What will the EU harmonised label look like?

The legal design brief

The PPWR specifies the system’s function more clearly than its appearance. Packaging must communicate material composition through accessible pictograms. Waste receptacles must carry corresponding labels for each separately collected material fraction. The implementing acts must account for composite packaging, for differences among Member-State collection systems, and for the relationship between packaging and receptacle labels. The design is meant to match: a symbol on the package should correspond to the same visual category on the bin.

The delay in adoption is legally consequential, not merely administrative, because the application dates for the Article 12 labels are calculated from the entry into force of the acts. Until the acts are published, every visual detail discussed below remains provisional except where it is already stated in the PPWR itself.

The JRC technical proposal

The Joint Research Centre published its technical proposal on 13 January 2026, following more than three years of literature review, citizen workshops, expert consultation, prototyping and behavioural testing. The research programme included large surveys across 21 Member States and subsequent behavioural experiments, together with participatory work in several countries. It drew expressly on existing national systems, in particular the Nordic pictogram scheme examined in the Nordic pictograms article. The proposal is the most detailed public indication of the Commission's design direction; the JRC, however, describes it as input to the implementing acts rather than as a source of legal obligations.

The proposal recommends a modular, material-based system comprising approximately 20 distinct labels at its most developed level of granularity. The families include colourless and coloured glass, paper and cardboard, wood and cork, metal, rigid and flexible plastics, several fibre-based composite categories including beverage cartons, textiles, ceramics, compostable routes, hazardous packaging and residual waste. The number of categories bears directly on the system's operation, since a system with too few categories cannot map accurately onto Member-State collection routes, whereas a system with a larger number imposes greater interpretive demands on consumers and greater artwork cost on packaging producers.

Pictograms, colour and text

A pictogram forms the stable core of the proposed label. That approach follows the PPWR's requirement for pictogram-based information and is directed at cross-border recognition. The JRC research reports that clear visual structure and component-level pictograms can improve sorting, particularly for multi-part packaging. The proposed system accordingly gives the icon a recognisable frame and applies matching visual treatment to packaging and receptacles.

Colour remains the least settled element. The JRC reports that citizens frequently preferred coloured labels and that colour can improve salience, but its interim evidence found that text contributed more consistently to sorting accuracy and that colour had a limited effect on accuracy in some tests. Member States and scheme operators have in addition invested in local colour conventions that do not align with one another. Belgium is reported to have argued that a mandatory Union colour could disrupt recognition of its blue PMD collection system; that argument is attributed to Belgium and is qualified in the note on sources below. The policy choice presented by the evidence is therefore between maximum visual uniformity and sufficient flexibility to preserve existing collection behaviour and to limit printing burdens.

Multilingual text presents a parallel tension. Text naming the material or the disposal route can improve accuracy, whereas requiring text in every market language would complicate pan-European artwork, particularly on small packs and in countries with several official languages. The JRC proposal consequently gives pictograms primacy and treats text as a supplement, with stronger support for text on receptacles than on packaging. The PPWR itself requires information to be available in languages easily understood by end users, as determined by the Member State; the extent to which that linguistic obligation must be satisfied within the physical label falls to be settled by the implementing act.

Composite, small and residual categories

Composite packaging is a principal test of the system. A label based only on the dominant material may be readily recognisable but may direct a package into a collection route that cannot process it. The JRC proposal differentiates fibre-based composites by composition and identifies beverage cartons separately, while the PPWR requires the Commission to account for integrated and separable components. For multi-component packaging, a component-by-component label or an optional digital explanation may be required where the parts follow different routes.

Small packaging is addressed through a hierarchy of fallbacks. Article 12 permits the label or data carrier to move to grouped packaging where direct marking is not possible or not warranted by reason of size or nature. Where grouped marking is also unworkable, the information may be provided through a single electronically readable code or another carrier. The JRC proposal examines minimum dimensions and pictogram-only variants, but those measurements are not binding unless and until adopted by the Commission.

The residual-waste label occupies a distinct position within the scheme. It provides a route for packaging that does not belong in a separate collection stream and for new or unusual materials that local systems cannot yet process. In the absence of such a category, a harmonised system would present producers with a choice restricted to recycling-associated symbols even where the correct destination is residual waste. The category is a sorting instruction based on the available collection route and does not function as an environmental performance grade.

Status of the proposal for artwork purposes

The JRC work indicates likely space, component and data requirements, but the proposal is not an approved EU label and its reproduction as such carries identifiable risks: a symbol adopted in advance may change during comitology, may conflict with a national label that remains in force, or may fall within the confusion prohibition in Article 12(8). The features that are stable at the verification date are structural rather than graphic. The PPWR establishes a pack-to-bin matching system; pictograms are to carry the common identity; composite and multi-part packaging require additional logic; digital carriers supplement rather than universally replace physical labels; and the final application dates move with the delayed implementing acts. Mandatory colour, the final category count, minimum sizes and the treatment of multilingual text remain unresolved legal questions as at 19 August 2026.

Primary sources

• Regulation (EU) 2025/40, Articles 12 and 13 — Open source
• JRC technical proposal on EU harmonised waste sorting labels under the packaging and packaging waste regulation (2026) — Open source
• JRC technical proposal, full text (JRC141706) — Open source
• JRC interim design and behavioural research report (2025) — URL not verified for this article
• EU Policy Lab, 'From evidence to action: publishing the technical proposal for EU harmonised waste sorting labels', 26 January 2026 — Open source

Note on sources and verification

The account of the proposal's content derives from the JRC technical proposal and associated EU Policy Lab material rather than from any adopted legal text; no implementing act had been published at the verification date, and the design described is therefore a research recommendation.

Belgium's argument that a mandatory Union colour could disrupt recognition of its blue PMD collection system is carried as an explicitly flagged uncertainty. The position is plausible on the face of the Belgian collection architecture described in the Netherlands and Belgium article, but no primary submission by Belgium advancing that argument was located in verification, and it is reported here as attributed rather than documented.

The figure of approximately 20 labels, the list of material families, and the reported findings on colour and text are taken from the JRC proposal and its interim research report as summarised in publicly available materials; individual measurements, minimum dimensions and pictogram variants were not confirmed against the full technical annexes.

Monitoring note. The analysis would change on adoption and publication of the Article 12(6) and 12(7) implementing acts, which would convert the design questions identified above into binding specifications and start the application periods running; on the outcome of comitology on the mandatory-colour question in particular; on any Commission decision to depart from the JRC category structure; and on publication of the receptacle-label act, which determines whether the pack-to-bin matching relationship is realised as designed.

Last verified: 19 August 2026.