New packaging recycling logos regulation

Learn how to apply the new regulation that requires the inclusion of recycling pictograms on packaging labeling and its application to companies in the food, cosmetics and chemical sectors.

On January 1, 2025, one of the most visible and operational obligations of Royal Decree 1055/2022 on packaging and packaging waste came into full force: mandatory marking on packaging with clear information on the collection container or fraction. This measure, aimed at improving waste separation and recycling, directly affects manufacturers, packers, importers and distributors, including the sectors we work with at MarCoPack: food, cosmetics and chemicals.

This Royal Decree is a key step forward in the Spanish and European strategy towards a circular economy. In addition to better waste management, it seeks to make it easier for consumers to identify how and where to recycle each package. For companies, it represents a technical and compliance challenge, but also an opportunity to reinforce their sustainable image and modernize their packaging.

Here is what you need to consider to adapt your packaging and labels to this new legal requirement.

Legal framework and implementation schedule

The Royal Decree 1055/2022approved on December 27, 2022, applies to all types of packaging: household, commercial and industrial. This regulation has been gradually implemented since 2023, and in January 2025, several countries (including Spain), have made mandatory the use of standardized symbols to indicate the type of recycling of each container.

In addition, this regulation is aligned with the Directive 94/62/EC and anticipates the principles of the future European Packaging Regulation (PPWR), which will strengthen regulatory harmonization in the EU.

In Spain, it is also complemented by the Waste Law 7/2022(on waste and contaminated soils for a circular economy), which reinforces the traceability of packaging.

What do the regulations currently require?

Identification of the type of packaging material (according to UNE-EN 13430 )
The container must indicate the type of material (plastic, cardboard, metal…) with its alphanumeric code. Example: “PET 1” for PET plastic, “PP 5” for polypropylene.
Separation or recycling instructions: A clear instruction to the consumer on which container to dispose of the packaging should be included. Example: “Deposit in the yellow container”.
Standardized icons (not invented by the brands):
- Official graphic symbols should be used (for example, those of the Circular Lab Project of Ecoembes in Spain or those of Citeo in France).
- It is forbidden to create your own recycling icons that confuse the consumer.
Important prohibitions:
- The green dot symbol cannot be used if the company is not a member of an extended responsibility system (such as Ecoembes).
- Misleading symbols such as arrows without legal backing are prohibited.
- You can’t say “100% recyclable” if only part of it is.

2. Marking obligations: what must be included on the package?

As of January 1, 2025, all household packaging must display visibly and legibly:

The destination container: for example, “Yellow container” or “Blue container”.
In the case of reusable containers, they must include the symbol corresponding to the Deposit, Return and Refund System (DRS).
For multilayer or composite containers, the correct form of separation or the container of the predominant material must be indicated.
Prohibited messages: Expressions such as “environmentally friendly” or similar expressions that may induce abandonment in nature are prohibited.
The marking must remain visible even after opening the container.

3. Which companies are affected?

To all companies that:

Manufacture or import products with physical containers
Labels containing information on recycling are applied
Commercialized in Spain or any other EU country.

How it affects the food, cosmetics and chemical industry

This change has important practical implications:

Redesign of labels: integration of new symbols and clear indications.
Coordination with suppliers: ensure that packaging suppliers are aware of the regulations.
Impact on machinery: adaptation of printers, labelers or vision systems may be required.
Compatibility with other regulations: must be in conjunction with the Food Information Regulation (1169/2011), cosmetic regulations and CLP labeling for chemical products.
Operational costs: redesign, stock of old labels, staff training and quality controls.

Recycling pictograms

With this regulation, household packaging must include a mandatory symbol that clearly indicates in which container it should be deposited. To this end, the various packaging SCRAPs have agreed on a common symbol, available in various formats and in all the official languages of Spain: Spanish, Catalan, Basque and Galician.

Types of pictograms per container

Each type of material must show a specific symbol indicating its final destination:

Yellow container: plastic, metal and briks.
Blue container: paper and cardboard.
Green container: glass.
Brown container: compostable containers (UNE EN 13432:2001 certified).

It should be noted that the symbology varies according to whether the product is destined for the domestic or international market.

ECOEMBES offers a MANUAL FOR COMPANIES, which explains how to apply these symbols and their different variants, which we have summarized below:

Available formats

Two versions are offered per pictogram:

Version A: for small spaces.
Version B: for large spaces and greater visibility.

These can be integrated in official color, black and white, or in any other color on a white or transparent background.

Mandatory multilingualism

In products distributed in several autonomous communities with a co-official language, it is recommended to adapt the pictogram to the corresponding market language (e.g. Catalan in Catalonia, Galician in Galicia, etc.). There are official versions in Spanish, Catalan, Basque and Galician.

In addition, there are versions in English, French, Italian and Portuguese, and a generic symbol for packages destined for several countries or placed directly on the international market. If the same package is also distributed in the domestic market, it should, whenever possible, appear in the corresponding color.

How to apply pictograms

If the package has several easily separable materials (e.g. cereal box with inner bag), each part should be marked with its corresponding symbol.
If the materials are not separable (multilayer), the container of the predominant material must be indicated.
The symbol should preferably be placed on the primary container or label.
Minimum recommended size: 10 mm (minimum allowed: 8 mm).
A margin free of graphic elements around the symbol must be respected.

Restrictions

It is not possible:

Alter the symbol (shape, color, proportions).
Use unreadable colors on non-contrasting backgrounds.
Insert extraneous text or graphics inside the symbol.

5. Practical guide to implement the change

These are the recommended steps to comply without mishaps:

Review all current packaging and classify which ones are affected.
Select the appropriate pictograms and messages according to the type of packaging.
Design updated labels that integrate the mandatory marking meeting the criteria of visibility and legibility.
Validate with suppliers that new labels can be produced on time.
Plan the transition: segregate existing stock and clearly mark the new containers.
Train the team on the new requirements.
Monitor compliance before the effective date.

6. Frequently Asked Questions

Does it apply only to household packaging?
No, although the marking obligation directly affects household packaging, the Royal Decree also applies to commercial and industrial packaging with other obligations.

What happens to the stock produced before January 1, 2025?
It can remain in the market, but must be differentiated from products with the new labeling.

Can I use generic pictograms?
Generic symbols are not enough: the indication of the container must be clear and understandable.

Is the Ecoembes “Recycle” symbol mandatory?
It is not mandatory, but it is permitted and recommended for its recognition among consumers.

What about packaging that is difficult to separate?
The predominant material and the corresponding container must be indicated.

7. Useful resources for companies

MITECO Interpretative Gu idance – Interpretative Note on Packaging Marking
Ecoembes Recycling Symbol User’s Manual
Ecoembes and Ihobe Packaging Ecodesign Guide
Ecoembes and Ihobe’s environmental labeling guide for containers and packaging
PROCIRCULAR’s symbol for household packaging recycling
Register of product producers (packaging section) – institutional information MITECO

The new marking obligation on packaging is not only a legal requirement: it is an opportunity for companies to modernize their processes, align with consumer expectations and demonstrate real environmental commitment.