Regulatory & Policy August 12, 2026
Art. 12(6) and 12(7) required the Commission to adopt the harmonized labeling implementing acts by today. It has not. On August 11, 2026 the EUR-Lex record for the Regulation listed no implementing act completing Art. 12, and the only act completing the Regulation at all is the pallet wrap exemption. The technical groundwork exists: the Commission's Joint Research Centre published its technical proposal for harmonized waste-sorting labels on packaging and on waste receptacles in January 2026 (JRC141706, EUR 40581), written to inform the Art. 12(6) and 13(2) implementing acts. (Corrected September 30, 2026: this sentence now cites the report, and its earlier description of the label design, which had not been checked against the report, was removed.)
What this means for you. The labeling obligation applies from August 12, 2028 or 24 months after those acts enter into force, whichever is later. That "whichever is later" is now doing the work. Every month the act slips, 2028 slips with it, so treat 2028 as a floor and not a deadline. The flip side is that you still do not know what the label will look like.
What to do. Do not commission final sorting-label artwork yet. Watch for the draft act and its consultation, because that is your only chance to comment on the pictogram set before it is fixed. Source: absence of any Art. 12 implementing act on the EUR-Lex record for Regulation (EU) 2025/40, read August 11, 2026: EUR-Lex CELEX 32025R0040. The JRC proposal has not been read in full, so no date or document number is stated for it [SIGNALED].
This entry is part of the PPWR Atlas update log. The Atlas is re-checked against the Official Journal, Commission guidance, and each national PRO's published schedule, and everything that changes gets logged with its source. See the week of August 10, 2026 or the full update archive.