EFIC and a number of other organisations express their strong concern and opposition to the use of text and colour for waste sorting labels on packaging. This would reintroduce national barriers to the free movement of packaged goods in the Union, directly contradicting the recent Single Market Strategy where the European Commission identified divergent packaging labels as one of the ten most disruptive barriers to the internal market.
The latest version of the draft Joint Research Centre's (JRC) guidelines on EU waste sorting labels continues to prioritise the use of full-colour labels with accompanying text when used on packaging. Although the draft offers some design options for a pictogram-based system, it simultaneously proposes restricting the use of colour- and text-free alternatives to cases justified by economic constraints, specific consumer readability needs, or to very small packaging.
This approach runs completely counter to the goals of the Packaging and Packaging Waste Regulation (PPWR) and will significantly fragment the Union market. Under Article 12 of the PPWR, the European Commission is mandated to harmonise consumer sorting instructions, an essential step to ensuring a functioning Single Market, improving separate collection and recycling of packaging waste, and removing unnecessary burden for industry. Prioritising a labelling system with full colour and text - which will require translation in one or more national languages as established by Member States - directly contravenes these objectives, reopening the door to divergent national requirements. As a consequence, a product would have to carry a label with up to 24 local terms, also contravening the objective of the labelling scheme to make sorting instructions clearer to consumers.
The direction proposed by the JRC also stands in direct contradiction to the Commission’s ongoing efforts to safeguard the Single Market, as clearly outlined in the Single Market Strategy and reinforced in recent years through infringement procedures initiated against national sorting instructions systems. The strategy clearly reaffirms the Commission’s commitment to protecting the integrity of the Single Market, recognising the need to balance providing clear information to consumers while minimising market barriers and burdens on industry.
Different packaging labelling rules across Member States will result in operational inefficiencies, higher costs, and consumer confusion. More critically, it will jeopardise the environmental and economic goals of the PPWR and the Single Market Strategy.
We therefore urge the Commission to reconsider the current direction of the JRC guidelines and ensure that the future EU labelling system aligns with the goals of EU-wide harmonisation, large scale recyclability, and protection of the Single Market.