The JRC Unveils Prototype PPWR Sortation Label Following Stakeholder Consultation
by Siân Lee at 10:27 in Environmental, Packaging

​In March 2025, the European Commission's Joint Research Centre (JRC) published a 182-page report summarising the results of the 2024 stakeholder consultation on waste sortation labelling. The original stakeholder consultation, which ran from 2 September to 30 September 2024, sought to gather perspectives from industry experts on the potential design of the EU-harmonised waste sortation label under the PPWR.

The summary report released by the JRC presents the prototype label which was used to gather feedback during the consultation period.

Whilst there is no legal guarantee that the European Commission will choose to implement any of the recommendations included in the JRC report, the stakeholder consultation reveals valuable insights for the Commission ahead of the finalisation of PPWR sortation label designs in 2026. From label granularity to colour, this blog will examine relevant considerations from the JRC report.

The PPWR: Harmonised Waste Sortation Labelling

The PPWR will require packaging placed on the market to be marked with a harmonised label containing information on material composition by August 2028 (or 24 months from entry into force of an implementing act).

By August 2026, the European Commission must adopt an implementing act to establish the exact format of the harmonised waste sortation label. In the meantime, various European research initiatives are underway in order to gather relevant insights on the potential design of the waste sortation label.

The Prototype Label: Key Trends and Insights from the JRC Report

The initial label prototype presented by the JRC features 8 distinct material categories (cardboard and paper, metal, residual, food waste, glass, wood, plastic and cartons). Certain material categories, including plastic, are further subdivided to differentiate between material type, for instance 'soft' and 'hard' plastic. This granularity was commented upon by various stakeholders, who generally favoured keeping label granularity to a minimum in order to avoid consumer confusion.

Space limitations on-pack are also raised as a potential issue regarding labelling designs which exhibit greater granularity. For instance, if packaging is reduced to the minimum size necessary to comply with the PPWR, the space available on-pack for more complex, granular labels will also be reduced.

Additionally, it is suggested that the residual waste category should instead be referred to as 'non-recyclable', as residual waste itself is not a material and therefore clashes with the material-based foundation of the new PPWR sortation labelling system. The definition of what constitutes 'residual waste' in each Member State may also vary, which may cause implementation challenges in practice.

In terms of label colour, respondents generally exhibited a preference for the use of black and white labels on packaging, as opposed to coloured labels. This is attributed to various factors, including the environmental impact of colour printing, concern over higher production costs and the potential for interference with brand image. At the same time, various stakeholders recognised the need for colour usage when it comes to the waste receptacle itself, in order to allow for easy consumer recognition and sortation.

The behavioural awareness of consumers must also be prioritised in order to ensure effective implementation of the new labelling system. The new system must ensure consumers are able to easily match the packaging label displayed on-pack to the corresponding waste receptacle. An overly granular labelling system (i.e. too many labels for different packaging types) has the potential to cause consumer confusion, which may lead to improper material sortation.

What's Next After the Stakeholder Consultation?

Following the release of the JRC summary report, a second prototype label design will be developed in order to incorporate stakeholder feedback. A second stakeholder consultation is currently planned for May 2025.

Despite the JRC's development of non-legislative prototype designs, the finalised label specification must be prescribed by law. Producers must therefore await the adoption of implementing acts in 2026 to obtain legal certainty from the Commission.

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