Table of Contents
- What Is Mandatory Labelling?
- Timeline and Key Dates
- Label Categories
- What Must Be Labelled
- How to Prepare
- Key Takeaways
Key Takeaways
- From 2027, all packaging sold in the UK must carry standardised recyclability labels indicating whether it can be recycled.
- Three label categories: “Recycle”, “Do Not Recycle”, and “Check Locally” — replacing the current patchwork of voluntary labels.
- Every packaging component must be labelled, not just the main container — caps, sleeves, and films need labels too.
- Start preparing now — artwork changes, recyclability assessments, and print updates take 6-12 months.
- Non-compliant packaging may face penalties and could not be legally placed on the UK market after the deadline.
What Is Mandatory Labelling?
Mandatory recyclability labelling is a requirement under the UK’s packaging EPR regulations that all packaging must carry clear, standardised labels telling consumers whether the packaging can be recycled.
Currently, recycling labels on packaging are voluntary, inconsistent, and often confusing. The new mandatory system replaces this with a simple, universal scheme that consumers can understand.
For background on EPR, see what packaging EPR is.
Timeline and Key Dates
| Date | Milestone |
|---|---|
| 2026 | Final label designs published; businesses begin preparation |
| 2027 | Mandatory labelling comes into force |
| Transitional period | Sell-through of pre-labelled stock may be permitted |
Important: The exact implementation date and any transitional arrangements should be confirmed with current DEFRA guidance. Start preparation early to avoid last-minute scrambles.
Label Categories
”Recycle”
Used when packaging is collected for recycling by most UK local authorities:
- Clear PET bottles
- HDPE bottles
- Corrugated cardboard
- Steel and aluminium cans
- Glass bottles and jars
”Do Not Recycle”
Used when packaging cannot be recycled through UK systems:
- Multi-layer laminates
- Black plastic (carbon black)
- Certain composites
- Small flexible packaging (below size thresholds)
“Check Locally”
Used when recycling availability varies by location:
- Plastic films (collected by some councils)
- Polystyrene pots (collected in some areas)
- Tetrapak cartons (collected in many but not all areas)
What Must Be Labelled
Every Separable Component
Each separable packaging component must carry its own label or be referenced on the main label:
Example — A bottled product:
- Bottle: “Recycle” (PET)
- Cap: “Recycle” (PP)
- Label: “Recycle” or remove instructions
- Shrink sleeve: Material-dependent
Primary, Secondary, and Transit Packaging
- Primary packaging (consumer-facing): Must be labelled
- Secondary packaging (multi-packs, shelf-ready): Must be labelled if consumer-facing
- Transit packaging (B2B only): Labelling requirements may be reduced — check guidance
Small Packaging
Very small packaging items may use abbreviated labels or reference consumers to online information rather than carrying a full label.
Label Design and Placement
Design Standards
- Labels must use the standardised design specified by DEFRA/OPRL
- Specific colours, sizes, and iconography will be mandated
- Labels must be clearly visible to the consumer
- Text must be in English (bilingual labelling in Wales may be required)
Placement Rules
- On the packaging itself, not on removable tags
- Adjacent to or integrated with other mandatory information
- Large enough to be readable (minimum size requirements apply)
- Contrast with the background for visibility
How to Prepare
Step 1: Assess Your Packaging (Now)
Use the packaging RAM tool to determine the recyclability of every packaging component. This determines which label each component needs.
Step 2: Create a Packaging Register
List every packaging item across your product range with:
- Material type
- Recyclability assessment result
- Required label category
- Current artwork status
Step 3: Plan Artwork Changes (6-12 months before)
For each packaging item:
- Brief your design team on the labelling requirements
- Determine where the label will be placed
- Update artwork files
- Order new printing plates/dies
Step 4: Coordinate with Suppliers (3-6 months before)
- Share labelling requirements with your packaging suppliers
- Coordinate timing of artwork switches
- Plan stock management for the transition (selling through old-label stock)
Step 5: Implement and Verify (at launch)
- Check first production runs for correct labelling
- Verify label placement, size, and readability
- Document compliance for audit purposes
Cost Implications
Direct Costs
- Artwork design: £500-5,000 depending on number of SKUs and complexity
- New printing plates: £50-500 per SKU depending on printing method
- Stock write-off: Old packaging stock that cannot be relabelled
- Recyclability testing: Costs of RAM assessments if not already done
Indirect Costs
- Staff time: Project management, coordination, verification
- Packaging redesign: If recyclability assessments reveal that current packaging will need “Do Not Recycle” labels, you may want to redesign before the deadline
Cost-Saving Tip
Combine labelling changes with other packaging updates (lightweighting, material switching) to reduce the per-change cost. If you are already redesigning packaging for EPR cost reduction, add labelling to the same project.
Impact on EPR Fees
Mandatory labelling itself does not directly change your EPR fees. However:
- Packaging redesigned to achieve a “Recycle” label (instead of “Do Not Recycle”) will attract lower modulated EPR fees
- The labelling requirement creates a commercial incentive to make packaging recyclable — few brands want “Do Not Recycle” printed on their packaging
Getting Started
- Audit your packaging for recyclability using the RAM tool
- Create your packaging register with label requirements
- Brief your design and procurement teams
- Set a project timeline working backwards from the 2027 deadline
- Budget for changes across your packaging range
Use the EPR fee calculator and visit our pricing page. See the EPR compliance deadlines guide for key dates.