Regulatory & Policy September 22, 2026
The Commission has opened a register entry for the implementing decision that will set the EU's harmonized sorting label, along with the related labels for reusable packaging, deposit packaging and recycled or bio-based content. It plans to adopt the act in the fourth quarter of 2026, and a draft will be put out for comment before that.
What this means for your artwork. Under Article 12(1) the label cannot be required until 24 months after the act takes effect, or August 12, 2028, whichever is later. No act was in force by August 2026, so the 2028 date quoted in most guidance is already out of reach. On the Commission's own plan the earliest realistic date is late 2028, and later if adoption slips. Do not lock sorting-label artwork to a 2028 changeover, and do not assume the national marks you print today are going away on a fixed date.
What to do. Watch for the draft. The comment window on it is the one chance to shape the pictograms and the placement rules before they are fixed, and the register entry lets you subscribe for a notification: Have Your Say initiative 19243. The February 12, 2027 date for ending the standalone printed Green Dot as an EPR-scheme mark (Art. 12(9)) is unaffected and still close.
Source: European Commission, Have Your Say initiative 19243 (new Commission implementing rules on harmonized labels), register entry read September 22, 2026 (type of act: implementing decision; draft act feedback: upcoming; Commission adoption planned for fourth quarter 2026); Reg (EU) 2025/40 Art. 12(1), OJ text. [SIGNALED] on the plan; the late-2028 floor is derived from Art. 12(1) and the plan, not stated by the Commission.
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 September 21, 2026 or the full update archive.