Regulatory & Policy October 21, 2026
The Commission now plans to adopt the implementing decision that sets the EU's harmonized sorting label in the second quarter of 2027, not in the fourth quarter of 2026 as its register showed earlier this month. The draft has still not been released for comment.
What this means for your artwork. Under Article 12(1) the label applies from August 12, 2028, or 24 months after the implementing acts enter into force, whichever is the latest. On the Commission's new plan the earliest realistic date for the EU label is about mid-2029, so artwork printed for 2028 does not need it. The February 12, 2027 change for EPR-scheme marks such as the Green Dot (Art. 12(9)) is not affected.
What to do. Do not budget a 2028 label changeover. Subscribe at Have Your Say initiative 19243 to hear when the draft opens for comment, because that window is the one chance to shape the pictograms and placement rules. Source: European Commission, Have Your Say initiative 19243, read October 21, 2026; Reg (EU) 2025/40 Art. 12(1), OJ text. [SIGNALED] on the plan; the mid-2029 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. See the week of October 19, 2026 or the full update archive.