No new mandatory label in 2026 — but three rules already apply
The harmonised label under Article 12(1) becomes mandatory from 12 August 2028 — or 24 months from the entry into force of the related implementing acts, whichever is the latest. The reuse label under Article 12(2) follows from 12 February 2029 at the earliest. One sub-obligation carries no date of its own: the marking of packaging covered by deposit and return systems. Anyone selling you a new mandatory pictogram for 12 August 2026 is misreading the regulation.
Three things do apply from 2026. First, the prohibition on misleading labels: economic operators must not provide or display labels, marks, symbols or inscriptions that are likely to mislead or confuse consumers or other end users about sustainability requirements, other packaging characteristics or the waste management options for which the regulation lays down harmonised labelling (Article 12(8)). Second, the identification and address duties from Chapter IV: a type, batch or serial number plus the manufacturer's name and postal address — for imports, also the importer's details (Articles 15(5), 15(6), 18(3)). These are operator obligations, not Article 12 labels, but they bind from 12 August 2026. Third, rules on environmental claims about packaging characteristics regulated by the PPWR: such claims are only permitted where they go beyond the regulation's minimum requirements and make clear what exactly they refer to (Article 14).
From 12 August 2028: the harmonised sorting label
From that date, packaging placed on the market must be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting. The label is based on pictograms and must be easily understandable, including for persons with disabilities (Article 12(1)).
The exceptions matter: with the exception of e-commerce packaging, the obligation does not apply to transport packaging or to packaging subject to a deposit and return system. The shipping box sent to an end customer therefore needs the label; the industrial pallet does not. Compostable packaging carries additional information — that the material is compostable, that it is not suitable for home composting and that it must not be discarded in nature.
What the pictograms look like is set by implementing acts the Commission must adopt by 12 August 2026 — which is also why the start date can shift. In addition, operators may voluntarily add a QR code or other standardised open digital data carrier with information on the destination of each separate packaging component.
From 12 February 2029: reuse labels and QR codes
Reusable packaging placed on the market from 12 February 2029 — or 30 months from entry into force of the relevant implementing act, whichever is the latest — must bear a label informing users that the packaging is reusable. Further information, including the availability of a local, national or Union-wide re-use system and collection points, is made available through a QR code or another standardised, open digital data carrier that also facilitates tracking and the calculation of trips and rotations (Article 12(2)).
There is also a point-of-sale rule: reusable sales packaging must be clearly identified and distinguished from single-use packaging where it is sold. Open-loop systems operating without a system operator within the meaning of Annex VI are exempt from the reuse label and QR code obligation.
Recycled content and bio-based claims: voluntary, but regulated
Article 12 contains no obligation to print the recycled content on packaging. Paragraph 4 governs the voluntary case: where packaging within the scope of Article 7 carries a label with information on recycled content, that label must — from the same default start date (12 August 2028, or 24 months after the paragraph-6 implementing act, whichever is the latest) — follow the specifications of the implementing act and rest on the calculation methodology of Article 7(8). Bio-based plastic content claims are regulated the same way, though tied only to the implementing-act specifications.
Two special rules complete the picture: from 12 February 2027, a label indicating that the producer fulfils its extended-producer-responsibility obligations may only be displayed digitally, as a corresponding symbol in a QR code or other standardised, open, digital-marking technology (Article 12(9)). And environmental claims about packaging characteristics regulated by the PPWR remain subject to Article 14 from 2026.
Placement, online sales and language
For the labels under paragraphs 1, 2 and 4, the rule is: clearly visible, easily legible and firmly affixed, printed or engraved so they cannot easily be removed (Article 12(5)).
Online retailers should note: the information contained in the labels must be available to end users before the purchase in online sales. And as with the declaration of conformity, the member state of sale determines the language or languages of the labelling.
Sell-through periods and a practical roadmap
The regulation softens the transition: packaging manufactured in the Union or imported before the respective deadlines that does not carry the new labels may still be made available on the market for up to three years from the date the labelling requirements take effect (Article 12(12)). Stock manufactured in the Union or imported before the deadline does not have to be destroyed — packaging manufactured or imported after it needs the new label from day one.
The sensible roadmap: in 2026, complete the obligations that are actually due — the EU declaration of conformity, the technical documentation and the identification details — and check existing artwork against the misleading-labels prohibition. Plan the label change once the implementing acts with the concrete pictograms are published. The wider 2026 picture is covered in our PPWR compliance guide.