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

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.

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 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.

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 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).

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 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 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 covers the decree’s fees.

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.

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).

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 and the tracker’s PR-EU-007 rule. E-commerce boxes stay in scope, which the e-commerce packaging piece 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.