Artwork approved this year will still be printing in 2028 and beyond, so marketing teams are asking a practical question: how much space should we reserve on our cups, bags and boxes for a label whose design the EU has not yet published? The PPWR labelling requirements in Article 12 of Regulation (EU) 2025/40 introduce a harmonised, pictogram-based label showing material composition to help consumers sort waste, plus separate labels for reusable packaging and rules for compostable packaging. The sorting label will not be mandatory before 12 August 2028, and in practice later, because the Commission has not yet adopted the implementing act that defines it.
This guide sets out what must be labelled, when, by whom, how national labels such as France's Triman are affected, and what to build into artwork now. For the wider PPWR picture, start with our PPWR overview for foodservice and e-commerce buyers. This is orientation, not legal advice; confirm obligations for your role and markets with the competent authority or your compliance scheme. Labels that carry product and ingredient information on food packs are a separate topic, covered in food packaging labels.
Status as of October 2026. Sources: Regulation (EU) 2025/40, Article 12, on EUR-Lex (eur-lex.europa.eu/eli/reg/2025/40/oj), and Commission guidance notice C(2026) 3702 of 5 June 2026 (non-binding).
When do the PPWR labelling requirements apply?
The harmonised sorting label applies from 12 August 2028 or 24 months after the implementing acts defining it enter into force, whichever is later. The Commission was due to adopt those acts by 12 August 2026 and had not done so as of October 2026, so the label will in practice become mandatory later than August 2028. The reusable-packaging label follows from 12 February 2029 or 30 months after its implementing act, whichever is later.
| Requirement | Article | Applies from | Status (Oct 2026) |
|---|---|---|---|
| Manufacturer name, trade name or trademark and postal address on packaging (or data carrier or accompanying document) | Art 15(6) | 12 Aug 2026 | Applies now |
| Type, batch or serial number or other identification | Art 15(5) | 12 Aug 2026 | Applies now |
| Importer name and address | Art 18(3) | 12 Aug 2026 | Applies now |
| Harmonised material-composition sorting label | Art 12(1) | Later of 12 Aug 2028 or 24 months after implementing act | Act not adopted; in practice after Aug 2028 |
| Compostable packaging wording in the label | Art 12(1) | With the sorting label | Depends on same act |
| Reusable packaging label and QR code or data carrier | Art 12(2) | Later of 12 Feb 2029 or 30 months after implementing act | Act not adopted |
| Recycled-content or bio-based content label (voluntary, but harmonised format if used) | Art 12(4) | Later of 12 Aug 2028 or 24 months after implementing act | Act not adopted |
| Digital marking of substances of concern | Art 12(1), 12(7) | After methodology act due by 1 Jan 2030 | Not adopted |
Article 12(12) adds a sell-off rule: packaging manufactured in the EU or imported before these deadlines may still be made available for up to three years after the requirement takes effect. That helps with stock, but it does not cover items manufactured after the deadline with old artwork.
What will the harmonised sorting label show?
The label will show the packaging's material composition through pictograms designed to be easily understood, including by people with disabilities, so that consumers know which bin to use. Its exact design, colours and format will be set in the implementing act, and matching labels will appear on waste bins under Article 13.
What the Regulation already fixes:
- It is pictogram-based, not text-based, so one design can work across languages.
- It must be printed, affixed or engraved visibly, legibly and indelibly on the packaging.
- Where size or nature of the packaging does not allow it, the label goes on the grouped packaging, and where even that is not possible, the information can be provided through a single electronically readable code.
- The information must also be available to online buyers before purchase.
- Operators may add a QR code or other open data carrier giving the destination of each separate component, alongside the label (not instead of it).
- Composite packaging must be accounted for, so a paper cup with a plastic lining or a bag with a window will need a label that reflects more than one material.
The Joint Research Centre published a technical proposal for the labels in January 2026, but that is input to the implementing act, not the final design. Do not print draft pictograms as if they were the EU label.
Which packaging must carry the label?
All packaging placed on the EU market needs the sorting label once it applies, with two main exceptions: transport packaging (other than e-commerce packaging) and packaging in a deposit and return system, which has its own labelling. E-commerce packaging is expressly covered, so printed mailer boxes and shipping bags sent to consumers need the label.
| Packaging type | Sorting label required? | Notes |
|---|---|---|
| Takeaway cups, food boxes, bags, wraps (service packaging) | Yes | Small items may use grouped packaging or a code where space is insufficient |
| Retail sales packaging (cartons, pouches) | Yes | |
| E-commerce mailer boxes and shipping bags | Yes | Express exception to the transport packaging exclusion |
| Other transport packaging (outer cases, pallet wrap) | No | Unless it is e-commerce packaging |
| Deposit and return packaging (e.g. drinks bottles and cans in DRS) | Not the sorting label | Clear DRS label instead; optional harmonised colour label |
| Certain medical and medicinal product packaging | Exemptions in Art 12(11) | Where space or safe use require it |
Who must make sure packaging is labelled?
The manufacturer must make sure packaging meets Article 12 before placing it on the market, because labelling is one of the requirements covered by the PPWR declaration of conformity. Importers must check labelling before placing imported packaging on the market, and distributors must verify it before making packaging available. For custom printed packaging, the manufacturer is often the brand owner.
In practice this means the business whose brand is on the packaging owns the artwork decision, while the printer reproduces what is approved and the importer checks it. If you import printed packaging from outside the EU, the label must be correct on arrival; a distributor or importer that later modifies packaging in a way that could affect compliance is treated as a manufacturer under Article 21. How the declaration and its technical file work is covered in our guide to the PPWR declaration of conformity.
How do reusable and compostable packaging labels work?
Reusable packaging will carry a label saying it is reusable, plus a QR code or other open data carrier with information on the re-use system and collection points, from 12 February 2029 or 30 months after the implementing act, whichever is later. Compostable packaging must state, within the harmonised label, that it is compostable, not suitable for home composting and not to be discarded in nature.
Reusable packaging
The data carrier must facilitate tracking of the packaging and calculating its trips and rotations, or give an average estimate where tracking is not feasible. Reusable sales packaging must also be clearly distinguishable from single-use packaging at the point of sale. Open-loop systems without a system operator are exempt from the label and data carrier. For chains preparing the reusable offer required for takeaway from February 2028, choose a reusable cup or container format whose surface can take a permanent mark and a durable code, since printed labels on reusables must survive washing cycles.
Compostable packaging
The compostable wording applies to the formats the PPWR requires to be compostable (tea and coffee bags and pods, sticky fruit and vegetable labels and, where a Member State requires it, very lightweight and lightweight plastic carrier bags and certain other formats). Other packaging made from compostable materials must still be designed for recycling and labelled with the sorting label like any other packaging. Claim rules for "compostable" and "biodegradable" wording are covered in recyclable, compostable and biodegradable packaging.
What happens to national labels like Triman?
According to the Commission's guidance, Article 12 fully harmonises sorting labels, so Member States may not keep national sorting labels next to the EU label once it applies, and may not add new mandatory national packaging labels. Until then, national rules continue to apply in their own markets.
Two national systems matter most for buyers supplying several EU countries:
- France: the Triman logo with Info-tri sorting instructions is mandatory on household packaging placed on the French market, including e-commerce, under the AGEC anti-waste law and Decree 2021-835.
- Italy: environmental labelling of packaging under Legislative Decree 116/2020 has applied since 1 January 2023, requiring material identification and sorting information for packaging placed on the Italian market.
The Commission guidance says such national measures should be repealed before the EU label applies or adapted to allow a transition, and that national sorting instructions judged disproportionate should be repealed sooner. Until France and Italy change their rules, keep complying with them for those markets. Confirm current requirements with the French and Italian compliance schemes before each reprint.
Material codes and other marks
Commission Decision 97/129/EC, which sets the numbers and abbreviations used to identify packaging materials (for example "PAP" codes for paper and board), applies until 12 August 2028, and according to the Commission guidance the abbreviations will no longer be allowed after that date. Article 12(8) also bans labels and symbols likely to mislead consumers about sustainability or sorting where harmonised labelling exists. The guidance reads Article 12(9) as allowing marks that show participation in an EPR scheme only in digital form, which may affect legacy logos on pack; check with your compliance scheme. The SUP Directive "plastic in product" marking on PE-lined cups is a separate obligation that continues; see paper cup rules in Europe and the UK.
What should you plan in artwork now?
Reserve a consistent label zone on each item, keep regulatory marks in a separate artwork layer, and avoid locking long-running designs into large print runs just before the label applies. Exact label size is not yet known, so plan for flexibility rather than a fixed dimension.
Practical steps for printed packaging:
- Reserve space: a clear panel on a flat, visible face of each item (cup side panel, bag gusset or back, box side or base), away from folds, seams and glue areas. On cups, keep it clear of the seam and on the same face as the SUP marking.
- Build a flexible artwork system: put regulatory marks (sorting label, SUP marking, manufacturer and importer details, batch code, market-specific national marks) on a dedicated layer, so they can change without redesigning the brand artwork. Plate-change and file preparation are covered in our packaging artwork guide.
- Plan for composite items: windows, liners and handles may need component-level information, so keep the bill of materials accurate for each item.
- Add a data carrier position: a QR code is optional for the sorting label, required for reusable packaging and useful for manufacturer details where space is short. Keep it apart from marketing QR codes, because the Regulation requires labelling information not to be mixed with sales content.
- Check contrast and size: pictograms must be legible after printing on kraft or coloured board, so allow a light background patch if needed.
- Time reprints: for slow-moving items, align artwork changes with the expected label date and the three-year sell-off allowance in Article 12(12).
- Keep France and Italy separate until harmonisation: market-specific versions or multi-market panels may still be needed.
Specify the label zone and data carrier in your artwork brief and request for quotation; at 9 Packaging, print method and placement for each item are confirmed at quotation and artwork review.
Does the PPWR labelling apply in the UK?
No for Great Britain. The PPWR is EU law and does not apply in England, Scotland or Wales, where mandatory recyclability labelling has been removed from the EPR regulations pending further alignment and on-pack labels such as OPRL remain voluntary. Northern Ireland is different: under the Windsor Framework, the PPWR applies there in large part, so check labelling for packaging supplied to Northern Ireland. GB rules are covered in our UK packaging regulations guide.
Next step: add a label zone to your next artwork revision
List the items you will reprint before 2029, mark which markets each goes to (and whether France or Italy is among them), and agree a label zone and regulatory artwork layer for each. Check that recyclability changes you are planning, explained in our guide to PPWR recyclability grades, are made in the same revision so you only change plates once. To review artwork space on new or existing items, send your files and target markets through our contact page.