Labelling Requirements under the PPWR: Transparency for Consumers and Economic Operators

With the new Packaging and Packaging Waste Regulation (PPWR), the European Union is focusing on maximum transparency and a more effective circular economy. A crucial lever for this is the labelling requirements for packaging. Clear and harmonised labelling is not only essential for consumers to support them in correct waste separation, but also for economic operators to ensure compliance with the new regulations and improve the recyclability of packaging.

Labelling requirements for packaging (Art. 12 and 13)

Article 12 (Labelling of packaging) and Article 13 (Labelling of waste receptacles for the collection of packaging waste) of the PPWR lay down detailed labelling requirements for packaging. The aim is to create a harmonised system across the EU that provides information on material composition and proper waste separation.

Key provisions under Article 12 (General labelling requirements):

• Material composition: All packaging must bear a label that clearly indicates the materials it is made of.
• Collection systems: Packaging and waste containers must be labelled with the pictograms published by the European Commission. This is to make it easier for consumers to dispose of waste correctly and to minimise incorrect disposal.
• Digital labelling: The PPWR allows the use of digital packaging labels (e.g. QR codes) for additional information. However, it is emphasised that mandatory labels must be physically affixed to the packaging and may not be exclusively digital.
• Harmonisation: The Commission will lay down the exact specifications for labelling through implementing acts to ensure uniform packaging labelling across the EU and eliminate national differences.
• Suitability for industrial composting: Packaging that must be compostable under Article 9 (e.g. certain coffee capsules, tea bags, very light plastic bags) must clearly indicate that it is suitable for industrial composting and complies with the relevant standards (such as EN 13432).
• Reference to avoiding incorrect disposal: It must be clearly communicated that compostable packaging must not be disposed of in the yellow bag/bin in order to prevent contamination of recycling.

The introduction of these harmonised packaging labels is expected to include a transition period to allow companies to adapt their packaging production.

EU packaging labelling: significance for manufacturers and retailers

The new EU packaging labelling requirements have far-reaching consequences for manufacturers, importers, and distributors:

• Design adjustments: Companies may need to adjust their packaging design to make sufficient space for the new mandatory packaging labels and ensure that they are clearly visible and legible.
• Compliance testing: All packaging placed on the market in the EU must comply with the new labelling requirements. This requires detailed testing of the material composition and the correct application of the pictograms.
• Supply chain management: It is crucial that the entire supply chain is aware of the new requirements and implements them. Particularly in the case of imports from third countries, it must be ensured that the packaging complies with EU regulations.
• Consumer communication: EU packaging labelling is a direct communication tool with consumers. Companies can use this opportunity to highlight their sustainability efforts and actively guide consumers towards correct disposal. This may also require additional information on websites or in accompanying materials.
• Ensuring data quality: Accurate data on material composition is the basis for correct labelling. Companies must ensure that they can reliably collect and manage this information.

Addressing the new PPWR labelling requirements at an early stage is crucial to avoid penalties and strengthen consumer confidence in the recyclability of products. Transparent EU packaging labelling is key to promoting the circular economy and protecting the environment.

Stay tuned for the continuation of our blog series, in which we will discuss the PPWR packaging bans.