual and visual proposal aligned with the EU Packaging and Packaging Waste Regulation (PPWR) and its objective of removing barriers within the EU internal market. It also accounts for the existing waste sorting systems in the different EU Member States. The proposal recommends EU-wide harmonised waste sorting labels. It focuses on informing consumers about the material composition of packaging and providing clear sorting instructions using standardised labels on both packaging and waste collection containers.
What impact does the JRC report have on packaging labelling and collection containers?
As reported by Euwid, the draft is based on the Unified Nordic Pictogram System for Recycling, a pictogram system developed in the Nordic nations. In order to differentiate between labelling on packaging and labelling on collection containers, it suggests a two-stage labelling concept. However, there is a common visual principle that ties both ideas together.
Is the JRC proposal binding?
The proposal is meant to act as a foundation for the PPWR's planned implementing acts. The report aims to serve as a suggestion; the European Commission is under no obligation to accept the solutions in their current form.
What measures regarding packaging labelling does the JRC report propose?
Under the proposal, packaging labelling should focus exclusively on the material composition of the packaging rather than on specific local disposal instructions. The recommended system uses material-based pictograms, optionally supported by short explanatory text. It does not require mandatory colours and avoids references to national or local waste collection schemes. The main argument is cross-border distribution within the EU internal market. According to the JRC report, including country-specific disposal instructions would increase market fragmentation and force companies to adapt packaging designs for different Member States. The use of colours would remain voluntary, partly due to cost considerations, potential environmental impacts and possible conflicts with brand identity.
Matching principle: How does the JRC proposal address labelling of collection containers?
Unlike packaging labels, waste collection labels are intended to provide specific sorting instructions. They should clearly indicate which types of waste belong in each container, making it easier for consumers to sort correctly. Under the proposal, waste collection containers are expected to use the same material-based pictograms as packaging. Unlike packaging labels, collection containers would be required to use colour coding to be more visible and effective in public spaces. Where necessary, additional explanatory text or practical examples must also be provided. For collection containers designed for multiple materials, so-called “meta-labels” are envisaged. These would combine several pictograms into one label. By contrast, such combined labels would not be permitted on packaging. The connection between packaging and collection containers is based on a matching principle: identical or very similar pictograms should be used on both. This approach is intended to help consumers identify the correct waste container in any EU Member State. According to studies, these measures could significantly improve sorting accuracy and overall user-friendliness.
What are the JRC proposal's limitations?
The report highlights several unresolved issues. These include the treatment of composite packaging, the interaction with deposit and return systems, and potential overlaps with existing environmental or product labels. It also points to legal and organisational limitations. The EU Packaging and Packaging Waste Regulation (PPWR) applies only to packaging and does not cover non-packaging items made from the same materials. In addition, responsibility for packaging labelling and waste collection container labelling lies with different actors, which further complicates implementation.
What criticisms have been raised about the JRC proposal for EU-wide harmonised waste sorting labels?
Critics of the JRC proposal point out that, instead of simple, language-independent symbols, it relies on icons that require written explanations. Making text mandatory, rather than optional, contradicts the long-standing objective of lowering language barriers and establishing consistent, unambiguous labelling throughout the EU.
According to the guidelines, any accompanying text must be provided in one or more languages specified by each Member State. Rather than creating harmonised terminology, this could result in a system covering 20–24 languages. The report itself acknowledges the likely consequences – limited space on packaging, frequent design adjustments, SKU fragmentation, and weakened harmonisation – yet accepts them.
It is also made clear in the guidelines that pictograms by themselves are not sufficiently comprehensible. The pictograms have no meaning by themselves and only function in conjunction with container labels, but text can increase sorting accuracy, particularly for specific user groups. From a critical perspective, this implies that the icons are a fundamental flaw in the overall concept.
The approach also falls short in terms of accessibility. The suggested text sizes do not adhere to accepted standards, and complete accessibility on packaging is physically impossible, even though black-and-white versions and contrast guidelines are provided. Digital solutions, such as QR codes or digital product passports, are treated only as optional supplements rather than central elements of the system.
Overall, critics see the guidelines not as a decisive solution but as a deliberate compromise: more language instead of less, explanatory text instead of intuitive symbols, and a printed system prone to fragmentation instead of a consistent, digital-first approach.
What is next for EU-wide harmonised waste sorting labels?
As the key PPWR requirements will take effect soon, on 12 August 2026, now is the time to prepare. The question of how to label products and packaging correctly is already raising many concerns for producers across the EU.
Therefore, this topic is in high demand and will be covered in our workshops, including the EPR & Product Compliance Interactive Lab taking place on 14 April 2026.
Spaces are limited, so secure a spot and register now!
Looking for a PPWR training course customised to your company’s needs? Due to the high demand, it is best to reserve your spot for a private online session by submitting a non-binding inquiry right away.
Do you have any urgent inquiries regarding packaging and product labelling? The trade-e-bility team will be happy to help you at +49/40/750687-300 or send us an email.
