PPWR: Commission pushes the sorting label back to 2027
The European Commission has changed its planning for the harmonised sorting label under Art. 12 PPWR. The implementing act that sets out the symbols and design is no longer due in the fourth quarter of 2026 but in the second quarter of 2027. Because the labelling obligation is tied to this act, it moves back as well. Other PPWR duties are not postponed: conformity assessment, technical documentation and the EU declaration of conformity have applied since 12 August 2026.
- What
- Implementing act on harmonised labelling (Art. 12 PPWR)
- Planning changed
- 19 October 2026, initiative 19243
- Previously planned
- Q4 2026
- Now planned
- Q2 2027, i.e. April to June
- Sorting label applies from
- 12 Aug 2028 or 24 months after the act, whichever is later
- Realistically
- Sorting label from mid-2029, reuse label from late 2029
- Before that
- Public feedback on the draft
- Still mandatory
- EU declaration of conformity, technical documentation, identifier and manufacturer details
What the Commission has changed
The PPWR sets EU-wide labels for packaging and for waste receptacles. They are meant to show consumers which bin a package or its components belong in, and to make reusable packaging and packaging in deposit return systems recognisable. What these labels look like is not set by the regulation itself but by a Commission implementing act under Art. 12(6). The regulation provided for 12 August 2026. That deadline has passed.
The Commission’s planning entry last showed adoption in the fourth quarter of 2026. On 19 October 2026 the entry was changed to the second quarter of 2027. Before the act is adopted, the Commission publishes a draft for public feedback. Only then will pictograms, colours and sizes be known. The groundwork comes from the Commission’s Joint Research Centre, which has proposed labels organised by material.
Why the obligation moves too
Art. 12 gives two dates for the sorting label: 12 August 2028 or 24 months after the implementing act enters into force. The later one applies. The same logic applies to the reuse label with QR code, with 30 months. If the act comes in the second quarter of 2027, the dates below follow. They are estimates based on a planning entry, not dates set in law. The planning has already slipped once.
| Obligation | Legal basis | With the act in Q2 2027 |
|---|---|---|
| Sorting label on material composition (Art. 12(1)) | 12 Aug 2028 or 24 months after the act | around April to July 2029 |
| Reuse label with QR code (Art. 12(2)) | 12 Feb 2029 or 30 months after the act | around October 2029 to January 2030 |
| Identifier and manufacturer details (Art. 15(5) and (6)) | since 12 Aug 2026 | in force, unchanged |
| EU declaration of conformity (Art. 39) | since 12 Aug 2026 | in force, unchanged |
Obligation
Sorting label on material composition (Art. 12(1))
- Legal basis
- 12 Aug 2028 or 24 months after the act
- With the act in Q2 2027
- around April to July 2029
Obligation
Reuse label with QR code (Art. 12(2))
- Legal basis
- 12 Feb 2029 or 30 months after the act
- With the act in Q2 2027
- around October 2029 to January 2030
Obligation
Identifier and manufacturer details (Art. 15(5) and (6))
- Legal basis
- since 12 Aug 2026
- With the act in Q2 2027
- in force, unchanged
Obligation
EU declaration of conformity (Art. 39)
- Legal basis
- since 12 Aug 2026
- With the act in Q2 2027
- in force, unchanged
Until the EU label applies, national labelling rules such as the Triman in France remain in place. Transport packaging, except in e-commerce, and packaging in deposit return systems are exempt from the sorting label.
What the delay does not affect
Only the design of the label is delayed, and with it the date from which it must appear on packaging. The other PPWR duties have applied since 12 August 2026 and do not depend on this act. Above all, this concerns the EU declaration of conformity.
Moves with the implementing act
- Harmonised sorting label on material composition
- Reuse label with QR code or other digital data carrier
- Matching labels on waste receptacles
- Uniform format for voluntary information on recycled content and bio-based plastic
Applies since 12 August 2026
- Conformity assessment under Annex VII before placing on the market
- Technical documentation for each packaging
- EU declaration of conformity under Art. 39 and Annex VIII
- Identifier plus manufacturer name and address (Art. 15(5) and (6))
- Limits for substances of concern, in particular PFAS in food contact packaging (Art. 5)
- Record keeping: 5 years for single-use, 10 years for reusable packaging
The declaration of conformity is still mandatory
Anyone placing packaging on the market has needed an EU declaration of conformity and the technical documentation behind it since 12 August 2026. In it, the manufacturer declares under its sole responsibility that the packaging meets the applicable PPWR requirements. The documents must be handed over within ten days at the authority’s request. The label delay changes nothing about this.
How the declaration is structured and which details Annex VIII requires is covered in our article on the declaration of conformity. What must already be on packaging today and what only comes with Art. 12 is set out in the article on PPWR labelling.
Declaration of conformity, technical documentation and manufacturer details become mandatory. The deadline for the labelling act passes.
The Commission moves adoption of the act from the fourth quarter of 2026 to the second quarter of 2027.
The Commission puts the draft with the pictograms up for public comment.
Design and technical specifications for the sorting and reuse labels are fixed. The 24- and 30-month periods start when it enters into force.
New packaging carries the EU label. Older stock may be sold for three more years.
What companies should do now
- Check your declarations of conformity. Every packaging placed on the market since 12 August 2026 needs a declaration and technical documentation. Missing either is a breach, regardless of the label.
- Check manufacturer details on packaging. Identifier, name and address must already appear on the packaging or in the accompanying documents.
- Record material data per component. The sorting label will later follow from the bill of materials. You need it for the technical documentation anyway.
- Do not finalise artwork for an EU label. Symbols, colours and sizes will only be known with the draft.
- Follow the draft. Once the feedback period opens, you can check how much space the label needs and which packaging must be redesigned.
Note
This overview is based on publicly available sources and is not binding legal advice. For an assessment of your individual case, please consult a lawyer or an accredited body.
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