Packaging Recycling and Sustainability Symbols in the EU: An Overview

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Packaging symbols are used to indicate whether it is recyclable, made using sustainable materials, or requires separate collection.  In this guide, we explain what importers and manufacturers in the European Union must know about packaging recycling and sustainability symbols such as the Mobius loop, Green Dot, WEEE symbol, OK Compost Label, and the FSC Recycled symbol.

Even though using some of these schemes and symbols are voluntary, companies that use recyclable and sustainable packaging materials might still get a competitive advantage due to the fact that more customers prefer buying sustainable products. Also, some retailers might refuse to purchase your products, if your product or packaging is not recyclable or is made using sustainable materials.

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Mobius Loop (Universal Recycling Symbol)

Mobius Loop

The Mobius Loop is one of the most commonly seen recycle symbols that are used in products or product packaging in the EU, as a sign indicating that the product or product packaging can be recycled.

The symbol is expressed in three clockwise chasing arrows, sometimes with a number in the middle of the arrows and a code below it, to indicate the nature of the materials (e.g. 22, PAP for paper).

Is the Mobius Loop mandatory?

The Mobius Loop is not a mandatory symbol for products or packaging under current EU regulations.

However, the Legislative Decree 116/2020 of Italy, which requires that all packaging materials sold in Italy must be properly labeled, made the Mobius Loop one of the mandatory symbols for packaging intended for consumption in Italy, starting on 31 December 2022. The purpose of the act is to facilitate packaging recycling and reduce packaging waste. Bulgaria also has similar legislation.

Packaging Materials

The Mobius Loop symbol is used in product packaging made of materials such as:

  • Plastic
  • Glass
  • Paper and cardboard
  • Wood
  • Metal
  • Textile
  • Composite materials (e.g. paper and metal, paper and plastic, glass and plastic)

Importers and manufacturers can voluntarily apply the Mobius Loop symbol to packaging materials that are made of the above-listed materials.

EU recycling Packaging Symbols

Requirements

As explained, importers and manufacturers may voluntarily place the Mobius Loop recycling symbol on the product packaging according to Decision 97/129/EC.

Material / Substance Symbols

Here we list some examples of the packaging materials and their corresponding abbreviations and numerical codes, which are based on Decision 97/129/EC establishing the identification system for packaging materials.

Material / Substance Code Number
Polyethylene terephthalate PET 1
High Density Polyethylene HDPE 2
Polyvinyl Chloride PVC 3
Paper PAP 22
Steel FE 40
Wood FOR 50
Cotton TEX 60
Jute TEX 61
Colorless glass GL 70
Paper and fiberboard/plastic C/PAP 81
Plastic/aluminum C/LDPE 90
Glass/plastic / 95

EN 13430 Standard

You can only use the Mobius loop if the packaging is recyclable according to EN ISO 13430 Packaging – Requirements for Packaging Recoverable. Some companies, such as TÜV SÜD offer EN 13430 testing and certification.

Costs

Packaging or product producers can apply the Mobius Loop symbol to their products without paying fees to any third parties. However, they might need to pay for the testing procedures to make sure that the packaging or the products are recyclable.

Green Dot

The Green Dot is a symbol trademarked by PRO Europe, which is a private umbrella organization for packaging and packaging waste recovery and recycling schemes. A product packaging labeled with the Green Dot indicates that for such packaging a financial contribution has been paid to a recycling organization that is a PRO Europe member.

By using the Green Dot symbol, importers and manufacturers do not have to recycle the packaging of each product themselves. Instead, the packaging recycling procedure is carried out by such organizations, whose task is to organize efficient and adequate national collection and recovery systems for sales and household packaging.

Extended Producer Responsibility (EPR)

Directive 94/62/EC requires that the Member States of the EU must ensure the establishment of an Extended Producer Responsibility (EPR) scheme for packaging by 31 December 2024, in accordance with the provisions set out by Directive 2008/98/EC. The purpose of this requirement is to facilitate the re-use, recycling, and recovery of waste in the EU.

The legislative measures include encouraging the development and production of multiple-use materials, and recovery and recycling of the materials. Some countries such as France and Germany have taken legislative actions to implement the EPR starting on 1 July 2022.

Procedure

Packaging producers who place packaging subject to national EPR schemes might be required to register with the specific systems or department. In the case of Germany, packaging producers are required to register in the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) via the LUCID Packaging Register.

Further, packaging producers should join recycling organizations such as PRO Europe members and pay a fee to have them fulfill the recycling responsibility for their company.

Packaging Materials

Packaging materials that might be covered by the EPR scheme include:

  • Cups for hot/cold beverages (including lids)
  • Containers and cups for foodstuffs (e.g., soups, smoothies, cereals, popcorn)
  • Household item packaging
  • Carrier bags
  • Gift packaging

Requirements

You should follow PRO Europe’s requirements, including signing an agreement with a PRO Europe member and paying for the right to use the Green Dot symbol.

Costs

The costs to implement the recycling procedures differ among products, industries, countries, and other factors. If you are a packaging producer using the PRO Europe service, you can refer to the price table provided by this organization.

If we take Germany as an example, the collection and recycling of a sparkling wine bottle with a volume of 375ml and weight of 500g is charged at a fixed fee of 0.0353 Euro per bottle.

Read the Participation Costs Overview 2021 published by PRO Europe to learn more.

OK Compost Label

Packaging or products bearing the OK Compost label indicates that such products or packagings are biodegradable and compostable in an industrial composting plant at temperatures between 55 to 60°C according to relevant EN standards.

Further, the OK Compost Home logo is applicable to products or packaging that can compost at lower temperatures. Such products or packaging are compostable in garden heaps.

Additionally, products or packaging featuring the OK Compost logos comply with the requirements of Directive 94/62/EC.

Is the OK Compost label mandatory?

The OK Compost Label is not mandatory for products or packaging. It is a sign showing that the products or packaging comply with the relevant standards on compostable materials and that such products or packaging are comparatively more eco-friendly to the environment. Companies can benefit from using the OK Compost Label for branding purposes since more consumers choose to use compostable products.

Packaging Materials

The OK Compost label is applicable to products or packaging such as:

  • Trays
  • Wrapping papers
  • Food and beverage containers
  • Envelopes
  • Glue labels

Requirements

In order to have their products or packaging OK Compost certified, and be able to apply the label to their packaging, companies need to follow the steps below.

Submit a certification application

Companies should submit an application to a certification body accredited by DIN-CERTCO. This is an example of the application form.

Lab testing

Companies must ensure the product or packaging is compostable by testing against the following EN standards:

a. European standard EN 13432: “Packaging – Requirements for packaging recoverable through composting and biodegradation – Test scheme and evaluation criteria for the final acceptance of packaging”

b. European standard EN 14995: “Plastics – Evaluation of compostability – Test scheme and specifications”

You can find more information about the testing requirements in this website.

Inspection tests

Besides testing, companies must pass an inspection carried out by an accredited body, in order to get certified and earn the right to use the label. The OK Compost certification is valid for 3 years. During this period, the accredited body might also perform further inspections to confirm and ensure continuous compliance with the certification requirements.

Costs

The cost to obtain an OK Compost certification includes fees for administration, assessment, license, testing, and other miscellaneous fees. According to the estimation of TÜV Rheinland, the costs of an initial certification are approximately between EUR 2,200 and EUR 3,400.

You can visit TÜV Rheinland’s this page to learn more about the fees.

WEEE Symbol

WEEE Symbol

The separate collection symbol, or WEEE symbol, is a crossed-out wheeled bin sign indicating separate collections for electrical and electronics equipment (EEE) and batteries. It is mandatory for most products covered by the Waste Electrical and Electronic Equipment (WEEE) Directive or the Battery Directive.

Is the WEEE symbol mandatory?

The WEEE symbol is mandatory under the WEEE Directive, for most electronics and electrical equipment. Also, it is mandatory for products covered by the Battery Directive.

Packaging Materials

The separate collection symbol is for EEE or batteries. On occasions when the placement of the separate collection symbol is limited by product size, it should be placed on the packaging.

Requirements

Sellers must register with relevant national authorities. The separate collection symbol must be printed on the product itself or the packaging visibly, legibly, and indelibly. For batteries, accumulators, and button cells containing mercury, cadmium, or lead, there is an additional requirement:

a. The letters Hg must be placed below the symbol if the product contains more than 0.0005% of mercury

b. The letters Cd must be placed below the symbol if the product contains more than 0.002% of cadmium

c. The letters Pb must be placed below the symbol if the product contains more than 0.004% of lead

Costs

There is no cost associated with the use of the WEEE symbol. However, there might be costs related to the registration with national authorities.

FSC Recycled Label

The Forest Stewardship Council (FSC) is an international non-profit organization established in 1993 that promotes responsible management of the world’s forests. The FSC allows certified companies to use the FSC labels on their products, which are FSC 100%, FSC Recycled, and FSC Mix.

The FSC Recycled label implies that the product is made from 100% recycled content. Products that bear the FSC Mix label are made using a mixture of materials from FSC-certified forests, recycled materials, and/or FSC controlled wood.

Products bearing an FSC 100% Label indicates that all the materials used in products are sourced from forests that have been audited by an independent third party and comply with the FSC’s social and environmental standards.

Is the FSC Recycled label mandatory?

The FSC Recycled label is not a mandatory label. However, companies can benefit from using the FSC Recycled label for branding purposes since the soaring number of consumers choose sustainable products. Also, the FSC Recycled label can also attract retailers that only sell sustainable products.

Packaging Materials

The FSC Recycled label is applicable to packaging materials such as:

  • Wooden furniture
  • Household decoration items
  • Wooden food containers
  • Yoga mats
  • Wooden packaging

Requirements

In this section, we briefly explain how to have your products or packaging FSC-certified.

Submit a certification application

Companies should choose an FSC-accredited certification body and submit a certification application.

Ensure Chain of Custody Standard

Companies should ensure that their suppliers and the companies from where the suppliers buy the materials are also FSC certified.

Auditing

A company has to be audited by an FSC-accredited certification body team and be assessed for its compliance with the relevant FSC requirements, before getting the certificate. Once a company is certified, it earns the right to use the FSC label on its products or packaging.

Costs

The cost to receive FSC certification varies depending on the product, and on the chosen FSC-accredited certification body.

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  • 3 Responses to “Packaging Recycling and Sustainability Symbols in the EU: An Overview

    1. WENDY HONG at 11:18 am

      Excellent article, just on plastic, is there a different symbol for single use (non-reusable) plastic containers? Intertek HK has mistakenly wanted us to use an open circle with an arrow symbol (pity unable to paste picture in here) for our PP item that we have recycle symbol with 5 etched on the products.

    2. Stuart Chundrlek at 1:36 am

      I believe that the French Triman Symbol is also a requirement in France and has been since 2015. The latest Environmental Law (Code de l’environnement Art. L541-9-3) has both expanded the use of this logo and has also limited or eliminated the allowable use of the Green Dot symbol for products sold into France.
      If I remember correctly, this has caused some argument within the EU as this places French Law against the laws of other member states, especially regarding the Green Dot symbol. I am interested in finding out how this plays out within the EU.

    3. Scott Peters at 8:29 pm

      Great article. One question, is there a penalty for having the wrong coding on a plastic article? For example, having the Recycle Symbol with “1” in the chasing arrows but showing PP under the logo?

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