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 12 August 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 12 August 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 of July 2026. | SIGNALED |
| Aug 12, 2028 | 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) acts, whichever is the latest, so it is a floor rather than a fixed date. | LOCKED |
| Aug 12, 2028 | Standalone Green Dot and other potentially misleading marks restricted once the harmonized label applies (Art. 12(8)). | SIGNALED |
| From 2028 | Reusable packaging carries a reusability label; DRS-eligible containers carry deposit marking; QR or digital carriers may link to a Digital Product Passport where other Union law already requires one. | SIGNALED |
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.
The Green Dot loses standalone status. A symbol indicating EPR fees have been paid may only appear inside a QR code, not as a separate printed mark, once the harmonized label applies [SIGNALED, confirm against the final act]. 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 August 2028 transition. These cannot be maintained alongside the EU label afterward.
Read Article 12 in detail | Is a Digital Product Passport required? | Open the PPWR Atlas