Marius Cristian Brînzea · Managing Partner
26 October 20264 min read
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) applies from 12 August 2026. Among its most visible novelties: every piece of packaging will carry an EU-harmonised label on material composition, so consumers can sort it correctly - the same pictograms on the packaging and on collection receptacles across the Union. The label's technical specifications were to be adopted by the Commission through an implementing act by 12 August 2026.
That deadline was missed, and the planning the Commission published in September promised adoption by the end of 2026. Around 19-20 October, the official planning calendar was pushed back again: adoption is now estimated for Q2 2027, preceded by a public consultation on the draft - the first moment the pictograms will be made public.
The knock-on effect comes from the regulation's own text: the label becomes mandatory from 12 August 2028 or 24 months after the implementing act enters into force, whichever is later. With an act adopted in the summer of 2027, the obligation would realistically apply only towards mid-2029.
The delay concerns the sorting label only. The PPWR obligations that entered into application on 12 August 2026 remain untouched: the identification markings on the packaging (type, batch or serial number and the details of the manufacturer and, where relevant, the importer), the ban on labels and symbols likely to mislead consumers about environmental characteristics, the requirements on substances and the conformity documentation.
The marking you use today remains valid: the material identification system of Decision 97/129/EC (PET 1, PAP 20 and the other codes) may still be used - the regulation repeals it only from 12 August 2028. National obligations - extended producer responsibility, the deposit-return system (DRS), declarations to the Environment Fund (AFM) - are not affected in any way.
Do not order "anticipated" labels: the final pictograms are not yet public, and any artwork printed now risks being redone entirely. Use the delay to run down existing packaging and label stocks, and when redesigning artwork, reserve space now for the future label, so you avoid a complete rework in 2027-2028.
Prepare instead what will not change: inventory the material composition of every packaging item in your portfolio - the harmonised label will be built on this data, and the 24-month window passes quickly with a large portfolio - and follow the public consultation, the real opportunity to flag practical problems: small formats, multi-material packaging, sales in several member states. Circulad'OR tracks the PPWR implementing acts calendar for its clients and can get your portfolio ready for the new labels: from the material composition inventory, managed in the Yvora platform, to checking the markings already mandatory on your packaging. Write to us if you want to know exactly where you stand.
The first conversation is free: you find out what applies to you, by when, and who does it - you, us, or the application.