PPWR Update: Week of September 21, 2026

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.

Regulatory & Policy  |  September 22, 2026

The Commission's three early consultations on recycled plastic in packaging closed on September 16, 2026. They cover how recycled content is calculated and verified (Article 7(8), 188 responses), the sustainability criteria that decide which plastic recycling technologies count (Article 7(9), 223 responses), and the conditions for counting recycled material imported from outside the EU (Article 7(10), 142 responses). All three acts are due by December 31, 2026.

Correction. Our August 25 entry described two consultations. There were three: the Article 7(9) call for evidence opened on the same day, August 14, and this site said until today that no register entry existed for it. It did. The Delegated Acts tab now carries it as ACT-11.

What changes for you today: nothing. The 2030 minimum recycled-content percentages apply from January 1, 2030 or three years after the calculation act takes effect, whichever is later, so the timing of these acts can still move that date. If your recycled-content plan leans on chemical recycling, the Article 7(9) criteria decide whether that output counts; if it leans on imported recyclate, Article 7(10) does. Drafts come next, and the drafts are where the detail lands.

Source: European Commission Have Your Say initiatives 18753 (Ares(2026)7895997), 19033 (Ares(2026)7896093) and 18752 (Ares(2026)7896043), register entries read September 22, 2026; Reg (EU) 2025/40 Art. 7(8), 7(9) and 7(10), OJ text. [SIGNALED] on status; the call-for-evidence documents have not been read here.