Status quo mandatory recycling symbols in the EU 2025

Recycling symbols on packaging are now an indispensable part of the circular economy. They help consumers to dispose of packaging correctly and support companies in meeting their legal obligations. Since 2025, numerous EU member states have introduced their own mandatory recycling symbols, which pose new challenges for retailers.

This article provides an overview of the current regulations in various EU countries and shows what online retailers need to bear in mind. At the same time, we take a look at the future of harmonization through the planned EU Packaging Regulation (PPWR).

The Triman logo: mandatory recycling symbol in France

France was one of the first countries to introduce a standardized recycling symbol, the so-called Triman logo. It has been mandatory since 2022, and clear rules also apply to online retailers when they sell products to France. The Triman logo shows consumers that the packaging is recyclable and indicates how it should be disposed of with an accompanying info tri.

What is special about the recycling labeling obligation in France is that, in addition to packaging, it increasingly includes other product groups and their corresponding waste streams. For example, textiles, furniture, building materials and DIY kits must be marked separately. Here too, the labeling is usually preceded by the triman, accompanied by an information tri that informs the end consumer about how to handle the product at end-of-life. In some cases, this includes a call for donations, returns to the store or upcycling. 

The logo consists of a stylized man forming three arrows combined with text or symbols indicating how the packaging should be recycled, the so-called Info-Tri. This is intended to guide consumers to dispose of the packaging correctly and helps to increase the recycling rate.

For more information on the requirements of the Triman logo and its meaning, see this article.

Although the EU has sharply criticized France for going it alone with regard to its own mandatory recycling symbols, the Triman logo and Info-Tri are still mandatory today for all household packaging and products that are also sold from abroad via e-commerce in France.

Mandatory recycling symbols in Italy

Since 2022, all household packaging in Italy must be labeled with recycling and disposal instructions. These must be clear and understandable for both consumers and disposal systems. Italy attaches particular importance to detailed information, which must be visible directly on the packaging. In addition to other information, the alphanumeric material code, which is uniformly defined in the EU Packaging Directive 94/62/EC, is mandatory. 

Unlike in France, in addition to the correct identification and communication of the packaging materials, the exact waste stream to which the individual packaging components are to be fed must also be specified. This ensures that the packaging is easily identifiable for both consumers and recycling companies.

In contrast to France, there is also a labeling requirement for B2B packaging in Italy. This differs in part from that for household packaging. 

Retailers who deliver to Italy should make absolutely sure that their packaging is compliant. You can find out more here.

New recycling labeling requirements in Spain in 2025

Since January 2025, packaging in Spain must also bear mandatory recycling symbols. The aim is to increase the recycling rate and provide consumers with simple guidance. Retailers should prepare for this change in good time, as non-compliant packaging can result in high penalties.

The symbols in Spain follow a color coding system: yellow for plastic, blue for paper and cardboard, and green for glass.  There are also clear regulations for dressing materials and packaging whose components cannot be easily separated. A special feature in Spain is that, under certain conditions, the communication of recycling labels via QR code is also tolerated.

Details on the new requirements and their implementation can be found in this video:

New mandatory recycling symbols in Portugal in 2025

Portugal joins the 2025 movement and introduces its own recycling symbols. According to the current legislation – Decreto-Lei n.º 152-D/2017, amended by Decreto-Lei n.º 34/2024 – the new labeling requirements apply to different types of packaging: All non-reusable packaging that falls under the recycling system must be labeled, as well as packaging that is part of a deposit and return system.

The labels must clearly indicate the destination of the packaging – i.e. the appropriate recycling garbage can. Until an official list is published by the Portuguese authorities, companies can create their own designs or use the recycling symbols used in Spain. Packaging that already complies with other standards such as Triman or Italian markings may continue to be sold on the Portuguese market. However, these do not replace the required labeling. Companies should check these regulations carefully and adapt their packaging accordingly to avoid fines.

Labeling requirements in Bulgaria

Since January 1, 2022, all packaging placed on the Bulgarian market for end consumers must be labeled accordingly in accordance with an amendment to the Bulgarian Packaging Act. Under the Extended Producer Responsibility (EPR), retailers are responsible for the collection, treatment and labeling of waste from their products. Violations can be punished with fines of between BGN 10,000 (approx. €5,000) and BGN 50,000 (approx. €25,000).

The Bulgarian Packaging Ordinance stipulates that, as in Italy, alphanumeric codes must be affixed to the individual packaging components in accordance with EU Decision 97/129/EC in order to identify the packaging material. These codes are mandatory for all packaging that has been placed on the Bulgarian market for the first time since January 1, 2022. The exact design and layout of the markings are at the discretion of the manufacturer or retailer, but they must be clearly and permanently visible on the packaging component with the highest weight.

In addition, the Möbius strip and the tidyman symbol can be used voluntarily.

Labeling requirements in Romania

According to Decree No. 249 of 28 October 2015 on the management of packaging and packaging waste, all packaging entering the Romanian market must be labeled accordingly. Annex 3 of the decree prescribes the use of the alphanumeric codes in accordance with EU Decision 97/129/EC on the individual packaging components to identify the packaging material.

The symbol must be affixed directly to the packaging or label and remain visible, legible and permanent. The regulation leaves room for individual label design options. Manufacturers or retailers are free to choose the size, color and style of the Möbius strip as long as it is clearly visible and permanently attached, even after the packaging has been opened. Both monochrome and multicolored labels are permitted. Companies selling to Italy must pay close attention here. Not all Möbius strips are permitted there in combination with the alphanumeric material code. 

Labeling with the Tidyman symbol is voluntary and offers manufacturers an additional opportunity to inform consumers about correct disposal. However, caution is advised here. If the packaging is also imported into the UK, for example, the Tidyman must be licensed there.

Labeling requirements in Slovakia

In Slovakia, packaging that is placed on the market must be labeled in accordance with Section 20 of Regulation No. 373/2015 of the Ministry of the Environment. The regulations stipulate that recycling codes in accordance with the alphanumeric material codes of EU Decision 97/129/EC must be affixed directly to the packaging or on the label. These codes must be visible, legible and permanent, even after the packaging has been opened.

The design of the mandatory recycling code again offers distributors freedom for individual implementation options, as long as the marking is clearly recognizable and meets the legal requirements. The use of the recycling triangle or Möbius strip and the Tidyman symbol is voluntary. Again, it should be noted that some versions of the Tidyman symbol are trademarked in the UK and may need to be licensed.

Mandatory labeling in other EU countries

In addition to France, Italy, Spain, Portugal, Bulgaria and Romania, other EU countries have also introduced specific regulations for recycling symbols. These symbols are currently voluntary in many countries. For example, there are standardized recycling symbols for the Scandinavian countries, which are recommended for online retailers with high sales in Denmark, Finland, Sweden or Norway.

For electronics (WEEE) and batteries, a strict, uniform labeling obligation with the crossed-out wheelie garbage can applies throughout the EU. This indicates to consumers that such products must not be disposed of with household waste. 

In addition, the UK is planning its own labeling requirements for packaging with the OPRL label from 2026. However, these are expected to be suspended and instead wait for the harmonization of packaging labelling by the PPWR. Retailers should monitor these developments closely in order to be able to react early. It is advisable to use EPR services such as ecosistant’s to keep up-to-date with your own obligations.

Single-use plastic: labeling requirements for single-use plastic products

Since July 3, 2021, certain single-use plastic products in all EU member states must be labeled with a special notice indicating the risk of environmental pollution from plastic. This labeling requirement applies to packaging with a surface area of at least 10 cm² and must be affixed in the respective national language of the member state.

The products concerned include, among others

1. tampons and tampon applicators

2. wet wipes, sanitary pads and sanitary towels

3. tobacco products with filters

4. beverage cups

For labeling, there are specific requirements regarding colors and proportions that must be taken into account in the design. The aim of the regulation is to educate consumers about the potential environmental impact of single-use plastics and to promote correct disposal.

Outlook: Harmonization through the PPWR

The planned Packaging and Packaging Waste Regulation (PPWR) could harmonize recycling symbols within the EU from 2026. The aim is to facilitate cross-border trade and increase the efficiency of the recycling system. The regulation not only includes the standardization of labels, but also stricter requirements for the recycling rate and the reusability of packaging.

Standardized labelling would reduce the administrative burden for companies and provide consumers with clear guidance. Companies would be obliged to adapt their packaging to a common European standard, which could lead to simplified logistics and more efficient use of resources. However, implementation will also pose challenges, such as converting existing packaging lines, training employees and adapting to new reporting obligations.

You can find more information in this article.

Conclusion

The increasing labeling requirements in the EU present retailers with new challenges. An early examination of the respective regulations is essential in order to avoid legal risks. The different requirements of the individual EU member states require precise planning and implementation, especially for companies that operate across borders. Errors or ambiguities in labeling can result in high fines and affect consumer confidence.

At the same time, harmonization through the PPWR offers an opportunity to simplify cross-border trade. Uniform standards could significantly reduce the administrative burden and improve transparency along the entire value chain. This would not only increase efficiency, but also sustainably increase the recycling rate.

For companies that want to efficiently adapt their packaging to the new requirements, it is advisable to make use of specialized consulting services. The services provided by our partner ecosistant offer valuable support in order to act in a legally compliant and sustainable manner in every market.

In addition, adapting to the new regulations opens up opportunities to position yourself as a sustainable company on the market. Consumers increasingly value transparency and ecological responsibility, which can turn well-implemented recycling labels into a competitive advantage. Companies that act early can not only avoid penalties, but also strengthen their market position in the long term.

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