From August 2028, all packaging placed on the EU market must carry a harmonised sorting label - a consumer-facing pictogram that tells people which waste stream to use. This is mandated by PPWR Article 12, and the technical proposal for the label system has been developed by the Joint Research Centre (JRC141706). The labels look simple. The underlying logic is not.

What the labels are

The JRC proposal defines 20 sorting labels across 10 material groups. Each label is a pictogram with a specific colour code, designed to be consistent across all EU member states. The material groups are:

  • Paper and cardboard (blue) - one label for all paper-based packaging
  • Glass (green) - four labels, split by colour: clear, green, brown, and mixed/other
  • Plastics (yellow) - two labels: rigid plastics and flexible plastics
  • Composites (varies) - three labels depending on the dominant material: paper-dominant, plastic-dominant, and metal-dominant composites
  • Metals (grey) - one label covering both steel and aluminium
  • Compostable (brown) - two labels: industrially compostable and home compostable
  • Textile, ceramic, wood, and cork - individual labels for each
  • Hazardous - for packaging that contained hazardous substances
  • Residual - for packaging that does not fit any recyclable stream

In addition to the component-level labels, the JRC proposal defines four "meta-labels" for waste receptacles, intended for use on bins and collection containers rather than on the packaging itself.

The colour coding scheme is: blue for paper-based packaging, yellow for plastics, green for glass, grey for metals, brown for compostable packaging. Composites take the colour of the dominant material group. Hazardous and residual labels have distinct colours.

Sorting labels are not material codes

A common point of confusion: sorting labels and PP01-PP12 material identification codes are different things with different purposes.

PP01-PP12 tell you what the packaging is made of. They are the PPWR Annex VI material identification codes - a technical classification for regulatory and industry use. There are 12 codes covering the main material families.

Sorting labels tell the consumer where to put the packaging after use. They are consumer-facing pictograms for waste sorting. There are 20 labels because the correct waste stream depends on more than just material - it depends on format, rigidity, glass colour, composite construction, compostability status, and whether the packaging contained hazardous substances.

A PET bottle (PP01) and a PET tray (also PP01) might both be "rigid plastic" for sorting purposes. But a PET film would be "flexible plastic" - same material code, different sorting label. A paper cup with a plastic lining might be PP08 (paper and cardboard) for material identification but "paper-dominant composite" for sorting. The mapping is not 1:1.

The attributes that determine the label

The sorting label for a component is determined by a combination of attributes:

  • Material code (PP01-PP12) - the starting point, but not sufficient on its own
  • Packaging format - is it rigid or flexible? This splits the plastics labels
  • Glass colour - clear, green, brown, or other. Determines which of the four glass labels applies
  • Composite type and dominant material - for multi-material packaging, the dominant material by weight determines the sorting label colour and group
  • Compostability certification - home compostable and industrially compostable get different labels, certified against EN 13432 or equivalent
  • Hazardous waste flag - packaging that contained hazardous substances gets the hazardous label regardless of material

The system applies a decision tree to these attributes. Material code narrows the field. Format refines it. Special cases (glass colour, compostability, hazardous content) override the default. The output is a specific sorting label, a label group, and a colour code.

Why derivation matters

The sorting label should be derived from component attributes, not manually assigned. There are several reasons for this:

First, accuracy. A manual label assignment depends on whoever is doing the tagging understanding the full decision tree. With 20 labels and multiple branching conditions, manual errors are likely - especially at scale across thousands of components.

Second, consistency. If a component's material or format changes, the sorting label must change with it. If labels are manually assigned, there is no guarantee that someone will remember to update the label when the underlying attributes change. A derived label recomputes automatically.

Third, auditability. If a market surveillance authority asks why a particular sorting label was applied to a component, "the system derived it from these attributes using the JRC decision tree" is a much stronger answer than "someone selected it from a dropdown."

What is still pending

Formal sorting label identifiers (official codes and pictogram files) have not been assigned yet. The JRC proposal defines labels by name, description, colour, and pictogram design, but the implementing act that will assign official identifiers and publish the final pictogram assets has not been adopted.

This means systems that implement sorting label derivation today are working from the JRC proposal. The underlying logic - which attributes map to which label group - is well-defined. The formal identifiers will be adopted when the implementing act is published. Merchant Packaging will adopt the official codes as soon as they are available.

What Merchant Packaging provides

Merchant Packaging derives the sorting label for every packaging component from its captured attributes. The label is never manually set. When any attribute changes - material, format, compostability status - the label is recomputed automatically.

The system exposes the sorting label code, label group, colour code, and a reference image via the API and in the UI. Artwork and repro teams can reference the label directly when preparing packaging designs. The data is also included in Digital Product Passport payloads.