PPWR: deadline for the labelling act has passed
The implementing act on harmonised packaging labelling, due by 12 August 2026, has not been issued; the 24-month changeover period has not begun.
The European Commission has not adopted the implementing act on harmonised packaging labelling under the PPWR on time. The date foreseen was 12 August 2026. As at 3 September 2026 the act has not been published; no date has been named.
What it is about
Article 12 of Regulation (EU) 2025/40 provides for a single, pictogram-based label across Europe: it is to show the material composition of packaging and indicate the correct waste stream to consumers. The technical specifications for this - design, pictograms, methodology for digital labelling - are not laid down by the regulation itself, which refers them to implementing acts under Article 12(6) and (7) and Article 13(2). Those acts were to be adopted by 12 August 2026.
What this means legally
Article 12(1) ties the start of the labelling obligation to two points in time: 12 August 2028 or 24 months after the implementing act enters into force - “whichever is the later”. Because the act has not been issued, the 24-month period has not started to run. The binding cut-off date moves back by every month of delay; the two-year changeover period is preserved in full. The same construction applies to reusable packaging labelling with a QR code, which is tied to 12 February 2029 or 30 months after the act.
What changes for companies - and what does not
In practical terms, nothing changes for brands in the short term. There is no standard to label against, and no obligation to anticipate one. The existing material codes under Decision 97/129/EC remain permitted. Anyone reworking packaging designs should leave layout space for a later label, but should not pre-empt any pictograms.
Unchanged, by contrast, are all the obligations that do not depend on the act: substance restrictions, producer details and identification number, declaration of conformity and registration have applied since 12 August 2026 and are not deferred by the delay.
The full PPWR timeline logic is set out in the guide PPWR: labelling and QR code obligations for packaging.
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