Regulatory & Policy August 25, 2026
The Commission was required to publish the implementing acts setting the harmonized sorting label by August 12, 2026, under Articles 12(6) and 12(7). That date has passed and no act exists. The Commission's implementation page says only that it is "currently preparing" one, and there is still no draft and no consultation on the register.
What that means for artwork planning. The harmonized label applies from August 12, 2028, or 24 months after these acts enter into force, whichever is later. With the acts still unwritten, the 24-month leg now governs, so 2028 is the earliest possible date rather than the actual one. Every further month of delay moves the label date by a month.
What does not move. The Article 12(9) rule ending the standalone printed Green Dot as an EPR-scheme identifier runs on its own clock and still applies from February 12, 2027. Article 12(8), the restriction on misleading marks for matters PPWR harmonizes, has applied since August 12, 2026. National labels, Triman in France and the Italian alphanumeric scheme, stay in force meanwhile.
The practical read. Do not commission harmonized-label artwork yet, and do not let a supplier tell you 2028 is fixed. Do handle February 12, 2027 for the Green Dot, because that one is real and close.
Source: Reg (EU) 2025/40 Arts. 12(6), 12(7), 12(8) and 12(9), OJ text; European Commission PPWR implementation page, read August 25, 2026. [LOCKED] on the provisions, [SIGNALED] on the act's status.
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 24, 2026 or the full update archive.