Packaging Recycling and Sustainability Symbols in the EU: An Overview

Are you planning to use packaging recycling and sustainability symbols on your products or packaging in the EU? This article covers several symbols, such as the Mobius Loop, the Green Dot, and the OK compost labels.

While most of the symbols we cover are voluntary, some might be compulsory in some countries.

Note: This article has been updated since the video was recorded. The video may contain some errors.

Mobius Loop (Universal Recycling Symbol)

The Universal Recycling Symbol is also known as the Mobius Loop, and, according to our research, it can be used on a voluntary basis. It is based on the “Mobius strip” and depicts three chasing arrows, which reference the cyclical process of reusing and recycling products or materials.

Companies that affix the Mobius Loop to their products are signalling the recyclability of their products or packaging. If they do so, they may need to provide evidence that their products and packaging are indeed recyclable.

For example, according to the “Guidelines for Voluntary Environmental Labeling” published by the CONAI, companies affixing the Mobius Loop on products for sale in Italy can only do so if they are in compliance with the requirements of the EN ISO 14021 standard.

Note that we were unable to find information regarding the accepted usage of the Mobius Loop in other EU countries.

Commission Decision 97/129/EC: Identification System For Packaging Materials

Commission Decision 97/129/EC establishes material identification codes for plastics, paper, and other packaging materials.

These codes, which are generally voluntary, are provided as abbreviations and numbers. They indicate the nature of the packaging materials to facilitate their collection, reuse, and recovery.

Product scope

Commission Decision 97/129/EC covers all packaging and packaging waste covered by the Packaging and Packaging Waste Directive, such as the following:

• Plastic packaging
• Paper packaging
• Aluminium packaging
• Glass packaging

Identification system

Annexes I to VII of the Decision provide the covered categories of packaging material, their abbreviations, and numberings. We list several examples of such in the table below.

Annex	Material category	Material examples	Abbre viations	Numbering
I	Plastic	a. Polyethylene terephthalate b. High-density polyethene c. Polyvinyl chloride	PET HDPE PVC	1 2 3
II	Paper and fibreboard	a. Corrugated fibreboard b. Non-corrugated fibreboard c. Paper	PAP PAP PAP	20 21 22
III	Metals	a. Steel b. Aluminium	FE ALU	40 41
IV	Wood	a. Wood b. Cork	FOR FOR	50 51
V	Textile	a. Cotton b. Jute	TEX TEX	60 61
VI	Glass	a. Colourless glass b. Green glass a. Brown glass	GL GL GL	70 71 72
VII	Composites	a. Paper and fibreboard / Plastic b. Plastic / Miscellaneous metals c. Glass / Aluminium		80 92 96

Countries where material identification codes are mandatory

According to our research, some countries in the EU made the material identification codes set by Commission Decision 97/129/EC mandatory. Note that the list below might not be exhaustive.

Italy

As for article 3 of the DECRETO LEGISLATIVO 3 settembre 2020, n. 116, producers in Italy must indicate what material their packaging consists of, based on Commission Decision 97/129/EC.

Bulgaria

Per Article 5 of Bulgaria’s Regulation on Packaging and Packaging Waste, producers should mark their packages with the appropriate material identification codes specified in Commission Decision 97/129/EC.

Extended Producer Responsibility (EPR)

The Extended Producer Responsibility (EPR) is an environmental policy that shifts the financial, administrative, or physical responsibility of recycling from governments to businesses. According to the Packaging and Packaging Waste Directive, EU member states must establish EPR schemes for all packaging by 2024.

As a result, companies have the obligation (or will be obligated by 31 December 2024, according to the national legislation of each EU country) to either:

a. Collect, dispose, and recycle their used sales packaging; or

b. Join a national Producer Responsibility Organisation (PRO) that collects, disposes of, and recycles the waste on their behalf in exchange for a fee

In the latter instance, companies can comply with the EPR’s requirements per the Packaging and Packaging Waste Directive by signing an agreement with a PRO Europe member organisation (or other organisations authorised in EU member states).

The PRO then collects, recycles, and disposes of the waste in return for a fee. By joining a PRO Europe member organisation, you also earn the right to affix the Green Dot symbol on your packaging.

By using the Green Dot lot, you are indicating that your packaging waste will get handled by a PRO Europe member organisation. While the Green Dot is generally voluntary, some countries might make its use mandatory (at the moment only Spain, as far as we know).

Some countries, such as France, set different labelling requirements. Below, we provide a few examples of countries and their respective packaging waste requirements.

Green Dot (Germany)

Der Grüne Punkt is German for “The Green Dot”. It is a leading provider of EPR solutions in Germany and a founding member of PRO Europe. As a PRO, Der Grüne Punkt frees companies from their packaging waste take-back and recovery responsibilities in exchange for a fee. It also owns the trademark of the Green Dot symbol.

Requirements

Germany mandates producers to adhere to the following:

1. Register their business entity with the Central Agency’s LUCID packaging register

2. Join a PRO (e.g. Der Grüne Punkt) and submit data reports on their packaging volumes

3. Pay an eco-contribution based on their annual waste volumes per product category

Affixing the Green Dot symbol is voluntary.

Costs

Producers pay Der Grüne Punkt per ton of circulated packaging in Germany. The fee depends on the different materials. Here are some examples:

• Glass – 1 Euro/ton
• Paper/board/cardboard – 3 Euro/ton
• Ferrous metals – 5 Euro/ton
• Aluminium – 13 Euro/ton
• Plastics – 17 Euro/ton
• Beverage carton packaging – 13 Euro/ton
• Other composites packaging – 13 Euro/ton
• Other materials – 2 Euro/ton

Producers should also pay a packaging licensing fee for the right to use the Green Dot symbol. They can use Der Grüne Punkt’s license calculator to determine how much it costs to acquire said fee by providing the following information:

• Start of contract (by calendar year)
• Material type and volume
• Type of contract

Green Dot (Spain)

Ecoembes is the Spanish PRO Europe member organisation, and it offers packaging collection, sorting, and recycling services. It also charges consumers a fee to take back packaging waste and recycle it.

Requirements

Here are some of the requirements:

1. Producers should sign an agreement with Ecoembes (or other PRO) and contribute a fee

2. Spain mandates producers to affix the Green Dot symbol to their household packaging units. According to PRO Europe’s website, this requirement is generally inapplicable to secondary and tertiary packaging that doesn’t end up in a private household

Costs

A producer must pay a fee per kilogram to use the Green Dot symbol and have Ecoembes collect their packaging waste. This fee depends on the recyclable material used for packaging. Here are some examples:

• Steel beverage cans – 0.146 Euro/kg
• Other steel containers – 0.138 Euro/kg
• Aluminium beverage cans – 0.113 Euro/kg
• Other aluminium containers – 0.096 Euro/kg
• PET drink bottles ≤ 3L – 0.44 Euro/kg
• Other PET drink bottles – 0.415 Euro/kg
• HDPE – 0.367 Euro/kg
• Food and drink carton boxes – 0.514 Euro/kg
• Paper and cardboard – 0.091 Euro/kg
• Ceramic – 0.02 Euro/kg
• Wood and cork – 0.100 Euro/kg

Green Dot (Other Countries)

31 PRO Europe members aid companies in collecting and recycling their packaging waste in return for a fee. Below we list a few of those members:

• ARA Altstoff Recycling Austria AG (Austria)
• Citeo (France)
• VALORLUX (Luxembourg)
• Rekopol Organizacja Odzysku Opakowań S.A. (Poland)
• FTI (Sweden)

As mentioned, using the Green Dot symbol is voluntary in most countries.

Info-tri (France)

CITEO, the French PRO Europe member, has published a set of harmonised Info-tri (Sorting Info) labels to improve consumers’ packaging waste sorting habits. The Info-tri labels are mandatory for household packaging and consist of the following four design elements:

• The Triman logo
• The strapline “Sorting made simpler”
• The packaging components (which show that different components might need to be separated)
• The term “sorting bin/glass bank”

The label should have a green background for glass products, and yellow for other products.

Requirements

France has mandated producers to affix the appropriate Info-tri labels, inclusive of the Triman logo, onto their household paper and packaging waste

To do so, producers in France must sign an agreement with CITEO, or other PRO authorised to license the use of the Triman logo and contribute a fee. Note that additional requirements might also apply, in order to comply with the French’s EPR requirements.

Costs

We advise you to contact CITEO to learn about the fee structure, as we couldn’t find any information on their website.

Italy

While there are no PRO Europe Italian members, there are several organisations that can help you to comply with the EPR requirements, including:

a. CONAI – A non-profit private national packaging consortium that manages recycling and packaging waste recovery

b. COMIECO – Another national consortium in Italy that manages the collection, recovery, and recycling of paper and board packaging waste

c. CiAl – A national non-profit consortium that packages, collects, recovers, and recycles aluminium packaging waste

If you join any of these organisations, you earn the right to use their respective trademarked logos. We explain some of their requirements and costs below.

Requirements

In order to join CONAI’s system, you should:

• Submitting an application form
• Having their eligibility evaluated by CONAI
• Signing a license agreement

CONAI will then collect, recycle, and dispose of your waste, in exchange for a fee. You might also choose to affix the CONAI trademarked logo on your packaging. COMIECO and CiAl have similar requirements.

Note that, in order to comply with Italy’s EPR requirements, there might be additional requirements than joining an EPR organisation. You can learn more in this article.

Costs

By signing an agreement with CONAI, importers and manufacturers must pay an environmental contribution fee, which depends on the type and amount of material. Here are some examples:

• Steel – 800 Euro/ton
• Aluminium – 700 Euro/ton
• Paper – 5-240 Euro/ton
• Wood – 900 Euro/ton
• Plastic – 60-560 Euro/ton
• Bioplastic – 294 Euro/ton
• Glass – 29 Euro/ton

You can contact COMIECO and CiAl to learn more about their price structure.

OK compost Label

Products or packaging bearing the OK Compost label indicate that such products or packaging are compostable. There are two types of labels:

• OK compost INDUSTRIAL
• OK compost HOME

OK compost INDUSTRIAL

Products or packaging carrying the OK compost INDUSTRIAL label are deemed to:

a. Be compostable in an industrial plant at temperatures between 55 to 60°C

b. Comply with the requirements of Packaging and Packaging Waste Directive and the harmonised EN 13432 standard

OK compost HOME

Packaging or products bearing the OK compost HOME label are compostable in garden heaps at lower temperatures. The OK compost HOME certification scheme is not based on any standard; instead, it is based on technical requirements set by TÜV AUSTRIA. These requirements also serve as the foundation for several other standards, such as the following:

• Australia’s AS 5810 for biodegradable plastics
• France’s NF T 51800 for plastics
• Europe’s prEN 17427 for packaging

Is the OK compost label mandatory?

The OK compost Label is not mandatory. However, it indicates that the products or packaging comply with the relevant standards and requirements on compostable materials.

Thus, companies can benefit from using the OK compost label for branding purposes since more and more consumers choose to use compostable products, given the fact that they are more eco-friendly than similar, non-compostable products.

Product scope

The OK compost label applies to products such as the following:

• Packaging material
• Disposable cutlery
• Disposable cutlery and plates

Requirements

Companies need to follow the steps below to have their products or packaging certified, and thus earn the right to affix the label to their packaging.

Submit a certification application

Companies should apply by filling in the relevant form on the TÜV AUSTRIA website.

The form requires several pieces of information, including:

• Trademark
• Preferred certification scheme
• Product information
• Company information

Lab testing

Companies seeking to acquire an OK compost certificate must ensure their products are tested per the harmonised EN 13432 standard (for OK compost INDUSTRIAL) or relevant technical requirements (for OK compost HOME).

The tests should be performed by TÜV AUSTRIA-registered labs, such as the following:

• AIMPLAS (Spain)
• TUV Rheinland Shanghai (China)
• INNOVHUB SSI (Italy)

Costs

The cost to obtain an OK compost certification includes the following types of fees:

• Administration fee
• Conformity assessment fee
• License fee
• Testing fee

You can learn more on this page.

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.

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.

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 registering with national authorities and relevant lab testing.

FSC Recycled Label

The Forest Stewardship Council (FSC) is an international non-profit organisation that promotes responsible management of the world’s forests. The FSC allows certified companies to use the following FSC labels on their products:

• FSC Recycled
• FSC 100%
• FSC Mix

The FSC Recycled label implies that the product contains 100% of recycled content.

Products that bear the FSC Mix label contain materials from FSC-certified forests, recycled materials, and/or FSC-controlled wood.

Products bearing an FSC 100% Label indicate that all the materials used in FSC-certified products:

a. Come from forests audited by an independent third party

b. Comply with FSC’s social and environmental standards

Is the FSC Recycled label mandatory?

Usage of the FSC Recycled label is not compulsory; however, companies can benefit from using the FSC Recycled label for branding purposes due to the rising number of consumers choosing sustainable products. Also, the FSC Recycled label can attract retailers that only sell sustainable products.

Product scope

The FSC labels apply to products such as:

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

Requirements

This section briefly explains 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 must undergo the following to ensure it conforms to relevant FSC requirements:

• Auditing by an FSC-accredited certification body
• Compliance assessment

When the FSC-accredited body deems the company compliant with the applicable FSC provisions, it issues the company 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 the chosen FSC-accredited certification body.