Packaging recycling symbols in the EU: the marks required now and the EU label that waits

No EU-wide recycling symbol is required on your packaging today. The EU sorting label of the Packaging and Packaging Waste Regulation (PPWR) does not apply yet (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). What you must print depends on the country you sell into: France asks for the Triman logo with a sorting instruction, Italy for environmental labelling, Spain for the name of the container. The Green Dot is a trademark, not a legal duty.

What you do:

1. List the EU countries you ship packaged goods to. The EU label is not in force, so the national rules below are the recycling marks in force now.
2. Selling to France: print the Triman logo and, beside it, the sorting instruction your producer responsibility organisation (the éco-organisme) gives you. On household packaging they go on the packaging itself, or on a sticker on it; the documents fallback is for products, not packaging (R. 541-12-21, copy in Ineris AIDA; L541-9-3; Service Public). The French rule in full is on Triman logo in France.
3. Selling to Italy: label the packaging so that it helps collection, reuse, recovery and recycling and tells the consumer where it goes, and state the packaging material per Decision 97/129/EC. This has applied since 1 January 2023 (Art. 219(5) D.Lgs. 152/2006). A pack for a business needs only the material code (Ministry guidelines, adopted by decree no. 360 of 28 September 2022). The Italian rule in full is on Italy packaging labelling.
4. Selling to Spain: on household packaging, say which container it goes in. This has applied since 1 January 2025 (Art. 13(2) RD 1055/2022).
5. Selling to Germany: no recycling mark is required by the section read here, and a material code is optional. If you use a material code anywhere, take the number and letters from the Decision 97/129/EC list below and from no other list. This page reads the rules of France, Italy, Spain and Germany only (Decision 97/129/EC; § 4 VerpackDG).
6. Do not print the Green Dot because you think it is required. It is a trademark you use only under a contract with a national scheme (PRO Europe).
7. Leave the EU sorting label alone until the Commission publishes the act that draws it. Print nothing in advance and call it the EU label.

No EU recycling symbol is required on packaging yet

Here is every mark you will meet on packaging, and whether the law asks for it.

The EU sorting label starts after 12 August 2028, on a date not yet fixed

From 12 August 2028, or 24 months after the implementing acts under Art. 12(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 6Click opens the article on EUR-Lex. or Art. 12(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 7Click opens the article on EUR-Lex. enter into force, whichever is later, packaging placed on the market carries a harmonised label with information on its material composition. The label is based on pictograms and must be easily understandable, including for persons with disabilities (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). The Commission was to adopt the act that draws it by 12 August 2026 (Art. 12(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 6Click opens the article on EUR-Lex.). No such act had been published in the Official Journal by 5 October 2026, and the Commission’s own FAQ, updated in August 2026, still describes the act as one to be adopted (Commission FAQ, section VIII). The label therefore applies 24 months after that act enters into force, which is after 12 August 2028. The full calendar of PPWR duties is in PPWR.

Your shipping carton is inside the duty. The label does not apply to transport packaging or to packaging in a deposit-return system, but the text keeps e-commerce packaging in: “With the exception of e-commerce packaging, this obligation does not apply to transport packaging” (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). That makes the label a duty of the manufacturer and of the importer: each may place on the market only packaging that meets Articles 5Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5Click opens the article on EUR-Lex. to 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex., and an importer checks that the packaging is labelled under Article 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. (Art. 15(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 1Click opens the article on EUR-Lex., Art. 18(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 1Click opens the article on EUR-Lex., Art. 18(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 2Click opens the article on EUR-Lex.).

Three more rules of the same article:

• Online sales. The label information must also be available to the buyer before purchase in an online sale, in a language the country of sale determines. Where the label does not fit on the packaging, it goes on the grouped packaging, and where that does not work either, the information goes in a single electronically readable code (Art. 12(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 5Click opens the article on EUR-Lex.).
• Stock. Packaging made in the Union or imported before the label date that does not carry the label may be made available on the market until 3 years from the date of entry into force of the labelling requirement (Art. 12(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 12Click opens the article on EUR-Lex.).
• Other labels. Reusable packaging carries its own label from 12 February 2029 or 30 months after the label act, whichever is later (Art. 12(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 2Click opens the article on EUR-Lex.). A label that states the recycled content or the biobased content is voluntary, but if you print one it follows the specifications of the act (Art. 12(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 4Click opens the article on EUR-Lex.; Commission Notice, point 13).

The material codes of Decision 97/129/EC name the material, not the bin

Decision 97/129/EC is the EU’s current identification system for packaging materials. It sets a number and an abbreviation for each material. It does not draw a symbol and it does not say where the packaging goes. Selected codes (Decision 97/129/EC, Annexes I to VII):

The Decision says their use “shall be voluntary” (Art. 3), and the Commission’s guidance repeats that the use is voluntary for manufacturers and that EU countries must ensure that no other system is used. If you print a material code, it is the one in the table (Commission Notice, point 13). The Decision is repealed from 12 August 2028 (Art. 70(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 70, paragraph 2Click opens the article on EUR-Lex.).

Deposit-return packaging carries a label set by the country of the scheme

Drink bottles and cans in a deposit-return scheme are outside the harmonised sorting label. The text puts them under a different rule: such packaging “shall be marked with a clear and unambiguous label”, and the label is a national one. The packaging may also carry a harmonised colour label defined in the Commission’s act, and a country may require it if that causes no barriers to trade (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). A country may also identify packaging in any other deposit scheme by a symbol across its territory, and a country may not prohibit labels for the deposit schemes of other countries (Art. 12(10)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 10Click opens the article on EUR-Lex.).

The formats concerned in the mandatory schemes are single-use plastic beverage bottles and single-use metal beverage containers up to three litres, with 90% separate collection by 1 January 2029 (Art. 50(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 50, paragraph 1Click opens the article on EUR-Lex.). If you sell these in an EU country with a scheme, the label of that country applies to you. The Commission’s FAQ puts it the same way: “products will have to comply with the DRS label of the Member State where they are made available on the market” (Commission FAQ, section VIII).

France requires the Triman logo and a sorting instruction beside it now

Article L541-9-3 of the French Environment Code says that every product placed on the market for households under an EPR scheme, except household glass drink packaging, carries a sign telling the consumer that the product has sorting rules, and an instruction on how to sort or where to take the waste. If several parts of the product have different sorting rules, the instruction goes part by part (L541-9-3). The sign is the Triman logo, or another common sign that EU law or another EU country’s law makes mandatory, with the same sorting information. The French administration names the crossed-out bin for electrical goods as an example; the case is in WEEE symbol (Service Public).

What each part is:

• The Triman logo. A small figure with an arm out, three arrowheads curling away from its hand, inside an open ring (as the Ministry draws it for its Info-tri campaign). Your producer responsibility organisation gives you the logo when you join, and a packaged product needs one logo, placed on the packaging, with the product’s and the packaging’s sorting instructions beside it (ADEME; Ministry).
• The Info-tri. The Ministry’s name for the new sign that accompanies the Triman logo and tells the consumer where to sort the product, the packaging or the old appliance. The Ministry says it has been rolling out since summer 2022 on a large number of products under an EPR scheme. The sorting instruction the law requires beside the logo is proposed by your organisation and accepted by the ministers for the environment and for consumer affairs, and it must be on the product, its packaging or, failing both, the documents supplied with it (R. 541-12-18, copy in Ineris AIDA; Ministry; Service Public).
• Small packages. Where the largest side of the product or packaging is under 10 cm², or a cylinder or sphere is under 20 cm², and no document comes with it, both may go on a digital medium. Between 10 and 20 cm² (20 and 40 cm² for a cylinder or sphere) only the instruction may go digital; the logo stays on the product or packaging (Service Public).

Do nothing and the French code, in the copy archived on 20 January 2025, sets an administrative fine of up to EUR 3,000 for a person and EUR 15,000 for a company for failing the information duty of L541-9-3, the sorting sign and its instruction. The Ministry says the fine can be applied per product without the sign and the instruction, and that the code’s amounts are maximums (L541-9-4, the fine is set by the Consumer Code procedure it names; Ministry FAQ, question 9). The scheme you join for France, and the registration number it gives you, are in packaging EPR.

Italy requires environmental labelling on all packaging since 1 January 2023

Paragraph 5 of Article 219 of the Italian Environmental Code says all packaging “must be suitably labelled” under the applicable UNI technical standards and the determinations of the European Commission, to make collection, reuse, recovery and recycling easier and to give consumers correct information on where packaging ends up. It also puts a duty on producers to state the nature of the packaging material, on the basis of Decision 97/129/EC (Art. 219(5) D.Lgs. 152/2006; Art. 3(3)(c) D.Lgs. 116/2020). These duties run from 1 January 2023 (paragraph 5.2). The text says “all packaging” and names no exception for packaging that arrives in a distance sale. Italy is the one country here that words the material code as a duty and not as a choice.

Packaging without these requirements that was already on the market or already labelled on 1 January 2023 may be sold until stock runs out (the footnotes to Art. 219, quoting Art. 15(6) of D.L. 183/2020).

Spain requires household packaging to name its container since 1 January 2025

Article 13 of the Spanish packaging decree sets the duties. Household packaging indicates the fraction or container in which its waste goes. For a package made of several materials that can be separated easily, it names the container for each; when they cannot be separated, or for composite packaging, it names the container of the material that weighs most, unless a better collection route is shown (Art. 13(2) RD 1055/2022). Reusable packaging says it is reusable and carries the deposit-return symbol where a scheme applies. The marking is on the packaging or its label, clearly visible, legible and durable (Art. 13(2), 13(8)). These marking duties apply from 1 January 2025 (Final Provision 5). The text carves out no distance sales.

The material code is a choice here: packaging “may be marked” with the abbreviations or numbers of Decision 97/129/EC, and the marking is voluntary unless EU law says otherwise (Art. 13(1)). Marking packaging with “respetuoso con el medio ambiente”, or any equivalent words that could lead to its abandonment, is banned (Art. 13(3)).

What Spain adds for packaging, with the representative route, the collective systems, the penalties and the 2026 declaration, is on Spain packaging EPR.

Germany lets you print the material numbers of the Decision and no others

Section 4 of the German packaging law, the VerpackDG, says packaging may be marked with the numbers and abbreviations of its Annex 2 to identify the material, and that using other numbers and abbreviations for the same materials is not permitted (§ 4 VerpackDG). It is a permission, not a duty, and this page reads that section only. The German registration is in packaging EPR.

The Green Dot is a trademark and a payment signal, not a legal requirement

The Green Dot is two arrows, one dark green and one light green, curling round each other inside a circle, with the registered-trademark sign beside it. Its owners describe it as “a financing symbol for producer responsibility (EPR) - not an eco-label”. It shows that a financial contribution has been paid to a nationally authorised take-back system, it is protected as a trademark worldwide, and in principle you may use it only under a contract with the national scheme of each country where you sell (PRO Europe). No law read for this page requires it. Spain lets packaging carry symbols that show it belongs to an EPR system (Art. 13(2) RD 1055/2022), which is a permission too.

In France a penalty rule was aimed at the Green Dot. Article L. 541-10-3 of the Environment Code says that “les signalétiques et marquages pouvant induire une confusion sur la règle de tri ou d’apport du déchet issu du produit sont affectés d’une pénalité”, and leaves the definition to a ministerial order (L. 541-10-3, as amended by loi no. 2026-602 of 8 July 2026, art. 5, version in force from 10 July 2026; text read on 5 October 2026 in the Ineris AIDA copy). That penalty is a surcharge on the EPR fee you pay your eco-organisation, at least the amount of the fee itself. The order of 30 November 2020 defined them as “les figures graphiques représentant deux ou plusieurs flèches enroulées et inscrites dans un cercle”, which is the Green Dot, from 1 January 2021, with exceptions for the Triman sign, signs another EU country regulates, and brand logos; the Conseil d’État found it aimed “de façon indirecte mais non équivoque” at the Green Dot (Ineris AIDA copy of the order). The Conseil d’État annulled that order on 30 June 2023, together with point 4° of II of the annex to the order of 25 December 2020 on the eco-organisations’ terms of reference. The ground was that France had notified the Commission of the law but not of the rule aimed at one sign, as Directive (EU) 2015/1535 requires (Conseil d’État, decision no. 449872, read on 5 October 2026). Citeo, one of the three household-packaging eco-organisations, wrote on 19 November 2020 that the Green Dot “ne doit plus être apposé sur les emballages” since 1 January 2021 (Citeo). That statement predates the annulment. No order replacing the annulled one was found, so no French rule penalises the Green Dot in the sources read: the law leaves the marking to a ministerial order. No law requires it either, so leaving it off packaging for France costs you nothing.

The PPWR will narrow this. By 12 February 2027, packaging in an EPR scheme may be identified only by a symbol in a QR code or other digital marking, which must not mislead the consumer about recyclability or reusability (Art. 12(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 9Click opens the article on EUR-Lex.). The Commission’s guidance reads this as a ban on physical EPR labels (Commission Notice, point 13).

National sorting marks are due to end when the EU label applies

The Commission’s guidance says packaging labelling under Article 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. “is exhaustive and fully harmonised, except as regards deposit and return schemes”, that national rules which add sorting instructions “are not allowed”, and that EU countries “will not be allowed to keep their national labels next to EU harmonised labels” after the date the EU label applies, so the national measures should be repealed or adapted before that date (Commission Notice, point 13). On that reading it reaches the Triman logo with its sorting instruction, and the Italian and Spanish rules that add sorting information; the guidance names no country. The Commission adds that a national measure judged disproportionate for the internal market “should be repealed as soon as possible”. The guidance is not law.

Until the label applies, the three national rules are still in force and are enforced as written. One limit sits on that. Art. 4(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. says EU countries may keep additional national information requirements, but must not prohibit, restrict or impede the placing on the market of packaging that complies with the Regulation for failing them. The Commission’s FAQ reads this as meaning that fines for such additional national requirements “are not allowed”, while fines for national requirements the PPWR itself permits are (Art. 4(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex.; Commission FAQ, section XV, question 13). That is guidance, not law, and no text read for this page says whether it reaches the French, Italian or Spanish marks. So keep printing the marks.

What the law leaves open

• What the EU label looks like and when it starts. The Regulation gives only the words “pictograms” and “material composition”, and the act that draws the label is overdue. The date is 24 months after that act enters into force. Meanwhile: print the national marks the countries above require and nothing marked as the EU label.
• Whether the material numbers may stay on packaging after 12 August 2028. The Decision is repealed from that date (Art. 70(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 70, paragraph 2Click opens the article on EUR-Lex.), and the Commission’s guidance says the abbreviations “will be no longer allowed after 12 August 2028”. Yet the PPWR keeps Article 8(2) of the old Directive, which points to the Decision, in force for 30 months after the label act (Art. 70(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 70, paragraph 1Click opens the article on EUR-Lex.). The texts do not say how the two fit together. Meanwhile: treat the code as optional and plan to drop it when the EU label arrives.
• Whether a ministerial order has replaced the annulled one, and whether an eco-organisation’s own tariff charges for the Green Dot. The law’s penalty needs a ministerial order. The Ineris AIDA copies list none since the annulment, and the articles on the Triman sign and the sorting instruction (R. 541-12-17 to R. 541-12-21) say nothing about the Green Dot; Légifrance’s official search was not run. Citeo’s current tariff was not read. Meanwhile: leave the Dot off packaging for France.
• Whether the Green Dot may stay on packaging. Art. 12(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 9Click opens the article on EUR-Lex. says identification of an EPR scheme is “only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology”, and opens with “By 12 February 2027”. The Commission reads it as a ban on physical labels. No text says what happens to a printed Green Dot, or from which day. Meanwhile: the Dot is optional, so a package without it breaks no rule.
• The penalty for a missing label in Spain, and whether Italy’s applies. Italy: packaging without the Article 219(5) requirements carries an administrative fine of EUR 5,000 to EUR 25,000 for whoever places it on the market (Art. 261(3) D.Lgs. 152/2006). Whether the Commission’s reading of Art. 4(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. (above) stops that fine is not settled. Spain: Ley 7/2022 Art. 108(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office.(b) makes a breach of the law and its implementing rules serious (EUR 2,001 to 100,000, Art. 109(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office.(b)); Art. 108(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office.(b) and (d) make some breaches minor (up to EUR 2,000, Art. 109(1)(c)). The class for a marking breach is not settled (Ley 7/2022). Meanwhile: treat the labelling as binding, since both texts are written as duties.
• How the Italian and Spanish duties apply to a seller outside the country. Both texts say “all packaging” and “household packaging” and carve nothing out for distance sales. For Spain, MITECO’s marking note of 10 March 2026 (refundida) lets a QR code replace the printed container mark for packaging with labels in several languages for several EU countries (point 2(b)), and for packs 10 cm wide or less (point 4(b)) (MITECO note). It does not mention distance sales, and it carries no notice on whether it binds. For Italy, no official guidance read for this page addresses the case. Meanwhile: treat the duty as covering packaging you ship into the country.