PPWR requirements for labels: what changes in practice

The PPWR (Packaging and Packaging Waste Regulation) applies from 12 August 2026. For labels, the PPWR does not create a simple split of materials into compliant and non-compliant. In the context of recyclability, evaluating the label alone is not enough – what matters is its impact on the recyclability of the entire packaging to which it is applied. Key packaging recyclability requirements will come into effect in 2030, along with mandatory minimum recycled content for specific plastic packaging.

For packaging manufacturers, the PPWR is one of the more important regulatory changes of recent years. It also matters for the labelling industry, although not always for the most obvious reasons. Recent months brought “PPWR compliant” materials, declarations of conformity, new label constructions and supplier assurances of readiness for the new rules. Several points need to be put in order.

The label is assessed together with the packaging

You can only assess the effect of a label on the recycling of packaging at the level of the complete construction, not a single component. Take an HDPE bottle with a self-adhesive label. You can analyse the bottle, the face material and the adhesive separately. Recycling, however, depends on the behaviour of the whole combination:

• What happens to the label during grinding and washing?
• Does the label separate from the bottle, and which fraction does it end up in?
• Where does the adhesive remain?
• Does the label material obstruct the further processing of HDPE?

For this reason, the phrase “PPWR compliant label” is a simplification. The same construction can work well with one type of packaging and be the wrong solution in another application.

Paper is not automatically a better choice than film

Replacing film with paper does not automatically improve the environmental properties of packaging. A paper label applied to plastic packaging remains an additional material, and the recycling process must account for it.

In some applications, a correctly selected PE or PP label can be the better solution. Such a label is compatible with the packaging material, or it separates effectively in a specific recycling process. The choice between paper and film should follow from the construction of the complete packaging, not from which material is perceived as more environmentally friendly.

The adhesive is also selected for its behaviour in recycling

One question now joins the existing selection criteria for the adhesive: what happens to the adhesive after the end of the packaging life. The face material is only one part of a self-adhesive label. The second part is the adhesive, and its behaviour in recycling can be highly relevant.

Until now, adhesive selection has focused mainly on performance parameters:

• tack
• peel adhesion
• application temperature
• resistance to moisture, chemicals and low temperature

In one process, it can be desirable for the label to stay with the packaging material. In another process, separation during washing is the correct solution. There is no single answer that is correct for all applications.

Inks, varnishes and coatings are also label components

The PPWR increases the importance of information on the material composition of packaging and its components, including inks, varnishes and coatings. A finished label can consist of a face material, a surface layer, several inks, a varnish and an adhesive. More complex products can have even more layers. Their share of the total packaging mass is often small, but that does not mean they can be forgotten.

For a printing house, this means obtaining data not only from producers of papers and films, but also from suppliers of adhesives, inks and varnishes. In practice, this can be one of the larger challenges connected with the PPWR.

Customers ask for material data, not for compliance alone

Customer enquiries include more and more questions about the PPWR, and these questions go beyond whether a given material “is compliant”. A customer may need information on:

• the type of polymer
• the grammage
• the adhesive mass
• the recycled content
• the possibility of separating the label in the recycling process
• substances present in individual components (in specific cases)

A good material database therefore gains value for a label manufacturer. A technical data sheet stating that the film is 60 µm and the adhesive is permanent is no longer enough. The manufacturer needs to know considerably more about what the delivered product consists of.

Why a general “PPWR compliant” declaration is risky

A label manufacturer usually does not know the complete packaging construction of the customer and does not control all of its components. A general declaration that a label complies with the PPWR can therefore be too large a simplification. A much better approach is to give the customer specific information:

• What is the face material?
• Which adhesive was used?
• What is the mass of the individual components?
• What information did we receive from the raw material producers?
• Do test results or guidelines exist for the behaviour of this construction in a specific recycling stream?

This is the information that carries real value.

2030 is closer than it seems

Some of the most important PPWR changes for packaging design apply after 12 August 2026, and the year 2030 is particularly relevant. From that year, the following start to apply:

• the key requirements on the recyclability of packaging
• the requirements on minimum recycled content for certain plastic packaging
• further requirements on packaging minimisation, empty space and reuse

Four years is not a long period in the packaging industry. A customer can use materials approved today for many years, and automotive, household appliance and industrial projects often have a considerably longer life cycle. If you design a new construction in 2026 or 2027, consider now whether it will still be a good solution in a few years.

The set of questions in the customer conversation changes

The largest change the PPWR brings to the labelling industry may be a wider set of questions asked at the start of a new project. Until now, we asked mainly about the application surface, temperature, chemical resistance, conditions of use, printing technology and expected durability.

Further questions now join that list:

• What is the packaging made of?
• Which recycling stream should it go to?
• Should the label stay with the packaging or be separated from it?
• What recyclability requirements does the customer have?
• Which data does the customer need for its PPWR documentation?

This changes the role of the label manufacturer. We are no longer only a supplier of a material that prints well and sticks well. Increasingly, we take part in designing a solution that must work throughout the whole life cycle of the packaging.

Here the PPWR can be not only an obligation for the labelling industry, but also an opportunity. A manufacturer can combine knowledge of materials, adhesives and printing technology with knowledge of recycling processes and regulatory requirements. Such a manufacturer is a more valuable partner than a company that only issues another “PPWR compliant” declaration. In the end, the question is not whether the label itself is “ecological”, but whether it was correctly designed as part of specific packaging.

Wondering if your current labels and packaging structures will stand the test of time and meet strict PPWR requirements? Consult your project with our technical team! We help analyze the entire design and select the right materials.

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FAQ

Can a label be “PPWR compliant”?

On its own—not in a meaningful way. The Regulation evaluates the packaging as a whole, including the applied label, adhesive, and print. The same label structure may work well with one package and be a poor choice for another. Instead of a general declaration, it is more useful to provide the customer with details on the facestock, adhesive type, weights of individual components, and information obtained from raw material suppliers.

Is a paper label a better choice than a film label?

Not automatically. A paper label on plastic packaging is still an additional material that must be factored into recycling. In certain applications, a well-selected PE or PP label performs better because it is compatible with the packaging material or can be effectively separated during the recycling process. What matters is the design of the entire package and the target recycling stream, not which material is perceived as more eco-friendly.

Should the label stay on the packaging or separate from it?

That depends on the recycling stream the packaging is intended for. In one process, it is beneficial for the label to remain attached to the packaging material; in another, it should separate during the washing phase. There is no single correct answer for all applications, which is why this question should be asked at the design stage rather than after material approval.

What label data might a customer need?

More and more often, customers don’t just need confirmation of compliance, but specific data: polymer or substrate type, basis weight, adhesive weight, recycled content, separability in recycling, and in certain cases, information on substances present in individual components. A technical data sheet showing only film thickness and adhesive type is no longer enough.

Do inks and varnishes count as well?

Yes – they are label components just like the facestock and adhesive. Although their share of the total packaging mass may be small, compositional data must also be obtained from suppliers of adhesives, inks, and varnishes, not just paper and film manufacturers. In practice, this can be more difficult than changing the label structure itself.

When does the PPWR come into force and what changes in 2030?

Regulation (EU) 2025/40 entered into force on February 11, 2025, and applies from August 12, 2026. The general recyclability requirement under Article 6(1) applies from this date, whereas the requirement for Design for Recycling according to detailed criteria will apply from January 1, 2030, or 24 months from the entry into force of the relevant delegated acts—whichever date is later. Minimum recycled content targets for certain plastic packaging are also set for 2030.

Does the PPWR introduce new packaging labeling?

Yes. Harmonized labeling indicating material composition must be placed on packaging from August 12, 2028, or 24 months after the entry into force of the implementing act adopted pursuant to Article 12(6)—whichever date is later. When planning, it is worth remembering that an additional compliance label is itself another layer of material with adhesive that factors into the overall packaging assessment.

What should you ask about when starting a new label project?

In addition to traditional questions regarding application surface, temperature, chemical resistance, and printing technology, new ones arise: what material is the package made of, which recycling stream is it heading for, should the label remain attached or separate, what recyclability requirements does the customer have, and what specific data do they need for their documentation?