Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) significantly changes the landscape of packaging labelling in Europe. And there is one important point: it is not simply a matter of replacing the current recycling symbol with another; the Regulation introduces a harmonised European system for providing information on the composition and management of packaging.
From the perspective of minibottle collecting, this has three interesting implications:
- The availability of a new reference date as a tool for dating miniatures, not only Spanish ones, but across Europe.
- The emergence of new labels or back labels adapted to the new packaging regulation (PPWR).
- The emergence of different versions of the pictograms on export miniatures, due to the requirement to label them in the language of the country of sale.
We currently come across things such as:
- PAP 21 / PAP 22 for paper and cardboard.
- PET 1, HDPE 2, PP 5, etc. for plastics.
- GL 70, GL 71 and GL 72 for glass.
- The Green Dot.
- The waste bin symbol/tidyman.
- National symbols indicating the yellow, blue, green, etc. bins.
- Instructions such as ‘recyclable’, ‘separate and place in…’.
The PPWR aims to harmonise all this information at European level.
Article 12 stipulates that, under certain conditions, packaging must bear a harmonised label based on pictograms, indicating the material composition of the packaging and facilitating its correct sorting by the consumer.
The Commission expressly states that the abbreviations used by previous systems will no longer be permitted as a means of identifying the material once the new harmonised system is fully operational.
Member States will not be able to maintain their own national labelling systems indefinitely alongside the harmonised European system.
When will the new symbol have to be displayed?
The Regulation came into force on 12 August 2026, although many of the specific labelling requirements come into effect at a later date (by 12 August 2028 or 24 months after the entry into force of the implementing acts setting out the pictograms and specifications, whichever is later).
