{
  "type": "problem",
  "slug": "recycling-labels",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/recycling-labels/",
  "markdown": "https://www.conphora.com/solutions/problem/recycling-labels.md",
  "title": "We do not know which recycling symbols to print",
  "description": "Packaging sorting labels under the PPWR: the harmonised label from 2028, material codes still in use, misleading symbols, and the EPR symbol by QR code.",
  "answer": "Until the Packaging and Packaging Waste Regulation's harmonised sorting label applies, from 12 August 2028 or 24 months after the Commission's labelling acts, whichever is later, the material identification of Directive 94/62/EC continues. Under Regulation (EU) 2025/40, no economic operator may print symbols that mislead or confuse about the sustainability or waste options of packaging. Review your current artwork now and plan one change to the harmonised label.",
  "theme": {
    "id": "labelling-packaging",
    "label": "Labelling and packaging"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "PPWR",
    "PPWD"
  ],
  "path": [
    "regulation-library",
    "knowledge-articles",
    "ppwr-tool"
  ],
  "trigger": "Packaging artwork is being redesigned, or a customer in another country asks which recycling and sorting symbols your packaging should carry",
  "keep": null,
  "why": [
    {
      "text": "Two systems overlap for a while. The Packaging and Packaging Waste Regulation (EU) 2025/40 repeals Directive 94/62/EC with effect from 12 August 2026, but keeps Article 8(2) of the directive in force until 30 months after the entry into force of the implementing act on the harmonised label (Article 70(1)(a)). That provision requires packaging to indicate the nature of its materials, for identification and classification by the industry, on the basis of Commission Decision 97/129/EC (Directive 94/62/EC, Article 8(2)), and the marking must be clearly visible, easily legible and durable (Article 8(3)).",
      "sources": [
        1,
        2
      ]
    },
    {
      "text": "Decision 97/129/EC lays down the numbering and abbreviations for plastics, paper and fibreboard, metals, wood, textiles, glass and composites, and makes their use voluntary (Articles 1 and 3). It is repealed with effect from 12 August 2028 (PPWR Article 70(2)).",
      "sources": [
        3,
        1
      ]
    },
    {
      "text": "The harmonised label replaces this. From 12 August 2028 or 24 months from the entry into force of the implementing acts, whichever is later, packaging placed on the market carries a harmonised label on its material composition, based on pictograms and easy to understand, including for persons with disabilities (Article 12(1)). Transport packaging is outside this duty, except e-commerce packaging, and so is packaging in a deposit and return system, which is marked with its own clear label (Article 12(1)). The Commission was to adopt the implementing acts on the label and its formats by 12 August 2026 (Article 12(6)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The regulation also sets how and where the label is shown. Labels are affixed, printed or engraved visibly, legibly and firmly; the information is available to end users before purchase in online sales; and where the size of the packaging does not allow it, the label goes on the grouped packaging or, failing that, into a single electronically readable code (Article 12(5)). The language is one the Member State of sale determines (Article 12(5)). Packaging made or imported before the date that does not comply may be made available for 3 years from the date the requirement applies (Article 12(12)).",
      "sources": [
        1
      ]
    },
    {
      "text": "Some symbols are restricted already. Economic operators may not display labels, marks, symbols or inscriptions likely to mislead or confuse consumers about the sustainability requirements, other characteristics or waste management options of packaging for which harmonised labelling is laid down (Article 12(8)). Packaging in an extended producer responsibility scheme may only be identified by a symbol in a QR code or other standardised digital marking, by 12 February 2027 (Article 12(9)).",
      "sources": [
        1
      ]
    }
  ],
  "steps": [
    {
      "name": "Keep the material identification you use today",
      "text": "The rule in Directive 94/62/EC that packaging indicates the nature of its materials, on the basis of Commission Decision 97/129/EC, continues to apply until 30 months after the Commission's implementing act on the harmonised label enters into force. It is a directive provision that applies through national law, and the codes of Decision 97/129/EC are voluntary, so check how each Member State of sale applies it before you remove existing material codes in a redesign.",
      "item": "regulation-library"
    },
    {
      "name": "Remove symbols that can mislead",
      "text": "Check every logo, symbol and claim on the packaging that concerns recycling, sorting, reuse or sustainability. Economic operators may not display labels, marks, symbols or inscriptions likely to mislead or confuse consumers about features for which the regulation lays down harmonised labelling."
    },
    {
      "name": "Plan the harmonised label for the date it applies",
      "text": "From 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later, packaging placed on the market carries a harmonised label on its material composition to help consumers sort it. Transport packaging is outside this duty, except e-commerce packaging, and deposit-return packaging has its own label.",
      "item": "ppwr-tool"
    },
    {
      "name": "Show the same information online",
      "text": "The label information must also be available to end users before purchase in online sales. Plan the product page together with the artwork, in the languages the Member State of sale determines."
    },
    {
      "name": "Use the transition for packaging already made",
      "text": "Packaging manufactured in the Union or imported before the labelling date that does not meet the new criteria may be made available for 3 years from the date the requirement applies. Plan print runs so that old stock runs out within that window.",
      "item": "knowledge-articles"
    }
  ],
  "documents": [
    {
      "name": "Artwork per packaging unit with the material identification and any sorting label",
      "from": "The manufacturer",
      "ground": "PPWR Article 12(1) and (5); Directive 94/62/EC Article 8(2) and (3)"
    },
    {
      "name": "A review of the environmental symbols and claims on the packaging",
      "from": "The manufacturer or importer",
      "ground": "PPWR Article 12(8)"
    }
  ],
  "risks": [
    {
      "title": "The importer must not place unlabelled packaging on the market",
      "text": "Before placing packaging on the market, importers ensure that it is labelled in accordance with Article 12 (PPWR Article 18(2)(b)).",
      "source": 1
    },
    {
      "title": "Distributors verify the labelling",
      "text": "Before making packaging available, distributors verify that it is labelled in accordance with Article 12, and hold it back if they have reason to believe it is not in conformity (PPWR Article 19(2)(b) and (3)).",
      "source": 1
    },
    {
      "title": "A data carrier that does not work is non-compliance",
      "text": "Where the QR code or data carrier referred to in Article 12 does not give access to the required information, the Member State requires the operator to put an end to the non-compliance and, if it persists, prohibits the packaging or ensures it is withdrawn or recalled (PPWR Article 62(1)(c) and (2)).",
      "source": 1
    }
  ],
  "faq": [
    {
      "q": "Do we have to print the material codes such as numbers and abbreviations?",
      "a": "Decision 97/129/EC lays down the numbering and abbreviations of the identification system and says their use is voluntary for the materials in its annexes (Article 3). Directive 94/62/EC requires packaging to indicate the nature of its materials on that basis (Article 8(2))."
    },
    {
      "q": "Can we keep a national sorting logo?",
      "a": "The regulation does not ban other labels as such, but forbids labels and symbols that are likely to mislead or confuse consumers about features for which harmonised labelling is laid down (PPWR Article 12(8)). Packaging in a national deposit system is marked with a clear and unambiguous label (Article 12(1))."
    },
    {
      "q": "Where does the label go on very small packaging?",
      "a": "On the packaging, visibly, legibly and firmly. Where that is not possible or not warranted on account of its nature and size, on the grouped packaging, and failing that via a single electronically readable code (PPWR Article 12(5))."
    },
    {
      "q": "Can we show that we pay for packaging EPR on the pack?",
      "a": "By 12 February 2027, packaging in an extended producer responsibility scheme may be identified in the Member States where the scheme applies only by a symbol in a QR code or other standardised digital marking, which must not mislead about recyclability or reusability (PPWR Article 12(9)). The wording leaves open whether 12 February 2027 is the start of this rule or a deadline."
    },
    {
      "q": "When does Decision 97/129/EC end?",
      "a": "It is repealed with effect from 12 August 2028 (PPWR Article 70(2)). Article 8(2) of Directive 94/62/EC continues until 30 months after the entry into force of the implementing act on the label (PPWR Article 70(1)(a))."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2025/40 on packaging and packaging waste",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/reg/2025/40/oj",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 94/62/EC on packaging and packaging waste (consolidated text of 4 July 2018)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0062-20180704",
      "accessed": "2026-10-04"
    },
    {
      "title": "Commission Decision 97/129/EC establishing the identification system for packaging materials",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/dec/1997/129/oj",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "packaging-rules-meaning",
    "packaging-producer-or-not",
    "green-claim",
    "small-product-label",
    "battery-labelling"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}