What the JRC Technical Proposal Covers

The JRC proposal aims to support the future PPWR implementing act for harmonised waste sorting labels. It proposes a system that is:

This approach is intended to reduce confusion for consumers and reduce market fragmentation for producers that currently face different national packaging labelling practices.

A Material-Based Labelling System

One of the most important concepts in the proposal is the material-based approach.

Instead of telling consumers the local bin name or collection destination, the label would identify the packaging material. This is important because collection systems vary across the EU. A destination-based instruction may be correct in one country, region or municipality, but not in another.

The proposal therefore focuses on identifying materials such as paper, cardboard, glass, plastic, composites, metal, compostable packaging, textile, ceramics, wood, cork, hazardous packaging and residual waste categories.

For businesses, this increases the importance of reliable packaging material data. Companies will need to understand the material composition of each packaging item and, where relevant, each separate component.

The Matching Principle: Packaging and Bin Labels Work Together

The proposed system relies on matching labels. In simple terms, consumers would compare the label on the packaging with the label on the waste receptacle and place the packaging in the receptacle with the corresponding label.

This means the pictogram becomes a key compliance and communication element. It is not intended to show every possible packaging shape. Instead, it acts as a consistent visual cue between the packaging and the receptacle.

For companies, this creates practical questions:

• Which label applies to each packaging material?
• Does the packaging have multiple components?
• Is the packaging small, irregular or difficult to label?
• Is text needed, optional or impractical?
• Are country-specific differences relevant?
• Could a digital data carrier be useful for additional sorting information?

These questions should be addressed before packaging artwork changes are needed at scale.

Key Design Elements Proposed by the JRC

The JRC proposal combines visual and system design. The main design elements include:

Pictograms

Pictograms are central to the proposed system. They are designed to be simple, recognisable and linked to packaging materials. The proposal draws inspiration from existing pictogram-based systems while adapting them for an EU-wide framework.

Colour

Colour is used to support recognition and grouping of material categories. However, the proposal recognises that colour associations differ between Member States and that colour use can create practical printing and implementation challenges.

Minimal Text

The PPWR direction favours labels that rely mainly on pictograms and use minimal language. This matters for the internal market because too much text can create translation burdens, larger label sizes and inconsistent consumer interpretation.

Accessibility

The proposal considers accessibility, including clear visual design and understandability for persons with disabilities. This is important because waste sorting labels must work for a broad consumer audience, not only for technical experts.

Digital Information

The proposal also discusses optional digital data carriers, such as QR codes, for additional information. This could be especially relevant where packaging has multiple components or where country-specific sorting instructions need to be communicated.

Business Implications for Packaging and Compliance Teams

The JRC proposal highlights several areas that businesses should start reviewing now.

Key Challenges Identified in the Proposal

The JRC report does not present harmonised labels as a simple plug-and-play solution. It identifies several challenges that businesses should take seriously.

Granularity

The system must decide how detailed material categories should be. Too little detail may not support correct sorting. Too much detail may confuse consumers and make implementation difficult.

Multi-Component Packaging

Packaging often includes several materials, such as a plastic tray with a cardboard sleeve. Businesses may need to decide how to communicate sorting instructions clearly without overcrowding the packaging.

Composite Packaging

Composite materials can be difficult to classify and label. The proposal recognises that composite packaging needs careful treatment to balance technical accuracy and consumer usability.

Compostable Packaging

Compostable packaging requires clear communication because “compostable” does not mean “throw in nature.” The proposal discusses home compostable and industrially compostable packaging, as well as the need to avoid misleading disposal behaviour.

Residual and Hazardous Packaging

Some packaging may not fit neatly into recyclable material streams. Residual or hazardous packaging labels may be needed in specific cases, but these categories can be complex because they may depend on content, contamination or local rules.

What Businesses Should Do Now

Although the implementing act is still the key legal milestone to watch, companies can already prepare in a controlled and low-risk way.

Start by improving packaging data quality. A company cannot assess future labelling obligations properly if it does not have a reliable view of its packaging materials, components, suppliers and markets.

Next, review packaging artwork processes. Labelling changes often involve long lead times, especially where packaging is printed in large quantities or used across multiple markets.

Finally, connect packaging compliance with regulatory monitoring. The final EU requirements may differ from the JRC proposal, so internal teams should avoid making irreversible assumptions while still preparing the foundations for compliance.

A practical readiness approach should include:

1 - Define packaging and packaging components in scope.

2 - Build a structured packaging inventory.

3 - Collect material composition data.

4 - Identify multi-component and composite packaging.

5 - Review label space and packaging artwork constraints.

6 - Track PPWR implementing act developments.

7 - Prepare supplier evidence and documentation workflows.

8 - Consider digital information options where physical label space is limited.

How ComplyMarket Can Support PPWR Label Readiness

ComplyMarket can help companies turn packaging compliance into a structured, audit-ready process.

For EU harmonised waste sorting labels, this means supporting the foundations that businesses will need before final labelling decisions can be made: packaging scope definition, packaging inventory management, supplier data collection, material and composition tracking, regulatory monitoring, evidence management and compliance workflow control.

ComplyMarket can support teams by helping them:

• Identify which packaging items, components and markets are in scope.
• Build a master packaging inventory connected to products and suppliers.
• Collect structured material and composition data from suppliers.
• Maintain technical evidence and declarations.
• Track packaging compliance requirements and regulatory updates.
• Prepare for future PPWR labelling and documentation obligations.
• Use software-supported workflows to reduce manual spreadsheets and scattered supplier emails.
• Improve audit readiness and marketability decision-making.

This is especially relevant because harmonised waste sorting labels will depend on accurate packaging data. Companies that prepare early will be better positioned to update labels, respond to customer questions, manage supplier evidence and adapt when the final implementing rules are published.

Final Takeaway

The JRC technical proposal is a strong signal of where EU packaging labelling is heading: clearer material-based information, stronger consistency between packaging and waste receptacles, and a more harmonised approach across the EU.

For businesses, the smartest next step is not to wait for the last minute. It is to build the data, evidence and workflow structure needed to respond quickly once the final rules are confirmed.

PPWR labelling readiness starts with controlled packaging compliance.