# The first PPWR marking date is a digital one in February 2027, and the EU sorting label now waits on an act planned for the end of 2026

> Under Articles 12 and 13 of Regulation (EU) 2025/40, the EU symbol for extended producer responsibility (EPR) can appear only in a QR code or other digital carrier from 12 February 2027, while the harmonised material sorting label applies from 12 August 2028 or 24 months after its implementing act enters into force, whichever is later; the Commission's own planning record puts that act's adoption in the fourth quarter of 2026, which on Strategic Packaging Insights (SPI) arithmetic moves the label to about January 2029.

Publisher: Strategic Packaging Insights  
Published: 2026-10-29  
Last updated: 2026-10-29  
Page: https://www.strategicpackaginginsights.com/insights/ppwr-labelling-harmonised-material-label-digital-marking/

**Under Articles 12 and 13 of Regulation (EU) 2025/40, the EU symbol for extended producer responsibility (EPR) can appear only in a QR code or other digital carrier from 12 February 2027, while the harmonised material sorting label applies from 12 August 2028 or 24 months after its implementing act enters into force, whichever is later; the Commission's own planning record puts that act's adoption in the fourth quarter of 2026, which on Strategic Packaging Insights (SPI) arithmetic moves the label to about January 2029.**

Most packaging teams treat "the PPWR label" as one 2028 artwork change. The text sets five label tracks with different start rules, two of them fixed in the calendar and three that float with Commission acts, and it ends national sorting marks such as France's Triman on the same day the EU label starts.

## Executive summary

The PPWR rewrites what goes on a pack in Europe, but not in one step. Article 12 sets five separate labelling duties and options: a mandatory pictogram label on material composition, a mandatory reuse label with a QR code, voluntary harmonised labels for recycled and bio-based content, a digital-only EPR symbol and, later, digital marking of substances of concern. Article 13 adds matching labels on waste bins. Each runs on its own start rule (Exhibits 2 and 3).

The first date that touches artwork is the least discussed. From 12 February 2027, Article 12(9) lets packaging in an EPR scheme carry a symbol showing that the producer meets its obligations only in a QR code or other open digital carrier, and the Commission's June 2026 guidance reads that as a ban on physical EPR labels. That date is fixed in the Regulation and does not wait for any Commission act.

The sorting label does wait. Its legal floor is 12 August 2028, but it cannot apply until 24 months after the implementing act enters into force. That act was due on 12 August 2026. The Commission's Have Your Say record, published on 14 September 2026, plans adoption between 1 October and 31 December 2026, and on 29 October 2026 the draft stage was still marked upcoming. On SPI's base case the label applies from 20 January 2029, and bins follow on 30 June 2029, because Article 13's 30-month clock runs from adoption rather than entry into force (Exhibit 10).

National marks end with the EU label rather than run beside it. The guidance says Member States will not be allowed to keep national labels next to EU harmonised labels, and that the Decision 97/129/EC material abbreviations will no longer be allowed after 12 August 2028. Read together, those two rules can open a window of 4 to 11 months in which old codes are gone and the new label is not yet required (Exhibit 11). Check with counsel on how that window applies to your packs.

For leaders, three moves matter now: move EPR symbols into a digital carrier before February 2027, keep sorting artwork modular until the act's pictograms are published, and plan one switch per market rather than a period of dual marking.

## Key findings

1. From 12 February 2027 the EPR symbol may appear only in a QR code or other standardised, open digital carrier (Article 12(9)); the Commission's guidance of 10 June 2026 reads the provision as a ban on physical labels for this information.
2. The Commission's Have Your Say record for the labelling act (PLAN/2026/1562) plans adoption in Q4 2026, from 1 October to 31 December; its draft act stage showed no publication date and zero feedback on 29 October 2026.
3. **SPI calculation:**  if the act is adopted on 31 December 2026 and enters into force 20 days later, the sorting label applies from 20 January 2029, the reuse label from 20 July 2029 and bin labels from 30 June 2029; adoption on 30 June 2027 moves the sorting label to 20 July 2029.
4. Article 13's bin clock is 30 months from adoption of the act, against 24 months from entry into force for the pack label, so in every SPI scenario bins are required about 161 to 163 days after packs.
5. The JRC's January 2026 proposal rests on a 16,380-person survey in 21 Member States and an 11,096-person behavioural experiment in 11, and makes colour and text optional parts of each label.
6. **SPI analysis:**  France's Triman, which since 2022 has required on-pack sorting signage except on glass beverage packaging, and Spain's bin information duty under Royal Decree 1055/2022, which has applied since 1 January 2025, both meet the same end point: the day the EU label applies.

## Five label tracks in two articles

Article 12 is often summarised as a single harmonised label from 2028. The text holds more than that (Exhibit 2), and each element has a different legal status: mandatory, voluntary but harmonised if used, or restricted to digital form.

The sorting label is pictogram based and must be easy to understand, including for people with disabilities. Compostable packaging under Article 9 must state that it is compostable, whether it is unsuitable for home composting, and that it must not be discarded in nature. Transport packaging is outside the duty, except e-commerce packaging, and so is packaging in a deposit return system, which carries its own label (Article 12(1); guidance section 13).

Article 12(5) sets the physical rules for every label. Labels and data carriers must be visible, legible and indelible, and the information must be available to buyers before purchase when goods are sold online. Where a pack is too small, the label goes on outer packaging; where that is also impossible, a single electronically readable code may be used. Personal data collected through a code must be limited to what is needed, and the carrier may not show sales or marketing content alongside the label information.

Article 12(8) adds a conduct rule: operators may not use labels likely to mislead consumers about sustainability, other features of the packaging or disposal options. Article 12(10) lets Member States allow a symbol for deposit systems other than those in Article 50(1), but bars them from prohibiting another Member State's deposit labels. Article 12(11) leaves out the immediate and outer packaging of medical devices, in vitro diagnostics and medicinal products where there is no room for the label or labelling could compromise safe use.

SPI analysis

The useful split for an artwork team is not mandatory against voluntary but physical against digital. Two elements, the EPR symbol and the substances of concern marking, may never be printed as symbols; one, the reuse label, needs both a printed mark and a data carrier. A pack design with no space reserved for a code will need rework twice.

## Three kinds of clock

Every PPWR label date is one of three types: a fixed date, a fixed floor with a clock that runs from entry into force of an act, or a fixed floor with a clock that runs from adoption (Exhibit 3). The difference between entry into force and adoption looks technical but shifts dates by weeks or months.

Three points follow. First, the substances of concern marking has no fixed floor at all: its act is due by 1 January 2030, so on SPI's reading a pack cannot be required to carry it before about 2032 even if the act is on time. Second, the bin clock is longer but starts earlier: 30 months from adoption against 24 months from entry into force. Third, the three-year sell-through window under Article 12(12) runs from the date each labelling requirement applies, so it moves with the label.

The Commission's material uses the same rules. The annex to C(2026) 2151 of 30 March 2026, which approved the draft guidance, says recycled and bio-based content labels will be fully harmonised from 12 August 2028 or 24 months after entry into force of their act, and that national reuse labels may not be kept after 12 February 2029 or 30 months after the related act. The tracker's [PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/) rule carries the same structure.

## What the Commission's own records show about timing

Press reports have said the labelling act may slip further. SPI uses only the Commission's records for its timing, and they show four things (Exhibit 4).

The planning record describes the act's scope in one line: harmonised labels to help consumers sort waste, including deposit items, identify reusable packaging, show recycled and bio-based content and inform about substances of concern. The Green Forum timeline lists the same deliverable under Articles 12(6) and 13(2), covering labels for reusable packaging, deposit packaging, recycled content and consumer sorting, and labels for waste receptacles, with a deadline of 12 August 2026.

What the record does not show matters as much. On 29 October 2026 the draft decision had no publication date, so no draft pictograms had been put out for public feedback. An implementing act under Article 12(6) also goes to a committee of Member State experts under the examination procedure in Article 65(2), as Article 13(2) states for bin labels. SPI has not yet confirmed a committee vote date.

SPI analysis

An adoption inside Q4 2026 would need the draft feedback stage to open and close within about nine weeks of 29 October. SPI has not yet confirmed how long the feedback period will be, so the planned quarter is tight but not closed. Exhibit 10 therefore treats 31 December 2026 as the base case and a six-month slip as the high case, both built only on the record's own window.

The 12 August 2028 floor itself is already out of reach. For the label to start on that date, the act had to be in force by 12 August 2026. Even an act adopted on 29 October 2026 and in force 20 days later would put the label at 18 November 2028. The [PPWR after August 2026 piece](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) sets out the wider timetable of delayed acts; this piece stays with the label.

## The evidence behind the pictograms

The act will build on a technical proposal from the Commission's Joint Research Centre (JRC), published on 13 January 2026 and presented by the EU Policy Lab on 26 January. The Policy Lab says the work took more than three years, and that DG Environment will use the proposal to develop the implementing act (Exhibit 5).

The design choices in the proposal tell a pack designer what to expect, although only the adopted act will bind (Exhibit 6). Labels name the material, not the bin, so one set of labels can work in every Member State; residual, compostable and hazardous packaging are the exceptions to that material focus. A tray with a board sleeve can carry one label per component.

Colour and text were the contested points. In July 2025, Toy Industries of Europe and more than 60 other associations opposed the JRC's provisional guidance, which favoured full-colour labels with text, arguing that it could fragment the single market. The January 2026 proposal keeps colour and text but makes neither mandatory, and producers rejected colour-filled glass pictograms on printing grounds (JRC, page 46).

The proposal also gives QR codes a supporting role: they could carry country or region-specific instructions and reduce the need for multi-language text (page 41). In the behavioural experiment, about 82% of participants said they had all the information they needed to sort, and after a short explanation of the matching concept 68% said it was already clear (Box 4, page 37).

SPI analysis

For a brand with a long tail of small multi-market packs, an optional monochrome version with no text is the most important line in the proposal. If the act keeps it, a single plate can serve every EU market, which is what the end of national marks is meant to achieve.

## A framework: five label tracks and what each asks of you

SPI groups the PPWR marks into five tracks by two tests: is the start date fixed or floating, and is the mark physical or digital (Exhibit 7). Each track needs a different owner and a different trigger in a packaging plan.

**Track A, fixed digital.**  This is the only track with a date that is already certain. The guidance reads Article 12(9) as allowing EPR information only in digital form. SPI has not yet confirmed how national schemes will apply that reading to existing printed marks, including the Green Dot trademark, so producers should ask their scheme before plates are next renewed.

**Track B, floating physical.**  The sorting label and bin labels share a floor but not a clock. In SPI's base case packs carry the label from 20 January 2029 and bins from 30 June 2029, so for about five months the pack label will have no matching bin label in some places. Recital 127 says producers should finance the labelling of waste receptacles, so the bin step will appear in EPR fees rather than as a separate bill.

**Track C, reuse.**  The reuse label always needs a data carrier that can track trips or rotations, or give an average estimate where tracking is not feasible. Reusable transport packaging placed on the market between 11 February 2025 and 12 February 2029 must comply by February 2032 at the latest, according to the guidance; units placed before 11 February 2025 are outside the rule.

**Track D, voluntary content labels.**  No brand has to state recycled or bio-based content. A brand that does so after the floating date must use the harmonised format, and recycled content labels must follow the calculation method under Article 7(8). The [recycled content piece](https://www.strategicpackaginginsights.com/insights/ppwr-recycled-content-targets-2030-2040/) covers that method.

**Track E, far off digital.**  The substances of concern marking must at least give the name and concentration of each substance in each material per packaging unit, through an open digital carrier. It is the furthest away and the most data heavy.

## Which national marks retire, and when

The guidance calls packaging labelling under Article 12 exhaustive and fully harmonised, with deposit return systems as the stated exception, and says Member States may not adopt other mandatory national packaging labelling rules. Exhibit 8 lists the national marks in SPI's tracker and related records that meet that rule.

**France.**  The Triman decree requires the signage to sit next to the sorting information, on the packaging itself for household and food service packaging, with stickers allowed. Packs whose largest face is under 10 cm² may move both to a digital medium if no other document accompanies the product, and packs of 10 to 20 cm² may move only the information (R. 541-12-21). Eco-organisms publish the information, and producers apply new versions within 12 months, with up to six months of stock sell-off (R. 541-12-18 and R. 541-12-19). The ministry's Info-tri page, last updated 16 December 2024, describes the mark in three steps: the Triman, the items, and how to sort them.

The French bill that would replace Triman with the EU scheme was adopted by the Senate on 18 February 2026 and sent to the Assemblée nationale on 20 February; the Senate dossier, last updated 4 September 2026, shows no later step. The [France AGEC and Triman piece](https://www.strategicpackaginginsights.com/insights/france-agec-triman-packaging/) covers the infringement case and the bill; the point here is the end date, which the PPWR sets whatever the bill's fate.

**Spain.**  Article 13 of Royal Decree 1055/2022 has required household packaging to show the bin or fraction it belongs in since 1 January 2025, with material codes under Decision 97/129/EC voluntary. MITECO's consolidated note of 10 March 2026 allows a QR code in place of physical sorting information only in set cases, such as packs that already carried a code before 2025 or multilingual packs sold in several Member States, and treats physical marking as impossible on packs 10 cm wide or less or with no room for a label at least 15 mm wide (6 mm for symbols only). CONAI reports that the note's update does not change existing obligations. The [Spain cost stack piece](https://www.strategicpackaginginsights.com/insights/spain-packaging-decree-plastic-tax-cost-stack/) covers the decree's fees.

SPI analysis

The guidance's line that national labels may not be kept next to EU labels turns a gradual transition into a single switch day per mark. A French pack printed after the label date should carry the EU label and not Triman, and a French pack printed before it can carry Triman for the three-year sell-through window. There is no period in which both are expected on the same new pack.

## Small packs, QR codes and the digital route

The PPWR, France and Spain each give small packs a digital route, but with different tests (Exhibit 9). A pack that qualifies for a QR code in one regime may not in another, which matters until the EU label applies.

The PPWR test is a fallback order, not a size threshold. A small pack first moves its label to outer packaging, and only if that is also impossible does a single code take its place. SPI has not yet confirmed whether the implementing act will set a minimum pictogram size; the JRC proposal has a section on label size, which SPI has not yet read in full.

In practice: Der Grüne Punkt and PRO Europe.

On 12 May 2026 Der Grüne Punkt announced EU-wide coverage for DigiDot, a sorting guide reached through one QR code on the pack that gives location-specific instructions for each component and can show the nearest collection point. The release cites more than 1,000 packaging types, about 50,000 branded products and over 500,000 collection container locations, and a rollout supported by the PRO Europe network of 31 member systems. Digi-Cycle, the Austrian company behind the tool, joined the GreenDot group in April 2026. The release presents QR codes as an optional tool under Article 12.

In practice: ARA.

Austria's ARA, a PRO Europe member, said in its own release of 12 May 2026 that its earlier digital recycling guide laid the foundation for DigiDot, which it describes as the digital evolution of the Green Dot. ARA names the PPWR and the Empowering Consumers Directive as the new rules on labelling and consumer information that DigiDot is built to meet, and says the QR approach reduces printing effort because product information no longer has to be printed on the pack. The [EPR fees per tonne piece](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) shows ARA's household fee lines.

## Scenarios: what the adoption date does to every label date

Exhibit 10 runs three adoption dates through the clocks in Exhibit 3. All three come from the Commission's planned window or a stated slip from it; none rests on press reports.

**SPI calculation:**  in the base case the sorting label applies 24 months after 20 January 2027, on 20 January 2029, which is later than the 12 August 2028 floor, so the clock decides. The reuse label applies 30 months after 20 January 2027, on 20 July 2029, later than its 12 February 2029 floor. Bin labels apply 30 months after adoption on 31 December 2026, on 30 June 2029. The sell-through window closes three years after each label date.

Two results hold in every case. The EPR date is unaffected, and the gap between the pack label and the bin label stays at 161 to 163 days, because both clocks move together. The reuse label always comes six months after the sorting label once the clock decides.

The window between the end of the old codes and the start of the new label grows with every month of delay (Exhibit 11).

SPI analysis

The guidance ties the end of the 97/129 abbreviations to the fixed date, while Recital 74 repeals the Decision from 12 August 2028, and the label itself floats. A manufacturer that prints material abbreviations under the Decision should plan for packs made from 12 August 2028 to drop them, even if the EU label is not yet due. The low-cost move is to print the EU label as soon as the act fixes its design, rather than waiting for the mandatory date.

In practice: Sanofi.

Sanofi's Europe sales were EUR 9,169 million in 2025, and it used 1.4 million cold chain shippers in 2024 (SPI Packaging Buyers Database, Sanofi profile, citing company reports including its eco-design factsheet of July 2026). Shippers are transport packaging, which is outside the sorting label unless it is e-commerce packaging, and Article 12(11) excludes medicinal immediate and outer packaging where there is no room for the label or labelling could compromise safe use. Secondary cartons that have room remain in scope. SPI has not seen Sanofi's label plan, so the share of its packs that will carry the EU label is not estimated.

## A scope test for each pack

Exhibit 12 turns Articles 12 and 13 and the guidance into a sequence of questions a packaging team can run on each stock keeping unit.

Deposit packaging follows a separate path, set out in the [deposit return piece](https://www.strategicpackaginginsights.com/insights/deposit-return-europe-uk/) and the tracker's [PR-EU-007](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-007/) rule. E-commerce boxes stay in scope, which the [e-commerce packaging piece](https://www.strategicpackaginginsights.com/insights/ecommerce-packaging-amazon-alibaba-ppwr/) covers for marketplaces.

## What it means along the chain

**Converters and printers.**  Article 12(5) asks for labels that are visible, clearly legible and indelible, printed, engraved or affixed so they cannot easily be removed. For converters the label is a plate and ink question first: the JRC's note that producers rejected colour-filled glass pictograms on printing grounds shows that print limits shaped the proposal. A converter that supplies several brands should expect one set of EU artwork files to replace several national ones, and should ask customers now which packs will move first.

**Brand owners.**  The brand that places packaging on the market carries the label duty, and the information must also reach buyers before purchase in online sales. That makes the product page part of the label: a pack photograph that shows Triman or a Spanish bin instruction after the label date would sit badly with the switch. Brand owners also hold the data for the later tracks, the component list for the optional disposal QR code and, from the 2030s, the substance concentrations for digital marking.

**Retailers and marketplaces.**  E-commerce packaging is the one kind of transport packaging that stays inside the sorting label duty (guidance, section 13). Retailers that pack online orders in their own boxes become the party whose box carries the label.

**Compliance schemes.**  Schemes meet the labels at two points. The EPR symbol becomes digital only on 12 February 2027, which turns a printed mark into a data service, as DigiDot shows. And Recital 127 says producers should finance the labelling of waste receptacles, which schemes collect through fees. In Spain, article 13 of Royal Decree 1055/2022 already makes producers gather composition data from packaging makers and pass it free of charge to waste managers through their EPR systems, according to MITECO's note.

**Member States.**  Under Article 13(1) Member States must ensure that every packaging waste receptacle carries the harmonised labels, and a bin may carry more than one. They may require a harmonised colour label for deposit packaging, but may not prohibit deposit labels from other Member States. Recital 136 leaves them rules on bin labelling only where the Regulation does not fully harmonise the subject.

SPI analysis

The label moves cost from artwork to data. The printed part of the EU label is likely to be simpler than today's national marks, but the digital parts (EPR symbol, reuse tracking, component destinations and substances of concern) need product data that many brand owners hold in scattered systems. Teams that build one packaging data record per SKU now will meet every later track with the same file.

## Industry reaction

> "To ensure uniform implementation, the Commission is empowered to establish harmonised pictograms and labelling specifications for packaging and waste receptacles through an Implementing Act drafted in consultation with stakeholders."

***European Commission** , EU executive, [Have Your Say data record for initiative 19243 on harmonised labels](https://ec.europa.eu/info/law/better-regulation/brpapi/groupInitiatives/19243), planning notice published 14 September 2026*

The same record plans adoption in the fourth quarter of 2026 and lists the draft stage as still to come.

> "Member States will not be allowed to keep their national labels next to EU harmonised labels after 12 August 2028 or 24 months from the date of entry into force of the implementing act specifying the labelling rules and pictograms."

***European Commission** , EU executive, [Guidance document for Regulation (EU) 2025/40, C/2026/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), 10 June 2026*

The guidance ties the end point for national marks to the same floating clock as Article 12(1), so it moves with the act.

> "Current sorting practices remain suboptimal due to packaging complexity and the absence of a unified labelling approach, which generates market fragmentation for producers and inconsistent information for citizens."
>
>
>
> **Joint Research Centre** , European Commission science service, [technical proposal on EU harmonised waste sorting labels](https://publications.jrc.ec.europa.eu/repository/bitstream/JRC141706/JRC141706_01.pdf), 13 January 2026
>
>
>
> "DigiDot contributes to addressing this challenge by linking a single QR code on packaging to dynamic digital information."

***Der Grüne Punkt** , German packaging compliance scheme, [release on EU-wide DigiDot coverage](https://www.gruener-punkt.de/en/company/news/details/qr-code-based-sorting-guide-digidot-now-offers-eu-wide-coverage), 12 May 2026*

In the same release, the company's managing director argues that harmonised labelling and dynamic digital guidance work best together.

## What leaders should do now

1. **Heads of packaging compliance, by 31 December 2026:**  list every SKU that prints an EPR symbol, including the Green Dot, and agree with each scheme how the 12 February 2027 digital-only rule applies to it.
2. **Artwork and print managers, before the next plate cycle in 2027:**  reserve one fixed panel for the EU sorting pictogram and one for a data carrier on every new EU pack, so the label switch is a plate change.
3. **Regulatory affairs, from now until adoption:**  watch Have Your Say record 19243 weekly; when the draft decision opens for feedback, review the pictograms against your pack range and submit comments in the window.
4. **Packaging design teams, within 30 days of adoption:**  recompute every label date from the act's entry into force using Exhibit 10, and set the 97/129 code phase-out for packs made from 12 August 2028.
5. **French and Spanish market leads, by mid-2028:**  plan one switch day per market from Triman and Info-tri or the RD 1055/2022 bin instruction to the EU label, and record manufacture dates for the three-year sell-through window.
6. **Reuse system operators, by February 2029:**  fit trip tracking or an average estimate method to every reusable unit, and log placing dates for transport packaging placed from 11 February 2025.
7. **Marketing and claims teams, before any 2028 relaunch:**  route every recycled or bio-based content claim through the harmonised label rules and the Article 12(8) ban on labels likely to mislead.

## Questions for your board

- How many of our SKUs carry a printed EPR symbol today, and what does moving them into a code cost before February 2027?
- Have we budgeted one artwork change per EU pack for the sorting label, or two because Triman, Spanish or other national marks are on separate plates?
- Which of our packs are excluded (transport, deposit, medicinal) and which still need the label?
- Who in the company watches the Commission's labelling act, and how fast can we respond when the draft pictograms appear?
- Do our reusable fleets have data carriers that can count trips by 2029?
- What would a six-month slip in the act do to our 2028 and 2029 packaging plans?

## What to watch

- **Q4 2026:**  the Commission's planned adoption window for the labelling implementing decision closes on 31 December 2026 (Have Your Say record 19243).
- **Q4 2026 or later:**  publication of the draft decision for feedback, the first public view of the pictograms.
- **12 Feb 2027:**  the EPR symbol may appear only in a QR code or other open digital carrier (Article 12(9)).
- **2027 onwards:**  the Assemblée nationale's decision on the bill that would replace Triman with the EU scheme.
- **12 Aug 2028:**  fixed floor for the sorting, content and bin labels; Decision 97/129/EC abbreviations end.
- **20 Jan 2029:**  SPI base case start of the sorting label, if the act is adopted on 31 December 2026.
- **1 Jan 2030:**  legal deadline for the Article 12(7) act on digital marking of substances of concern.

## Methodology

- **Data used:**  SPI Regulation Tracker rules [PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/), [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), [PR-EU-007](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-007/), [PR-FR-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-003/) and [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/), among the tracker's 79 rules; Regulation (EU) 2025/40 recitals on EUR-Lex and the text of Articles 12 and 13 as reproduced by lxgesetze.de, an unofficial German text that SPI has not yet confirmed against the article text in the Official Journal (the Commission Notice confirms the 12 August 2028 or 24-month rule for the sorting label and the digital-only reading of Article 12(9); the 12 February 2027 and 12 February 2029 dates and the paragraph numbers rest on the unofficial text); Commission Notice C/2026/3084; the C(2026) 2151 annex; the Have Your Say record for initiative 19243; the Commission Green Forum page; JRC technical proposal JRC141706; French and Spanish official texts; scheme releases. All consulted on 29 October 2026.
- **Counting rules:**  months are added to calendar dates; "whichever is later" is applied to every floating date; the Article 13 clock runs from adoption and the Article 12 clocks from entry into force.
- **Scenarios:**  low and base adoption dates sit inside the Commission's planned Q4 2026 window; the high case is an SPI assumption of a six-month slip. Entry into force 20 days after adoption is an SPI assumption.
- **Commission timing:**  only the Commission's own records are used; press reports on a further delay are not.
- **Cut-off:**  29 October 2026.
- **Limitations:**  the English text of Articles 12 and 13 is taken from the Commission's guidance where it quotes them and otherwise from the German text; the implementing act's content is not yet known; the JRC proposal is not binding. This is analysis for planning, not legal advice; check with counsel.

## Sources

1. EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 22.1.2025, recitals 64 to 74, 127 and 136, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-29.
2. Regulation (EU) 2025/40, Article 12, German text as reproduced by lxgesetze.de, [https://lxgesetze.de/ppwr/12](https://lxgesetze.de/ppwr/12), consulted 2026-10-29.
3. Regulation (EU) 2025/40, Article 13, German text as reproduced by lxgesetze.de, [https://lxgesetze.de/ppwr/13](https://lxgesetze.de/ppwr/13), consulted 2026-10-29.
4. EUR-Lex, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 (OJ C, 10.6.2026), [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-10-29.
5. European Commission, Annex to C(2026) 2151 final, approval of the draft guidance notice (30 March 2026), [https://environment.ec.europa.eu/document/download/3d59ca88-539c-4b6b-a623-0f61068e853e_en?filename=Annex+to+the+Communication+to+the+Commission.pdf](https://environment.ec.europa.eu/document/download/3d59ca88-539c-4b6b-a623-0f61068e853e_en?filename=Annex+to+the+Communication+to+the+Commission.pdf), consulted 2026-10-29.
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