EDANA, the leading global association for the nonwovens and related industries, represents over 270+ member companies across the entire supply chain, including producers of a wide range of packaged goods and, in some cases, contributors to the manufacturing of packaging materials themselves. As such, EDANA’s members are
directly impacted by the requirements of the Packaging and Packaging Waste Regulation (PPWR).
Brussels, 13th of August 2025 - EDANA, the leading global association for the nonwovens and related industries, represents over 270+ member companies across the entire supply chain, including producers of a wide range of packaged goods and, in some cases, contributors to the manufacturing of packaging materials themselves. As such, EDANA’s members are directly impacted by the requirements of the Packaging and Packaging Waste Regulation (PPWR).
As the European Commission prepares the Implementing Act on harmonised waste sorting labels under the PPWR, with the Joint Research Centre (JRC) providing a user manual that will likely inform the regulatory text, EDANA advocates for a flexible and pragmatic approach to labelling requirements.
Given the wide variety of packaging types used in the nonwovens sector, EDANA is concerned that certain proposed obligations could negatively affect packaging functionality, design, environmental performance, and regulatory consistency.
EDANA respectfully urges the European Commission to:
- Permit economic operators the option to use black-and-white or transparent waste sorting labels without mandatory colours
- Avoid any obligation to include text on labels indicating material composition
- Support flexible labelling approaches that allow operators to choose label placement based on packaging characteristics
- Encourage the voluntary use of QR codes or other digital solutions to provide detailed, language-specific sorting information
- Provide realistic guidance and exemptions for very small packaging where standard labels or data carriers cannot be applied
- Adopt a phased implementation with clear, neutral pictograms and sufficient timelines to enable industry adaptation.
NO COLOUR OBLIGATION
EDANA calls on the Commission to allow economic operators the option to use black-and-white or transparent waste sorting labels, without mandatory colours.
Packaging in the nonwovens sector often depends on pre-set printing processes with limited colour cylinders, and requiring additional colours would increase production complexity and costs, especially for small or customised packaging formats.
Moreover, mandatory colours may clash with brand designs or reduce label visibility, affecting consumer recognition.
From an environmental perspective, the use of extra colour inks, particularly darker or metallic shades, can hinder recyclability by contaminating substrates or lowering recyclate quality.
Preserving the option for simplified, low-ink printing is essential to maintain design flexibility, control costs, and support circular economy objectives.
NO TEXT OBLIGATION
EDANA firmly opposes any obligation to include text indicating material composition on waste sorting labels.
Text requirements would undermine the Single Market by forcing companies to produce multiple packaging versions or include multiple languages on a single label, thus adding costs, complexity, and increasing risks of mislabelling and waste.
Many nonwovens products are distributed across the EU without a predetermined final destination, making harmonised packaging essential. Text-based labelling would disrupt this harmonisation, disproportionately affecting operators in multilingual countries and conflicting with the PPWR’s aim to reduce packaging volume.
An optional standardised, language-neutral alphanumeric code could offer a practical and scalable alternative, ensuring clarity, operational efficiency, and market cohesion.
Overall, companies in each Member State should remain free to include text in the label.
NO PLACEMENT OBLIGATION
EDANA strongly emphasises the need for flexibility regarding the placement of waste sorting labels.
Packaging formats differ widely in shape, size, surface area available for labelling, material composition, and the nature of the product itself.
Therefore, the forthcoming user manual should avoid prescribing a compulsory location for these labels and instead allow operators to choose the most suitable and visible placement based on their specific packaging solutions.
Very small packaging, which often lacks space for standard pictograms or data carriers, should be granted realistic guidance, including possible exemptions or alternative formats.
ENCOURAGE THE USE OF QR CODES
To address space and language limitations, EDANA supports the optional use of QR codes or similar digital tools to provide consumers with additional sorting information.
These digital solutions offer a convenient way to deliver detailed, language-specific instructions without overcrowding packaging or compromising design.
Given the diversity of packaging sizes and existing mandatory labelling (e.g., ingredients, safety, CE marking), rigid rules on label size or placement are impractical. Allowing flexibility in the use, size, and positioning of QR codes ensures alignment with PPWR goals while supporting consumer accessibility and packaging efficiency.
A 3-YEARS+ TRANSITION PERIOD
Finally, EDANA notes that implementing the currently proposed waste sorting labels within the next two years would have highly disruptive effects on companies.
The system, as it stands, lacks clarity and includes overly prescriptive elements such as mandatory text and colour requirements, which increase complexity, costs, and risk fragmenting the Single Market due to inconsistent enforcement across Member States.
Since artwork changes alone can take up to two years to implement, short-term revisions would create inefficiencies, capacity bottlenecks, and potential stock shortages.
While EDANA supports harmonised labelling as a step towards better recycling outcomes, implementation must be carefully phased with realistic timelines and clear, neutral pictograms to avoid unintended negative impacts in the short term.
For further information, please contact:
Brieuc LITS, Public Affairs Director, EDANA
Alexander HEUSCH, Regulatory Affairs Manager, EDANA