PPWR sorting label delayed to 2027: what your packaging must already show since 12 August 2026

2026-10-30 · IberTrust Global

On 26 October 2026 trade press reported that the European Commission has moved the implementing rules for the harmonised packaging sorting label under the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) to the second quarter of 2027, with a public consultation first.

Many sellers read this as “PPWR labelling is postponed”. Only one part is postponed. Other marking duties already apply.

What is delayed

• Article 12(1) PPWR: the harmonised, pictogram-based label showing material composition to help consumers sort waste.
• It applies from 12 August 2028 or 24 months after the implementing acts enter into force, whichever is later. With the implementing act now planned for 2027, the real date moves further back.
• Until the EU label applies, existing national sorting-label rules (for example France's Triman) are not automatically switched off. The Commission expects Member States to repeal or adapt them before the harmonised label applies.

What already applies since 12 August 2026

• Identification of the packaging: a type, batch or serial number or another element that allows it to be identified (Article 15).
• Manufacturer contact details: name, registered trade name or trademark, postal address (a single contact point) and, where available, electronic contact — on the packaging or via a QR code or other data carrier (Article 15).
• Importer details: when packaging comes from outside the EU, the importer must also indicate its own name, trade name or trademark, postal address and electronic contact (Article 18).
• Supplier documentation: packaging suppliers must give the manufacturer the information needed to demonstrate conformity (Article 16).
• Harmonised definitions of manufacturer and producer for EPR purposes.

Typical gaps we see with non-EU brands

• Cartons and bags printed in the factory with no EU contact point at all
• A QR code that leads to a generic shop page instead of the required contact information
• “Labels are postponed, so we changed nothing” — while the identification and contact duties are already in force
• Packaging EPR registration in the destination country (for Spain, under Royal Decree 1055/2022) still not done

What to do now

1. Check every packaging format for an identification number and the manufacturer / importer contact block.
2. Decide who is the EU importer or producer for each sales flow (marketplace, own website, B2B).
3. Keep national sorting labels where a country still requires them, and plan the switch to the EU label once the implementing act is published.
4. Confirm packaging EPR registration in each country where you place packaged products.

Need a packaging check?

IberTrust Global S.L. supports non-EU sellers with packaging EPR in Spain, authorised-representative services and EU contact-point requirements. Send us photos of your packaging and your sales channels — we will tell you what is missing.

Request a packaging compliance review →
Or email contact@ibertrust.info.

Sources: European Commission, “New EU rules on packaging set to enter into application” (11 August 2026); Regulation (EU) 2025/40 (PPWR), Articles 12, 15, 16 and 18 (EUR-Lex); Commission notice C(2026)3702 on the interpretation of PPWR; Packaging Insights, “EU delays PPWR labeling rules to Q2 2027, plans consultation” (26 October 2026). General information, not legal advice.