Close each label rollout with a decision record that can support product release and later authority questions. The record should show the packaging classification, applicable Article 12 or 13 paragraph, source quote, implementing-act version, artwork proof, QR or digital-carrier content, online-sales proof, language decision, owner approval, and any supplier or manufacturer evidence.
Separate new production from packaging already manufactured in the Union or imported before the relevant Article 12(1), 12(2), or 12(4) deadlines. Article 12(12) allows those non-compliant pre-deadline packs to be made available on the market until three years from the date of entry into force of the relevant labelling requirements, but that should be documented as a stock-specific decision, not used as a blanket delay for the rollout.
Existing reusable transport packaging needs its own transition record. Commission guidance says reusable transport packaging placed on the market before 11 February 2025 may remain in circulation until functional obsolescence or operational limitations remove it from the system. Packaging placed on the market after that date but before the reusable-label requirements apply should be brought into compliance by the end of the applicable Article 12(12) period. This is Commission interpretation, so retain the guidance version and the facts supporting the stock category.