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 and the related labels for reusable packaging, deposit packaging, and recycled or bio-based content. Adoption is planned for the fourth quarter of 2026, after a draft goes out for comment.

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. With no act in force by August 2026, the 2028 date in most guidance is out of reach, and on the Commission's own plan the earliest realistic date is late 2028. Do not lock sorting-label artwork to a 2028 changeover.

What to do. Comment on the draft when it appears, because that window is the one chance to shape the pictograms and placement rules. You can subscribe for a notification at 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 close.

Source: European Commission, Have Your Say initiative 19243, register entry read September 22, 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. Current status is at ACT-04 on the Delegated Acts tab.

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. The August 25 entry missed the Article 7(9) call, which the Delegated Acts tab now carries as ACT-11.

What changes for you today: nothing. The 2030 recycled-content minimums apply from January 1, 2030 or three years after the calculation act takes effect, whichever is later, so these acts can still move that date. If your plan leans on chemical recycling, Article 7(9) decides whether that output counts, and if it leans on imported recyclate, Article 7(10) does.

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.