Recyclable by design: what the new EU packaging rules mean for labels

Europe is moving forward with packaging circularity. By 2030, all packaging placed on the EU market must be recyclable by design under the Packaging and Packaging Waste Regulation (PPWR). A new European standard series, EN 18120, has just arrived as a key piece of that puzzle. Here is what it means, why it matters for label materials and what companies should be thinking about now.

Why standardization matters for PPWR

Turning a policy target into something manufacturers can actually act on requires clear, science-based criteria. That is where CEN, the European Committee for Standardization, comes in. The EN 18120 series defines how plastic packaging should be designed to work within collection, sorting, and recycling systems across Europe.
A practical tool at the heart of these standards is the traffic-light assessment table. It classifies packaging components and materials as:

Fully compatible (green)
Limited compatible (yellow)
Not compatible (red)

This framework creates a shared, transparent language for what “recyclable by design” actually looks like in practice. It helps identify materials that perform well in recycling systems and flags those that will eventually need to be phased out under PPWR.

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

Labels are part of the packaging, not an afterthought

One of the clearest messages from EN 18120 is that labels cannot be assessed in isolation. How a label material behaves during recycling directly affects the recyclability of the whole package.
This is not just a technical detail. For packaging designers and brand owners, it means design choices about labels will carry real weight in meeting PPWR requirements. Getting this right calls for closer collaboration across the value chain between material suppliers, packaging designers, and brands.

“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 consideration and alignment with emerging design-for-recycling criteria is becoming increasingly important.”

Standards today, regulation tomorrow

EN 18120 is not a legal requirement today. It serves as reference material for the European Commission’s Joint Research Centre (JRC), which is developing the official PPWR design-for-recycling guidelines. Those guidelines are expected in 2028, with full compliance required by 2030.

That timeline is shorter than it sounds. Companies that start aligning their packaging strategies now will have more room to adapt, less need for costly redesigns later, and a clearer picture of where their materials stand.

EU focus, global implications

PPWR applies to the EU market, but its impact is global. Any brand selling packaging into Europe regardless of where it is produced, will need to meet these requirements. That makes EN 18120 relevant to packaging value chains well beyond European borders.

Companies that get ahead of this now are better positioned for consistent sustainability strategies across markets, not just compliant ones for Europe.

Working with you on what comes next

At UPM Adhesive Materials, active participation in CEN standardization work is part of how we stay close to where regulation is heading. The goal is not just to ensure our own materials meet future requirements but to give customers the clarity and guidance they need to make informed decisions today.

If you want to understand how these standards affect your specific packaging format or label materials, our team is here to help you work through it.

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