PPWR Labelling Requirements: Sorting, Reuse and DRS Labels, with the Sorting Label Applying Later than 12 August 2028

Article 12 of the PPWR (Regulation (EU) 2025/40) sets the labelling requirements for packaging: a harmonised sorting label, a reusable packaging label with a QR code, a deposit return label and rules for voluntary and digital labels; only the ban on misleading labels and some checks apply today, since 12 August 2026. The harmonised sorting label itself applies from 12 August 2028 or 24 months after the Commission's implementing acts, whichever is the latest, and is therefore later than 12 August 2028.

Labelling is Chapter III of the EU Packaging and Packaging Waste Regulation (PPWR), after the sustainability requirements, and covers Art. 12 (packaging), Art. 13 (waste receptacles) and Art. 14 (environmental claims). The Art. 12(6) implementing act that fixes the label designs was due on 12 August 2026, and no Art. 12(6) or Art. 12(7) implementing act is adopted as of 24 October 2026.

This page sets out every Art. 12 label with its paragraph and date rule, what already applies, the exclusions, placement and language rules, the wording of Art. 12(9) on the EPR symbol, the 3-year sell-off rule and who answers for the label.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every date on this page is checked against EUR-Lex and Commission guidance, see our methodology and fact-checking.

The key facts of the PPWR labelling requirements are summarised in the table below.

What Are the PPWR Labelling Requirements under Article 12?

The PPWR labelling requirements in Art. 12 cover the sorting label, the reusable label, the DRS label, voluntary recycled-content and bio-based labels, digital marking of substances of concern and the EPR symbol, plus a ban on misleading marks. Each label has its own paragraph and its own date rule, and most dates depend on a Commission implementing act.

The table below lists every Art. 12 label with its status on 24 October 2026.

Art. 12 has twelve paragraphs: paragraphs 1 to 5 set the labels and how they are shown, paragraphs 6 and 7 mandate the implementing acts, paragraph 8 bans misleading marks, paragraphs 9 and 10 cover EPR and deposit symbols, and paragraphs 11 and 12 deal with medical packaging and old stock. The full wording of all twelve paragraphs is in Article 12 in the PPWR legal text.

Which PPWR Labelling Rules Already Apply since 12 August 2026?

Since 12 August 2026 the ban on misleading labels in Art. 12(8) applies, and importers and distributors must check that packaging is labelled in accordance with Art. 12 before it reaches the market. The PPWR has been in force since 11 February 2025 (Art. 71) and applies generally from 12 August 2026. The importer check sits in Art. 18(2)(b) and the distributor check in Art. 19(2)(b); the harmonised labels themselves still wait for the Art. 12(6) implementing act.

Are misleading labels, marks and symbols banned?

Yes: Art. 12(8) PPWR bans labels, marks, symbols and inscriptions likely to mislead or confuse end users about the sustainability requirements, characteristics or waste management options of packaging. The ban applies from 12 August 2026 and is without prejudice to requirements concerning other harmonised EU labels. What counts as misleading follows Directive (EU) 2024/825, according to the Commission's PPWR FAQ (non-binding), section VIII, 2nd edition (August 2026).

Can packaging still carry the Packaging Directive material codes?

Yes, until 12 August 2028: the Commission reads the Decision 97/129/EC material codes as voluntary until that date, in the Decision's form if used, and as no longer allowed once Art. 70(2) PPWR repeals the Decision. That reading comes from Commission Notice C/2026/3084 (OJ C, 10.6.2026), section 13, which is non-binding. Decision 97/129/EC is repealed with effect from 12 August 2028.

A second, separate date governs the marking article of the old Directive. Art. 70(1)(a) PPWR keeps Art. 8(2) of Directive 94/62/EC (marking for material identification) in force until 30 months after the entry into force of the Art. 12(6) implementing act, while the rest of the Directive is repealed with effect from 12 August 2026. Which marking rules of the Packaging Directive 94/62/EC carry over, and for how long, is explained on the comparison page.

When Does the Harmonised Sorting Label Apply?

The harmonised sorting label applies from 12 August 2028 or 24 months after the implementing acts under Art. 12(6) or (7) enter into force, whichever is the latest, and because no such act was adopted by 12 August 2026 the date will be later than 12 August 2028. The 24-month limb therefore governs. The sorting label is one of several PPWR application dates that depend on a Commission act.

The Art. 12(6) implementing act, due 12 August 2026, is planned as a Commission implementing decision on harmonised labels under Have Your Say initiative 19243, whose planning record was published on 14 September 2026. The draft is not yet open for feedback and nothing is adopted as of 24 October 2026. The first-subparagraph act under Art. 12(7), on identifying material composition by digital marking, was also due on 12 August 2026, and the Commission states in the introduction to Notice C/2026/3084 that it does not intend to prioritise it.

Which packaging needs the sorting label, and which is excluded?

All packaging needs the material composition label except transport packaging that is not e-commerce packaging and packaging covered by a deposit and return system under Art. 50(1). The label is pictogram-based and must be easily understandable, including for persons with disabilities (Art. 12(1)). Medical device and medicinal product packaging has a separate exemption in Art. 12(11), set out in the last section of this page.

The three scope groups of the Art. 12(1) sorting label are listed below.

• Sales, grouped and e-commerce packaging: needs the harmonised sorting label.
• Transport packaging other than e-commerce packaging: excluded.
• Packaging in a deposit and return system under Art. 50(1): excluded, and labelled as DRS packaging instead.

Is there an official design for the EU sorting label yet?

No: the pictograms and specifications come only with the Art. 12(6) implementing act, which is not adopted, and the Joint Research Centre's technical proposal of 13 January 2026 does not bind the Commission. The JRC technical proposal JRC141706 on harmonised waste sorting labels states that the Commission is free to amend it or depart from it. Artwork based on it is a design choice, not compliance with an adopted act. What the proposal shows is described under EU harmonised sorting labels and symbols.

What Must Reusable Packaging Carry under Article 12(2)?

Reusable packaging must carry the harmonised reusable label and a QR code or other digital data carrier from 12 February 2029 or 30 months after the Art. 12(6) implementing act enters into force, whichever is the latest. Its floor date of 12 February 2029 is 6 months after the sorting label's floor date of 12 August 2028, and both dates depend on the Art. 12(6) act. The data carrier follows the definition in Art. 2(29) of Regulation (EU) 2024/1781, which Art. 3(2) PPWR applies.

The data carrier gives information on the re-use system: its availability, the collection points, tracking, and the number of trips and rotations. Art. 12(3) PPWR exempts open loop systems without a system operator from both the label and the QR code. What the data carrier must contain is set out under QR codes for reusable packaging.

How Must Deposit Return Packaging Be Labelled?

Packaging in a deposit and return system under Art. 50(1) PPWR must carry a clear and unambiguous label, and may also carry the harmonised colour label, which a Member State can make mandatory. Art. 50(1) covers single-use plastic beverage bottles and single-use metal beverage containers up to 3 litres, for which Member States set up deposit systems by 1 January 2029 to reach 90 % separate collection. DRS packaging is excluded from the Art. 12(1) sorting label.

DRS labelling is not harmonised, so the DRS label of the Member State where the packaging is made available applies, according to the Commission's PPWR FAQ (non-binding), section VIII. Art. 12(10) allows a national symbol for deposit systems outside Art. 50(1) and forbids Member States to prohibit the DRS labels of other Member States. Which bottles and cans must be in a deposit system is explained under deposit return systems under the PPWR.

Are Recycled-Content and Bio-based Content Labels Mandatory?

No: recycled-content and bio-based content labels are voluntary under Art. 12(4) PPWR, but a recycled-content label used on packaging placed on the market from 12 August 2028 or 24 months after the Art. 12(6) act, whichever is the latest, must follow the harmonised specifications and the Art. 7(8) calculation method. Recital 67 confirms that the recycled-content label is not mandatory. A bio-based content label, if used, must follow the Art. 12(6) specifications. The label is voluntary; the PPWR recycled content targets are not.

What must the compostable packaging label say?

Packaging that must be compostable under Art. 9(1) PPWR, and where applicable Art. 9(2), must state that it is compostable, not suitable for home composting and not to be discarded in nature. The three statements are part of the Art. 12(1) label.

Art. 9(1) covers permeable tea, coffee and beverage bags, soft after-use single-serve units and fruit and vegetable sticky labels, which must be compostable by 12 February 2028. Which items must be compostable is covered under PPWR compostable packaging.

Substances of concern: digital marking and the Article 12(7) implementing acts

Packaging containing substances of concern must be marked with standardised, open digital-marking technology under a methodology the Commission must adopt by 1 January 2030, showing at least the name and concentration of each substance per material. That methodology is the second-subparagraph mandate of Art. 12(7). The first-subparagraph mandate, on material composition, was due on 12 August 2026; the two dates are separate.

Art. 12(1), third subparagraph, adds an optional QR code or other standardised, open digital data carrier showing the destination of each separate component. The status of both mandates is tracked under PPWR implementing acts.

How Must PPWR Labels Be Placed, and What about Online Sales and Languages?

Art. 12(5) PPWR requires labels to be affixed, printed or engraved visibly, legibly and firmly so that they cannot easily be erased, and the same information to be available before purchase in online sales. Art. 12(5) also sets two fallbacks for the label. Five rules of Art. 12(5) are listed below.

• Placement: affixed, printed or engraved visibly, legibly and firmly, so that the label cannot easily be erased.
• Fallbacks: the grouped packaging first, then a single electronically readable code or other data carrier.
• Online sales: the label information is available to end users before purchase.
• Language: one or more languages easily understood by end users, as determined by the Member State where the packaging is made available.
• Electronic information: personal data only as needed under Art. 5(1) of Regulation (EU) 2016/679, and no display together with sales or marketing information.

Where other Union law requires a product data carrier, Art. 12(5) asks for one data carrier for product and packaging, with the packaging information easily distinguishable.

What Does Article 12(9) Say about the EPR Symbol?

Art. 12(9) PPWR reads:

"By 12 February 2027, packaging included in an extended producer responsibility scheme may be identified throughout the territory of the Member States in which that scheme or system applies. Such identification shall be achieved only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology."

The English text reads "By 12 February 2027", while the German version reads "Ab dem 12. Februar 2027" and the French version "Au plus tard". A corrigendum of 21 July 2026 (OJ L, 2026/90604) changed the Czech text from "Do" to "Od" and from "postačí" to "pouze". No corrigendum has changed the English wording as of 24 October 2026, and this page quotes it as it stands. Art. 12(9) also requires that the symbol does not mislead on recyclability or reusability. The symbol identifies a scheme; registration and fees are explained under EU packaging EPR.

Can Packaging Made before a Labelling Requirement Applies Still Be Sold?

Yes, for a limited time: packaging manufactured in the Union or imported before a labelling requirement of Art. 12 applies may be placed on the market for 3 years from the date that requirement applies. Art. 12(12) runs per requirement, so the 3 years for the sorting label start only once its own date is known, and the reusable label has its own clock.

Stock produced before 12 August 2026 but not yet placed on the market need not be destroyed, remanufactured or re-labelled, according to the Commission's PPWR FAQ (non-binding), section X. Packaging placed on the market before 12 August 2026 may remain on the market.

Who Is Responsible for PPWR Labelling?

Three economic operators share the labelling duties: the manufacturer may place packaging on the market only if it complies with the PPWR (Art. 4(1)), the importer must ensure it is labelled in accordance with Art. 12 and the distributor must verify it. The manufacturer documents compliance under Annex VII internal production control (Art. 38), with no notified body, no CE marking and no PPWR certificate.

Art. 18(2)(b) PPWR makes the importer ensure that packaging from a third country is labelled in accordance with Art. 12 before it places it on the market. The label check is one of the PPWR obligations of importers before release.

Art. 19(2)(b) PPWR requires the distributor to verify that the packaging is labelled in accordance with Art. 12 before making it available. Producers or their producer responsibility organisations must also explain the meaning of Art. 12 labels to end users under Art. 55(1)(d), from 12 August 2028 or the application date of the relevant Art. 12 provision, whichever is the latest.

The table below shows who does what for PPWR labelling.

A QR code or data carrier under Art. 12 that gives no access to the required information is formal non-compliance under Art. 62(1)(c), and if it persists Art. 62(2) leads to a prohibition, recall or withdrawal. National penalty rules are due by 12 February 2027 under Art. 68; see PPWR penalties and market surveillance.

How Do the PPWR Labelling Requirements Fit with National Labels, Waste Receptacles and Other PPWR Rules?

Art. 12 sits in Chapter III of the PPWR next to Art. 13 on waste receptacles and Art. 14 on environmental claims, which may only concern properties that go beyond the minimum requirements of the Regulation. Art. 14 claims must also state whether they relate to the packaging unit, part of it or all packaging of the operator. Labels report on design rules that are explained under PPWR requirements for packaging.

General environmental claims law under Directive (EU) 2024/825 is covered on greenwashingdirective.com. The digital product passport under Regulation (EU) 2024/1781, named in recital 70 of the PPWR, is covered on esprguide.com.

Can Member States keep national sorting labels?

Not once the harmonised label applies: the Commission reads Art. 12 as exhaustive and fully harmonised except for DRS labels, so national sorting instructions are not allowed and national labels may not be kept next to the EU label after 12 August 2028 or 24 months after the implementing act, whichever is later. That reading is in Notice C/2026/3084, section 13, which is non-binding.

Art. 4(2) PPWR adds that Member States shall not prohibit, restrict or impede packaging that complies with the labelling and information requirements of Articles 5 to 12. In France, the Triman logo remains mandatory under national law as of 24 October 2026. How the French label relates to the EU label is explained under Triman and France's sorting label rules.

Labels on packaging waste receptacles (Article 13) and end-user information

Art. 13 PPWR obliges Member States, not producers, to put harmonised labels on all packaging waste receptacles except DRS receptacles, from 12 August 2028 or 30 months after the adoption of the Art. 13(2) implementing acts, whichever is the latest. The Art. 13(2) acts were due on 12 August 2026 and are not adopted as of 24 October 2026; this date runs from adoption, not from entry into force.

The cost of labelling receptacles is covered by producers' EPR financial contributions under Art. 45(2)(a). Receptacle labels support separate packaging waste collection.

Does Article 12 apply to medical device and medicinal product packaging?

Not always: Art. 12(11) PPWR exempts immediate and outer packaging under the medical device, in vitro diagnostic, veterinary medicinal product and medicinal product rules where there is no space or safe use would be jeopardised. The instruments are Regulations (EU) 2017/745, 2017/746 and 2019/6 and Directive 2001/83/EC.