​With less than 4 months to go until PPWR takes application in the European Union, inevitably much attention is diverted to deadlines associated with Declaration of Conformity (DoC) requirements, PFAS restrictions, and changes to EPR rules. However, the 12 August 2026 is also a key milestone for the European Commission. By this date, the European Commission is required to adopt implementing acts on mandatory harmonised waste sortation requirements, which will become a legal requirement 2 years from this date (12 August 2028 or 24 months from entry into force of implementing acts).
Whilst labelling may seem like a less-immediate priority until implementing rules are set, organisations should be mindful that the PPWR will impose additional requirements for labelling as early as 2026 and 2027.
As part of our PPWR blog series, today we will explore the road to PPWR harmonised sortation labelling in 2028 and provide examples of other labelling rules to watch out for in 2026 and 2027.
Harmonised waste sortation labelling: What to expect in 2028
From 12 August 2028, all packaging (with the exception of most transport packaging) must be labelled with a pictogram identifying the material composition. These pictograms will mirror those displayed on waste collection containers across the EU, helping consumers to correctly sort packaging waste.
The precise design and application rules for the harmonised sorting label must still be determined by the Commission via implementing acts by 12 August 2026. The Commission's Joint Research Centre (JRC) has already published prototype label specification designs, which are expected to inform eventual rules adopted by the Commission in 2026. Despite this, businesses must await implementing acts for full legal certainty.
Member States will not be allowed to keep their own mandatory national labels alongside the harmonised EU sortation label after 12 August 2028 (or 24 months from the date of the entry into force of implementing act). In the meantime, it is expected that Member states will begin to repeal existing mandatory sortation requirements. Certain Member States have already lodged draft legislation to initiate this process of repeal.
What about other rules for packaging labelling? Watch out for additional rules in 2026 and 2027
One of the most commonly overlooked aspects of PPWR labelling is the existence of earlier requirements that apply before 2028. For example:
From PPWR application (12 August 2026), manufacturers shall ensure packaging bears a type, batch or serial number allowing for its identification (on-pack or via accompanying documentation). Manufacturers are additionally required to indicate on the packaging (or via a QR code or another data carrier) their name, registered trade name or registered trademark as well as postal address.
From 12 February 2027, EPR system participation symbols (e.g. Green Dot) will no longer be permitted on pack. If used, such identification shall be achieved only via digital means (in a QR code or other standardised, open digital-marking technology).
Additional labelling rules will be introduced under the PPWR for compostable and biobased packaging, reusable packaging, and packaging subject to DRS. The PPWR will also regulate claims relating to recycled content in plastic packaging.
Practical considerations and the wider regulatory context
Packaging artwork changes must be carefully planned to avoid unnecessary redesigns or rework. As such, it is not only essential to consider the PPWR requirements holistically but the wider EU context in which PPWR sits. In particular, Directive (EU) 2024/825 on Empowering Consumers for the Green Transition introduces new prohibitions on the making of generic, unsubstantiated environmental claims (for example, "environmentally friendly") and sets new rules for the display of sustainability labels.
Unlike the PPWR however, the Empowering Consumers Directive must be transposed by Member States to take legal application. This creates an additional layer of complexity, as businesses must track which Member States have already transposed these rules in line with EU prescribed deadlines.
How Lorax EPI can support you
At Lorax EPI, we track and monitor mandatory packaging labelling requirements globally, not just within the European Union. Whether your organisation seeks PPWR clarity or requires global outlook, we can offer:
A PPWR labelling guide, summarising upcoming deadlines into a clear, practical action checklist for your organisation, inclusive of the wider context of the Empowering Consumers Directive
A global matrix of mandatory packaging sortation requirements, with tailored guidance on how to meet applicable rules based on packaging format