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Why is there still no global labelling standard?

The absence of a global standard

The arguments for a single global packaging label are readily stated. Packaging trades globally. Consumers everywhere face the same basic question at the bin. The costs of fragmentation — divergent artwork per market, consumer confusion, greenwashing that arbitrages between regimes — are borne widely. The 2020 global mapping of packaging labels and claims conducted for the UN’s One Planet Network documented that inconsistency at length and called for “global consistency when it comes to definitions”.

Three sustained attempts at harmonisation are examined below: international voluntary standardisation, European legal harmonisation, and the current twin track of EU regulation and treaty negotiation. The obstacle is not primarily institutional weakness or industrial resistance, though both are present in the record. It is that the central assertion of a packaging recyclability label — this container can be recycled here — depends on local collection, sorting and reprocessing. Those conditions are not global.

Attempt one: voluntary international standardisation

The first attempt ran through the International Organization for Standardization. Between 1998 and 2006, ISO's environmental labelling subcommittee — created in 1993 with its secretariat at Standards Australia (ISO, n.d.) — published the 14020 family: general principles (ISO 14020:1998), self-declared claims (ISO 14021:1999), ecolabelling programmes (ISO 14024:1999) and environmental product declarations (ISO/TR 14025:2000, an International Standard from 2006) (ISO, n.d.b). The series established a shared vocabulary and a shared set of procedural expectations for anyone operating an environmental claim or scheme, and those definitions and procedures are referenced today in legislation on multiple continents.

The series was not itself a label, however, and its structure did not permit it to become one. ISO standards bind only those who adopt them, and the 14020 family deliberately standardises the grammar of environmental communication rather than any particular utterance: it tells a scheme how to define recyclability claims responsibly, not whether any given package is recyclable. The design was a choice, not an oversight. National ecolabels already existed when the subcommittee was created — Germany's Blue Angel from 1978, the Nordic Swan from 1989 — and the committee's mandate was to discipline that existing plurality, not to replace it with a single mark. The Global Ecolabelling Network, founded in 1994 as the peak body of those national schemes, institutionalised the same settlement: mutual recognition among many labels rather than convergence on one (GEN, n.d.). The forum in which voluntary international standards could have acquired the force of trade discipline, the World Trade Organization, has not produced harmonisation either. Environmental labelling has been discussed in the WTO's trade and environment bodies for decades without resolution; the organisation's own summary records that "most members believe that existing disciplines on technical barriers to trade are adequate to deal with environmental labelling", while a persistent dispute continues over whether labels based on non-product-related production methods are even WTO-consistent, and labelling requirements surface "regularly" as specific trade concerns in the TBT Committee (WTO, n.d.). The international system settled into an equilibrium in which labels are tolerated as national measures, disciplined case by case, and harmonised nowhere.

Attempt two: harmonisation by European law

The second attempt proceeded in an institutional setting that the first lacked: a legislature, a court, and a single market premised on uniform product rules. It did not produce a common marking system either, and the sequence by which it did not is set out below.

Directive 94/62/EC on packaging and packaging waste anticipated a common marking system from the outset. Article 8 provided that the Council "shall … decide no later than two years after the entry into force of this Directive on the marking of packaging", and that packaging "shall indicate for purposes of its identification and classification by the industry concerned the nature of the packaging material(s) used" (Directive 94/62/EC, Art. 8). The Council decision never came. What came instead was Commission Decision 97/129/EC, establishing the numbering and abbreviation system for packaging materials — with a recital stating the intended status of that system: "the identification system is to be voluntary at least in a first stage but subject to revision to establish whether to introduce it on a binding basis at a further stage" (Decision 97/129/EC). The further stage never arrived. For twenty-eight years the European Union, a polity with extensive harmonisation machinery, operated a voluntary identification system sitting beneath a marking mandate that was never activated. Article 8 accordingly contained two distinct elements: an identification requirement addressed to packaging itself, and a mandate to the Council to decide the marking system within a fixed period. The second was never exercised, and the first was given effect only through the voluntary numbering and abbreviation scheme of Decision 97/129/EC.

Member states legislated in the absence of a binding Union measure. France made its Triman signalétique and sorting instructions mandatory from 2022 (Décret n° 2021-835, 2021). Italy made material coding and consumer disposal information mandatory from January 2023 (UL Solutions, 2023). Spain's packaging decree required labeling indicating the disposal fraction from January 2025 (Real Decreto 1055/2022). Three organising principles — France labels the sorting gesture, Italy labels the material, Spain labels the destination container — produced three incompatible mandatory regimes inside one single market. In July 2025 the Commission referred France to the Court of Justice, arguing that the Triman obligation "has imposed a restriction on the free movement of goods contrary to Article 34 TFEU" (Packaging Europe, 2025). The EU is at present litigating against a member state's packaging label and legislating its own: Regulation (EU) 2025/40 establishes a harmonised label and repeals Decision 97/129/EC from 12 August 2028, with the harmonised requirements applying from that date or twenty-four months after the implementing acts, whichever is later (Regulation (EU) 2025/40, recital 74; PPWR-doc, n.d.).

The sequence has a definite structure. Harmonisation did not fail in Europe because the idea was rejected; it failed because it was deferred — made voluntary "in a first stage" — and the deferral allowed national requirements to diverge until each state's label encoded its own waste system. By the time a binding Union measure was adopted, no neutral baseline remained, and the harmonised label falls to be applied over three established national regimes rather than over unoccupied ground.

Attempt three: the current twin track

The third attempt runs on two tracks simultaneously, and as of August 2026 the two tracks stand at different stages.

The first track is the EU's harmonised label itself, the most extensive harmonisation instrument attempted in this field to date, and one whose operation is not yet settled. Its dates are contingent on implementing acts not yet adopted, its design remains contested, and it governs one market of twenty-seven states rather than a global system.

The second track is global in scope: the negotiations toward an international legally binding instrument on plastic pollution. The fifth session's resumed meeting, INC-5.2 in Geneva, "adjourned early on 15 August [2025] without consensus on a text of the instrument" (UNEP, 2025); as the Earth Negotiations Bulletin's summary put it, "when the meeting adjourned, members technically had four iterations of the treaty text before them" — and agreement on none (IISD Earth Negotiations Bulletin, 2025). A further session in February 2026 was organisational only, electing a new chair after the incumbent resigned, with "no substantive negotiations" held; the next substantive session had, as of this writing, no announced date (UNEP, 2026). The draft texts contain no labeling regime of the kind at issue here: the chair's revised text proposal addressed product design in general terms — improving design "in pursuit of circularity" and improving "the availability of relevant information on materials and additives in plastic products" — with no comprehensive labeling regime, and delegates reached no convergence even on whether such provisions should be mandatory (INC Chair, 2025).

The third attempt thus reproduces the pattern of the first two: binding harmonisation proceeds, partially and slowly, within a single legal order, and gives way to voluntarism or to deadlock beyond one.

A counterexample: the barcode

One mark applied to the same physical object, the package, achieved the global adoption that the three attempts did not. The barcode — standardised in 1973, first scanned at a retail checkout on 26 June 1974 — achieved effectively universal global adoption through a private, neutral, non-profit standards organisation now known as GS1, formed under that name in 2005 from the merger of EAN International and the Uniform Code Council, with more than two million member companies and its identifiers scanned billions of times daily (GS1, n.d.; GS1 Singapore, n.d.). No treaty required it, and no directive mandated it. This packaging mark achieved global adoption within a decade, while environmental marks have not done so in three decades; the differences between the two cases are set out below.

Three differences carry most of the explanation, and together they specify the structural problem.

First, the barcode's benefits accrue to the same parties who bear its costs. A retailer who invests in scanning captures the checkout efficiency; a manufacturer who prints the symbol gains access to every scanning retailer. Environmental labels invert this: producers bear the cost while the benefits — better sorting, less contamination — accrue to municipalities, reprocessors and publics, a misalignment that voluntary adoption cannot bridge.

Second, the barcode asserts a context-free fact. An identifier is true everywhere or nowhere; nothing about crossing a border changes what a GTIN identifies. The core assertion of a recyclability label is the opposite: locally contingent by nature. The same laminated pouch is truthfully labelled "not recyclable" where no facility accepts it and truthfully labelled otherwise where one does. The thresholds used by the schemes examined state the point in numerical terms — How2Recycle's "Widely Recyclable" requires access for 60 per cent of Americans and half of Canadians (How2Recycle, n.d.), while OPRL's "Recycle" requires collection by 75 per cent of UK local authorities (OPRL, n.d.). These are not rival estimates of one fact; they are measurements of different places. A "global" recyclability label would either assert nothing (a lowest common denominator true everywhere) or assert falsehoods somewhere.

Third, the barcode standardised syntax and left semantics local — what the number is, not what the product costs in any given shop. The successful parts of environmental-label harmonisation have exactly this character: ISO's grammar of claims, the shared material abbreviations of Decision 97/129/EC, the emerging use of digital data carriers to resolve one printed symbol into jurisdiction-specific disposal information. Where harmonisation has aimed at semantics — one symbol meaning "recyclable" everywhere — it has failed every time it has been tried.

What would have to be true

On the account offered here, the absence of a global standard follows from the character of the assertion rather than from a failure of institutional will. A global packaging label could exist under any of three conditions: if waste-management infrastructure converged globally (so the local fact became a global one); if the label's content retreated to context-free assertions (material identity, data carriers — harmonisation of syntax); or if a global authority acquired the power to impose semantics and absorb the resulting local falsehoods. The first is a decades-long industrial project no treaty can decree. The third does not exist, and the INC record suggests it is not imminent. The second is in progress, and it is the form of "global standard" for which the present record provides support.

The analysis also clarifies what should count as success. Critiques of labeling fragmentation often imply that forty national labels represent forty failures to agree. On the structural account offered here, a substantial share of that plurality is not disagreement but accuracy: schemes measuring genuinely different collection systems will, if honest, produce different verdicts. The reform target that follows is not one global label but the elimination of unnecessary divergence — shared material syntax, shared claim grammar, shared data carriers — combined with explicit statement that the final verdict is, and will remain, local.

The realistic future, visible in the current EU design with its pictograms backed by digital carriers, is therefore layered rather than unified: globally standardised identification and data syntax; regionally harmonised sorting semantics where a single legal order can enforce them; and national or sub-national truth about what happens to the package after the bin. That outcome is not the global label envisaged by the 2020 mapping's call for global consistency. It is, however, consistent with what three decades of attempted harmonisation have established: the absence of a global answer to "can I recycle this?" reflects the absence, at the level of fact, of a global answer to that question.

References

Décret n° 2021-835 du 29 juin 2021 relatif à l'information des consommateurs sur la règle de tri des déchets issus des produits soumis au principe de responsabilité élargie du producteur. Available at: Open source (Accessed: 17 August 2026).

Commission Decision 97/129/EC of 28 January 1997 establishing the identification system for packaging materials pursuant to European Parliament and Council Directive 94/62/EC. Available at: Open source (Accessed: 17 August 2026).

Directive 94/62/EC of the European Parliament and of the Council of 20 December 1994 on packaging and packaging waste. Available at: Open source (Accessed: 17 August 2026).

GEN (Global Ecolabelling Network) (n.d.) About GEN. Available at: Open source (Accessed: 17 August 2026).

GS1 (n.d.) About GS1 and How we got here. Available at: Open source and Open source (Accessed: 17 August 2026).

GS1 Singapore (n.d.) History of GS1. Available at: Open source (Accessed: 17 August 2026).

How2Recycle (n.d.) How2Recycle labels. Available at: Open source (Accessed: 17 August 2026).

IISD Earth Negotiations Bulletin (2025) Summary of the resumed fifth session of the Intergovernmental Negotiating Committee on plastic pollution (INC-5.2). Available at: Open source (Accessed: 17 August 2026).

INC Chair (2025) Chair's revised draft text proposal, 15 August 2025. Available at: Open source (Accessed: 17 August 2026).

ISO (International Organization for Standardization) (n.d.) ISO/TC 207/SC 3 — Environmental labelling. Available at: Open source (Accessed: 17 August 2026).

ISO (International Organization for Standardization) (n.d.b) Catalogue records for ISO 14020:1998, ISO 14021, ISO 14024 and ISO 14025. Available at: Open source; Open source; Open source; Open source (Accessed: 17 August 2026).

OPRL (n.d.) How the scheme works. Available at: Open source (Accessed: 17 August 2026).

Packaging Europe (2025) EU Commission refers France to Court of Justice for undisclosed labelling law. Available at: Open source (Accessed: 17 August 2026).

PPWR-doc (n.d.) PPWR labelling requirements. Available at: Open source (Accessed: 17 August 2026).

Real Decreto 1055/2022, de 27 de diciembre, de envases y residuos de envases. Available at: Open source (Accessed: 17 August 2026).

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 2025/40, 22.1.2025. Available at: Open source (Accessed: 17 August 2026).

UL Solutions (2023) Italy environmental labeling requirements for packaging. Available at: Open source (Accessed: 17 August 2026).

UNEP (2025) Fifth session of the Intergovernmental Negotiating Committee (resumed), INC-5.2. Available at: Open source (Accessed: 17 August 2026).

UNEP (2026) Intergovernmental Negotiating Committee on plastic pollution. Available at: Open source (Accessed: 17 August 2026).

UNEP and Consumers International (2020) "Can I Recycle This?" A Global Mapping and Assessment of Standards, Labels and Claims on Plastic Packaging. Available at: Open source (Accessed: 17 August 2026).

WTO (World Trade Organization) (n.d.) Environment: labelling. Available at: Open source (Accessed: 17 August 2026).

Note on sources and verification

The Spanish decree's labeling application date (1 January 2025) is drawn from the instrument's preamble as published in the BOE; the full text of the operative labeling article was not separately extracted. The PPWR's harmonised-label application dates rest on the Regulation's recital 74 (retrieved from EUR-Lex) corroborated by two secondary compliance sources; Article 12's verbatim text could not be retrieved. The 65 per cent comprehension figure is a third-party poll (ISRI/Earth911, United States, 2014) cited within the 2020 UNEP/Consumers International report, not a finding of the report's own fieldwork; the report describes its global mapping as a sample rather than a census, and no total count of schemes mapped is stated in it — figures of that kind circulating in commentary should be treated with caution.

Last verified: 17 August 2026.

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