PPWR Update: Week of October 19, 2026

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.

Regulatory & Policy  |  October 20, 2026

On October 20, 2026 Parliament adopted its amendments to the proposal that would pause the duty to appoint an authorized representative for EPR in each EU country where you sell directly to end users (Art. 45(3)). Its version limits the pause to micro and small enterprises established in the EU, ends it on January 1, 2035 or when a new EU-wide EPR law applies, whichever is earlier, and keeps the duty in place for producers outside the EU.

What this means for you. The law has not changed and the duty applies today. Parliament sent the file back to its environment committee to negotiate with the Council, which dropped these EPR proposals from its own mandate in June, so no final text is in sight. Medium and large firms would get no relief under Parliament's version. Separately, the Commission's new guide for small businesses says it has asked member states to enforce the duty in a constructive and pragmatic way and not to sanction operators while the proposal is examined. That is a request to national authorities, not a suspension.

What to do. Keep appointing representatives where you sell directly to end users in another member state. A micro or small business should follow procedure file 2025/0395(COD) and read the Commission guide for small businesses. Source: European Parliament, texts adopted P10_TA(2026)0345 of October 20, 2026 and committee report A10-0266/2026 of October 9, 2026, Art. 2 as amended; European Commission, DG ENV small-business EPR guide, read October 21, 2026. [SIGNALED]: Parliament's amendments are a negotiating position, not law.

Site Update  |  October 21, 2026

Article 14 of the PPWR sets the conditions for environmental claims about the packaging properties the Regulation regulates, such as recyclability and recycled content in plastic packaging, and it has applied since August 12, 2026. A new Article 14 page sets out both conditions: the claim must relate to a property that exceeds the Regulation's minimum requirement, and it must say whether it covers the packaging unit, part of the unit, or all packaging the company places on the market. Compliance is shown in the Annex VII technical documentation. The obligation is now on the timeline, and the labeling page and the declaration of conformity page link to it.