The European Commission Joint Research Centre has published a technical proposal recommending the harmonisation of waste sorting labels across the European Union, as part of the implementation of the Packaging and Packaging Waste Regulation (PPWR).
Prepared for the European Commission’s Directorate-General for Environment, the proposal is intended to support the PPWR within the policy framework of the European Green Deal and the Circular Economy Action Plan 2.0. It aims to address persistent fragmentation in national waste-sorting labelling systems, which the Commission identifies as a barrier to efficient recycling and the functioning of the internal market.
According to the JRC, more than 250 stakeholders and approximately 25,000 EU citizens contributed to the work through workshops, behavioural experiments and online surveys, complemented by internal desk research. The resulting proposal outlines a set of design and implementation principles for future EU-wide labelling rules.
At the core of the recommendations is the introduction of unified, intuitive pictograms to guide consumers when sorting packaging waste. The JRC reports that citizens showed a clear preference for this approach, particularly when on-pack labels and waste receptacles are colour-coded consistently. However, the proposal cautions that colour coding should not be used in isolation.
Behavioural testing cited in the document found that a significant share of participants struggled to interpret black-and-white labels, while respondents with colour blindness or visual and cognitive impairments showed a marginal preference for achromatic designs. As a result, the JRC stresses that accessibility requirements must be embedded in any harmonised system, with colour used only to complement pictograms and text.
The proposal also points to digital data carriers, such as QR codes, as a way to extend sorting guidance without increasing on-pack complexity. These tools could support multilingual instructions, provide region- or country-specific guidance, and offer solutions for small packs with limited labelling space, while also improving accessibility for users with disabilities.
Specific guidance is also proposed for compostable packaging. The JRC suggests that home-compostable and industrially compostable formats should be clearly differentiated on pack, using dedicated pictograms and mandatory text such as “DO NOT THROW IN NATURE” in the relevant language. For industrially compostable packaging, an optional supplementary identifier placed next to the main sorting label is discussed.
Recognising the growing prevalence of multi-material packaging, the proposal clarifies that more than one sorting label may appear on a single pack to reflect different components, such as a plastic tray combined with a cardboard sleeve. Waste receptacles may also indicate that multiple materials can be disposed of together, using so-called meta-labels that group related materials within a single symbol.
At the same time, the JRC warns that combined or meta-labels can create confusion if consumers do not clearly understand how on-pack labels relate to bin-level instructions. The proposal therefore advises that such labels be used selectively, supported by clear user guidance, and explicitly states that meta-labels should not appear on packaging itself.
The document further suggests that harmonised labels should identify materials that fall under residual waste in local sorting systems. This category is described as a fallback for packaging innovations whose optimal recycling route has not yet been established.
Looking ahead to implementation, the JRC highlights several regulatory and practical challenges. These include limited space on packaging for multi-component and composite materials, differing national practices in colour and text conventions, and the risk that overly granular instructions could overwhelm consumers. While higher granularity may improve sorting accuracy in some cases, the proposal notes that industrial sorting technologies may sometimes deliver comparable or better results, though performance varies across the EU.
The interaction between harmonised labels and national deposit return scheme indicators is also flagged as a sensitive issue, requiring careful alignment to avoid contradictory instructions. In addition, the JRC acknowledges that new labelling requirements will entail redesign and printing costs, with a disproportionate impact on small and medium-sized enterprises. To mitigate this, transitional periods, clear guidance and targeted support measures are recommended.
The proposal concludes by advocating a top-down harmonisation approach through an EU implementing act. Stakeholders are encouraged to remain engaged throughout the regulatory process and to support future communication and education efforts to ensure consistent consumer understanding as the system evolves.
