Design for recycling under PPWR: what the CEN standards mean for label choices

In this edition of the Spotlight, the experts from UPM discuss what manufacturers have to bear in mind when choosing the right label in the context of PPWR and CEN standards requirements for recyclability.

The EU’s Packaging and Packaging Waste Regulation (PPWR) has applied since August 12, 2026, and its design for recycling requirements come next. The European Commission must adopt the detailed criteria by January 1, 2028, and from January 1, 2030, all packaging placed on the EU market must be recyclable by design.

To give manufacturers criteria they can act on, CEN, the European Committee for Standardization, tasked by the European Commission, has published the EN 18120 series. It defines how plastic packaging should be designed to work within European collection, sorting and recycling systems. The standards are not legally binding, but they serve as reference material for the European Commission’s Joint Research Centre, which is preparing the technical basis for the binding criteria. Equivalent standards for other packaging substrates, including paper, glass and metals, are under development and are expected to be published towards the end of 2026.

Green, yellow or red

At the heart of EN 18120 is a traffic-light assessment table that classifies packaging components and materials as fully compatible (green), limited compatible (yellow) or not compatible (red). It gives the value chain a shared language and flags materials that will eventually need to be phased out.

Why the label matters

EN 18120 makes clear that labels cannot be assessed in isolation. A label’s face material, adhesive and inks all affect what happens during grinding and washing. In PET bottle recycling, for example, PET flakes sink in the wash tank while polyolefin label fragments float and are separated out. An adhesive that stays on the flakes, or inks that bleed into the wash water, can lower the quality of the recyclate.

“The new CEN standards highlight that labels are not an isolated component, but a functional part of the packaging system,” says Santeri Marjamäki, Product Portfolio Compliance & Regulatory Enablement Manager at UPM Adhesive Materials. “Design choices related to label materials can influence sorting and recycling outcomes, which is why early alignment with emerging design for recycling criteria is increasingly important.”

Turning recyclability requirements into material choices

Understanding recyclability criteria is one challenge. Applying them to packaging and label material choices is another. UPM ProCycle™ brings adhesive technologies and circular label products together in one coherent portfolio, making it easier for converters and brand owners to select solutions for recyclability performance. Every product in the portfolio is externally recognized as recycling compatible, and independent testing verifies specific label functionalities such as clean release.

The portfolio includes solutions for rigid PET and HDPE packaging and continues to expand alongside evolving packaging circularity requirements. Most recently, the RP37 adhesive received RecyClass recognition of full recycling compatibility on HDPE containers. For brands that also want to reduce fossil raw material use, the UPM ProCycle portfolio includes Carbon Action PP, an ISCC PLUS certified bio-circular face film made with 30% renewable content on a mass balance basis.

The next step comes in 2027

The rules for recyclable packaging are becoming clearer, but the work is not finished. During 2027, the European Commission is expected to take the next major steps toward defining how packaging will be assessed under PPWR, building on the CEN standards. For converters and brand owners, this makes the coming year an important time to follow developments and align packaging and label choices with emerging requirements.

“We are actively engaged in the ongoing standardization work and closely follow the development of the recyclability criteria,” says Ashley Drew, Sustainability Manager at UPM Adhesive Materials. “Not only to ensure that our materials will comply, but because our customers need clarity and future-ready solutions.”

This content was sponsored by UPM.