We do not know which recycling symbols to print

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)).^[1][2]

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 It is repealed with effect from 12 August 2028 (PPWR Article 70(2)).^[3][1]

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)).^[1]

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)).^[1]

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)).^[1]