What will come into effect from August 2026, when the harmonised EU label will be introduced, and how businesses can prepare their packaging processes now.
On 11 February 2025, the new European Packaging Regulation, officially known as the Packaging and Packaging Waste Regulation (PPWR), came into force. It does not introduce a single new packaging label with a uniform start date. Instead, identification details, harmonised material and sorting labels, labelling for reusable packaging, and supplementary digital information will be introduced in stages. The harmonised EU sorting label is due to be introduced in 2028 at the earliest. However, as the Regulation is, in principle, already applicable from 12 August 2026 and obligations relating to identification, compliance and documentation, amongst other things, will take effect from that date. Companies should begin implementation at an early stage.
What will apply from 12 August 2026
The general application of the PPWR does not mean that, from August 2026, every item of packaging must bear a new sorting label. The general obligations of the individual economic operators will become particularly relevant. Four questions are crucial for their correct classification: What type of packaging unit is involved? What function does it fulfil? What material is it made of? And what role does the company play in the supply chain?
Producers must ensure that packaging can be identified by a type, batch or serial number, or some other identifier. In addition, the name or brand, postal address and electronic contact details must be provided. Depending on the size and nature of the packaging, this information may also be provided via a QR code, another data carrier or an accompanying document.
Importers must add their own contact details and verify compliance. Distributors must check before making the product available on the market whether the relevant labelling is present and whether the producer and importer have fulfilled their information obligations.
For international companies, the terminology is important: the English term ‘manufacturer’ corresponds to ‘Erzeuger’ in the German PPWR. The English term ‘producer’, on the other hand, is the ‘Hersteller’ within the meaning of extended producer responsibility.
The harmonised recycling label: 2028 at the earliest
The harmonised recycling label, as set out in Article 12 of the EU Packaging Regulation, is intended to inform consumers about the material composition of packaging and make it easier for them to sort it. It will be based on pictograms and must be easy to understand. Additional information is required for certain types of compostable packaging.
The obligation to affix the sorting label will come into force on 12 August 2028 or 24 months after the relevant implementing acts enter into force. 12 August 2028 is therefore not a guaranteed start date, but the earliest possible one.
Transport packaging is generally not subject to these labelling requirements. However, this does not apply to packaging sent to end customers in online retail. Consequently, for example, the shipping box for an electronic product sent to a private customer may be treated differently from packaging intended solely for transport between businesses.
Special regulations also apply to packaging that forms part of a deposit or return scheme.
Reusable packaging, voluntary information and digital information
From 12 February 2029 or 30 months after the relevant implementing act comes into force, reusable packaging must bear a reusable label. Supplementary information, such as details of return points, reuse systems and circulation cycles, is to be provided via a QR code or another standardised open data format.
Information on the percentage of recycled material or the proportion of bio-based plastics is not generally mandatory. If such information is provided voluntarily, it must in future comply with harmonised specifications and calculation methods. Furthermore, voluntarily used symbols and environmental claims must not give consumers any false or misleading impressions regarding recyclability, reusability or the intended disposal routes.
What businesses should do now
Businesses do not yet need to print an unknown pictogram, they should lay the groundwork for swift implementation:
Act early, reap the benefits later
The PPWR labelling requirements do not begin in 2028. Whilst the harmonised sorting label will not be introduced until then at the earliest, the identification, role and information requirements will already come into effect with the general implementation of the PPWR. Those who organise their packaging data, responsibilities and change processes now will reduce time pressure later on and avoid costly corrections to packaging, supplier processes and digital systems.
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