PPWR labelling requirements
PPWR Article 12 introduces a harmonised label showing packaging's material composition to help consumers sort it correctly. The labelling obligation applies to packaging from 12 August 2028. The Commission is due to adopt the implementing acts defining the harmonised label format and the digital material-identification methodology by 12 August 2026 — both were still pending as of 9 July 2026.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
What the label must convey
Regulation (EU) 2025/40, Art. 12, requires packaging to carry harmonised labelling that communicates its material composition, so end users can sort waste into the right separate-collection stream. The information may be given through pictograms and, where provided, a QR code or other standardised, open digital data carrier that can direct each component of the packaging to its correct sorting stream. Reusable packaging carries its own marking indicating reusability and, where relevant, pointing to the reuse system (linked to the reuse obligations in Art. 29).
The dates
| Date | What | Status |
|---|---|---|
| By 12 Aug 2026 | Commission to adopt implementing acts: the harmonised label format/specifications, and the methodology for digital identification of material composition. | Pending (as of 9 Jul 2026) |
| 12 Aug 2028 | Harmonised material-composition and separate-collection labelling obligation applies to packaging. | Fixed in the regulation |
So the sequence is: the regulation sets the obligation and the 2028 application date; the exact pictograms and format come from implementing acts due by 12 August 2026. Because those acts were not yet adopted as of 9 July 2026, final artwork cannot be produced until they land — but the categories of information and the 2028 deadline are already known, so preparation can start now.
How labelling interacts with recyclability
Labelling (Art. 12) and recyclability grading (Art. 6) are separate obligations. The label tells the consumer how to sort the packaging; the recyclability grade governs whether the packaging may be placed on the market at all. A high recyclability grade does not remove the need for the sorting label, and vice versa.
What to do now
- Inventory your packaging by material so you know what each label will have to say.
- Reserve artwork lead time for a 2028 change across your ranges — labelling changes ripple through print, tooling and stock.
- Track the implementing acts. Watch the Commission's packaging page for the label format and the digital material-identification methodology, and design to them once published.
Because the label format is still being defined, treat the specifics here as the regulation's framework, not final artwork specifications. Confirm against the implementing acts once adopted.
Get this mapped to your own packaging
The report screens your packaging profile against Regulation (EU) 2025/40 and returns only the obligations that apply to you — each with its threshold, deadline and article, plus supplier letters ready to send.
Get my PPWR obligations report →Frequently asked questions
When do the PPWR labelling rules apply?
The harmonised material-composition and separate-collection labelling obligation applies to packaging from 12 August 2028 under Article 12. The implementing acts defining the label format are due by 12 August 2026 but were still pending as of 9 July 2026.
What information must PPWR labels show?
A harmonised indication of the packaging's material composition to enable correct sorting for separate collection, conveyed through pictograms and, where provided, a QR code or other standardised open digital data carrier. Reusable packaging carries a reusability marking.
Can I design my PPWR labels now?
You can prepare — inventory your packaging by material and reserve artwork lead time — but final label artwork cannot be produced until the Commission adopts the implementing acts defining the harmonised format, which were still pending as of 9 July 2026.
Is labelling the same as the recyclability grade?
No. Labelling under Article 12 tells consumers how to sort packaging. The recyclability grade under Article 6 governs whether packaging can be placed on the market at all. They are separate obligations that both apply.
Sources
- Regulation (EU) 2025/40 (PPWR) — Art. 12 harmonised labelling (material composition, separate collection, reusability); labelling applies from 12 August 2028 — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- European Commission — Art. 12 implementing acts on label format and digital material-identification methodology (due by 12 August 2026; pending as of 9 July 2026) — https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en