What Regulation (EU) 2025/40 changes on packaging labels, when each change binds, and what survives the transition. Every item carries an evidence label.
PPWR replaces the national label patchwork with a single EU label using pictograms for material composition and consumer sorting. Article 12(1) reads from August 12, 2028 or 24 months from the entry into force of the implementing acts adopted under paragraphs 6 or 7, whichever is the latest. That is two acts, not one, and it makes 2028 a floor rather than a fixed date. The act specifying the pictograms was statutorily due August 12, 2026 and has not been adopted, so every month of slippage past that date pushes the obligation further out on a rolling basis.
Transport packaging and packaging in a deposit return system are outside the obligation, with the exception of e-commerce packaging. Packaging containing substances of concern must additionally be marked by standardized open digital-marking technologies.
| Date | Requirement | Evidence |
|---|---|---|
| Aug 12, 2026 | Statutory due date for the Art. 12 labeling implementing act (pictograms and material-composition methodology). Not adopted as at October 21, 2026; Have Your Say initiative 19243 plans the pictogram and labeling-specification act for the second quarter of 2027, and no register entry covers the material-composition methodology. | Signaled |
| Aug 12, 2028 or later | Harmonized EU sorting pictograms become mandatory on consumer packaging; material-composition labeling applies. National labels may not be maintained alongside the EU label. Art. 12(1) sets this as August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest, so it is a floor rather than a fixed date. | Locked |
| Feb 12, 2027 | An EPR-scheme mark such as the Green Dot may be shown only inside a QR code or other standardized open digital-marking technology, not as a standalone printed symbol (Art. 12(9)). | Locked |
| Aug 12, 2026 | Art. 12(8) restricts marks, symbols and inscriptions likely to mislead consumers about packaging sustainability characteristics or waste management options for which harmonized labeling has been laid down in the Regulation. The provision carries no date of its own, so it applies from the general application date of August 12, 2026. | Locked |
| Feb 12, 2029 or later | Reusable packaging placed on the market from February 12, 2029, or 30 months after the Art. 12(6) implementing act enters into force, whichever is the latest, must bear a reusability label plus a QR code or other standardized open digital data carrier giving further reuse information, including the re-use system and collection points (Art. 12(2)). Open loop systems that have no system operator, as defined under Annex VI, are exempt (Art. 12(3)). Deposit-return packaging carries its national deposit label under Art. 12(1). PPWR creates no Digital Product Passport; a carrier may link to one only where other Union law already requires it. | Locked |
A harmonized pictogram conveys material composition and which bin the packaging belongs in, so consumers sort the same way EU-wide. Exact icons come from the Art. 12 implementing act, which has not been adopted.
Under Art. 12(9), by February 12, 2027, packaging in an EPR scheme may be identified as such only by a symbol in a QR code or other standardized open digital-marking technology [LOCKED on the date and the mechanism; how it applies to the Green Dot is SIGNALED, since Art. 12(9) does not name it]. In Portugal, the Green Dot stops applying to beverage containers after August 9, 2026 as Volta DRS marking takes over.
Containers in scope of a deposit return system carry deposit marking regardless of EPR exemption status. Marking specifics vary by national scheme, for example Volta in Portugal and Pfand in Germany. Packaging in a deposit return system sits outside the Art. 12 harmonized label obligation.
Until the harmonized label applies, some national marks remain. France requires Triman and Info-Tri sorting instructions. Italy requires alphanumeric material codes such as PP 5 and PET 1 until the harmonized label applies. These cannot be maintained alongside the EU label afterward.
A claim printed on packaging about a property the Regulation regulates, such as recyclability or recycled content in plastic packaging, must meet Art. 14 from August 12, 2026. It may be made only for a property that exceeds the applicable minimum requirement, and it must say whether it covers the packaging unit, part of the unit, or all packaging the economic operator places on the market. Compliance is shown in the Annex VII technical documentation. A recycled-content label on packaging subject to Art. 7 must also follow the specifications of the Art. 12(6) implementing act and the Art. 7(8) methodology (Art. 12(4)), from August 12, 2028, or 24 months after the Art. 12(6) implementing act enters into force, whichever is the latest.
Read Article 12 in detail | Article 14, environmental claims | Is a Digital Product Passport required? | Open the PPWR Atlas