PPWR labelling dates When do the new packaging label duties start?

For packaging material-composition labels, Article 12(1) says packaging placed on the market must carry the harmonised label from 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted under Article 12(6) or Article 12(7), whichever is later. The label must give material-composition information to help consumer sorting and must be pictogram-based and easily understandable.

For reusable packaging, Article 12(2) uses a different date. Reusable packaging placed on the market must bear a reusable-packaging label from 12 February 2029 or 30 months from the date of entry into force of the implementing act adopted under Article 12(6), whichever is later. The required reusability information also links to a QR code or other standardised, open, digital data carrier, except for the open-loop-system derogation in Article 12(3).

For waste receptacles, Article 13(1) requires Member States to ensure harmonised labels on packaging-waste receptacles by 12 August 2028 or 30 months from adoption of the Article 13(2) implementing acts, whichever is later. Receptacle labels must correspond to the packaging labels, except for packaging subject to deposit and return systems. These dates are conditional: do not substitute an expected adoption date for the act's actual adoption or entry-into-force date.

No. The 12 August 2026 date is the Commission deadline for implementing acts, not the date when every economic operator must already have final artwork on packaging. Article 12(6) requires the Commission to establish the harmonised label and specifications for the Article 12(1), 12(2), and 12(4) labelling requirements, including digital formats.

Teams should use 12 August 2026 as a monitoring and planning checkpoint, not an assumed artwork-freeze date. Once the implementing acts are adopted and enter into force, the operational clock for several label duties can be calculated from those acts. Planning should reserve artwork space, data-carrier placement, accessibility, translations, product-master-data fields, and supplier change windows before the final specifications arrive.

Material-composition labels are broad, but they are not universal. Article 12(1) excludes transport packaging, except e-commerce packaging, and packaging that is subject to a deposit and return system. Compostable packaging covered by Article 9(1) and, where applicable, Article 9(2) must also use the harmonised label to say the material is compostable, is not suitable for home composting, and must not be discarded in nature.

Deposit and return packaging has its own label treatment. Packaging subject to Article 50(1) deposit and return systems must be marked with a clear and unambiguous label, and Member States may require a harmonised colour label if that does not distort the internal market or create trade barriers.

Recycled-content and biobased-plastic-content labels are triggered when packaging to which Article 7 applies is marked with that information. From 12 August 2028 or 24 months from entry into force of the Article 12(6) implementing act, whichever is later, those labels and any QR code or digital carrier must follow the relevant specifications.

Article 12(12) gives a sell-through style rule for packaging covered by Article 12(1), 12(2), and 12(4). Packaging manufactured in the Union or imported before the relevant paragraph deadlines, and not compliant with those label criteria, may be made available on the market until three years from the date of entry into force of the relevant labelling requirements.

Do not turn that rule into a blanket delay for new artwork. It depends on the relevant Article 12 paragraph, the deadline for that paragraph, and the date the labelling requirements enter into force. The Commission's 2026 guidance adds a specific reusable-transport-packaging interpretation: units placed on the market before 11 February 2025 may remain in circulation until functional or operational retirement, while units first placed on the market from 11 February 2025 until the reusable-label duty starts should comply by February 2032 at the latest.

Keep a label-deadline matrix rather than a single PPWR date. The matrix should map each packaging family to Article 12(1), Article 12(2), Article 12(4), Article 12(5), Article 12(8), Article 12(12), Article 13, or a documented non-applicability conclusion.

The evidence file should also preserve the source of each date, the implementing-act version used for artwork, label proofs, QR-code or digital-carrier content, language decisions for target Member States, and any old-stock decision relying on Article 12(12).