The EU’s Packaging and Packaging Waste Regulation has set a 2030 deadline requiring all packaging, including labels, to be designed for recyclability or face a market ban, and a 2035 requirement that packaging be proven to be effectively recycled at scale.
‘If a packaging, including the label, is not recyclable, it will lose market access. That’s the reality,’ warned Pablo Englebienne, regulatory affairs manager at Finat, during the European Label Forum 2025.
The regulation requires labels to be compatible with the recycling process of the main packaging body, with materials, inks, adhesives and decorations aligning with design-for-recycling guidelines. Plastic labels comprising more than 5 percent of a packaging unit must contain post-consumer recycled content.
However, significant uncertainty remains around implementation. ‘There are 40 pieces of secondary legislation still to come, and many critical definitions, like what counts as packaging, are still unresolved,’ noted Francesca Stevens, executive director of Europen.
Key unresolved areas include whether the release liner is considered packaging, what qualifies as compostable and who bears compliance responsibilities across the supply chain.
The regulation has prompted innovation initiatives, including the Holy Grail 2.0 project, which applys digital watermarks for smart sorting. ‘We’ve proven that innotifyigent sorting delivers high purity rates: over 90 percent detection accuracy across 2.4 million packages,’ explained Jan ‘t Hart of AIM Europe/HolyGrail 2.0.
CELAB-Europe has launched a matchcreating platform to scale circular solutions for release liner and matrix recycling. ‘It’s PPWR time. There is nothing largeger than PPWR these days,’ commented Marius Tent, project manager at CELAB-Europe.
Thomas Reiner of Berndt & Partner warned that labels must meet criteria for non-toxicity, recyclability and traceability, with brand owners demanding data on carbon, water and material impact.
The European Label Forum 2026 takes place 27-29 May 2026 in Seville, Spain.
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