Regulatory & Policy August 25, 2026
Articles 12(6) and 12(7) required the Commission to publish the implementing acts setting the harmonized sorting label by August 12, 2026. That date has passed with no act, and the Commission's implementation page says only that it is "currently preparing" one, with no draft or consultation on the register. Current status is in the September 22 entry and at ACT-04 on the Delegated Acts tab.
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 unwritten, the 24-month leg governs, so 2028 is the earliest possible date and each 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 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 such as Triman in France and the Italian alphanumeric scheme stay in force meanwhile.
The practical read. Do not commission harmonized-label artwork yet or accept that 2028 is fixed, but do prepare for the Green Dot change on February 12, 2027.
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. See the week of August 24, 2026 or the full update archive.