The PPWR Harmonised Packaging Label: One EU Mark Instead of 27

Sell the same product into five EU countries today and you probably print five different back panels. France wants Triman plus an Info-Tri sorting block. Italy wants the environmental labelling required under its national decree, with material codes per component. Some retailers still expect a Green Dot. Same cardboard box, same PET bottle, five artwork variants, five approval cycles.

The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, applicable from 12 August 2026 — is supposed to end that. Article 12 creates a single pictogram-based label that every pack on the EU market carries; Article 13 puts a matching label on the bins. One artwork, 27 countries.

The catch is that the pictograms do not exist yet. This post separates what the Regulation locks down from what is still waiting on the European Commission, so you can make decisions at your next artwork cycle instead of guessing.

The 30-second answer

• What it is: a harmonised, pictogram-based label carrying the packaging's material composition, so consumers can sort it. Article 12(1) of Regulation (EU) 2025/40.
• When: 12 August 2028 or 24 months from the entry into force of the Commission implementing acts, whichever is the latest. The acts were due by 12 August 2026 and had not been adopted when this was written, so plan for a date later than 2028.
• What is not settled: the pictograms, colours, formats, placement rules and the method for identifying material composition — all in the pending Article 12(6) and 12(7) acts.
• National marks: Triman, Info-Tri and the Italian environmental label are still legally required in their own markets. They are superseded once the harmonised label applies, not before.
• Out of scope: transport packaging and deposit-and-return packaging — but not e-commerce packaging, which is in scope.
• Old stock: Article 12(12) allows packaging made or imported before the deadline to be sold through for up to 3 years.

What the harmonised label actually is

Article 12(1) is worth reading literally. Packaging placed on the market must be marked with a harmonised label containing information on its material composition, to facilitate consumer sorting. It must be based on pictograms and easily understandable, including for people with disabilities. Compostable packaging must additionally indicate that it is compostable, not suitable for home composting, and not to be discarded in nature.

Two things follow. First, this is a material label, not a recyclability grade — it says what the pack is made of and therefore where it goes. Recyclability performance is a separate regime under Article 6; see recyclability grades under PPWR. Second, being pictogram-based, it is meant to work without translation, which is what makes one artwork viable across 27 markets.

Article 12(5) sets the physical rules that are already fixed. The label must be affixed, printed or engraved visibly, legibly and firmly so it cannot easily be erased, and the same information must be available to end users before purchase in online sales — which means the label content belongs on your product detail page, not just on the box. If the size or nature of the packaging makes on-pack marking impossible, the label moves to the grouped packaging, and only failing that to an electronically readable carrier.

What is still pending — and why it matters to your calendar

Article 12(6) required the Commission to adopt, by 12 August 2026, implementing acts establishing the harmonised label and the specifications for labelling requirements and formats; Article 12(7) required, by the same date, a methodology for identifying material composition using standardised, open digital-marking technologies.

At the time of writing, that work is not finished. The Commission's Joint Research Centre published a technical proposal on EU harmonised waste sorting labels on 13 January 2026 — a non-binding evidence base for DG Environment covering pictogram design, colour coding, minimal text and a consistent visual link between pack and receptacle. That is an input to the act, not the act itself. Trade commentary through mid-2026 pointed to a draft after the summer, then Waste Expert Group discussion and consultation.

The consequence is a moving deadline. Because Article 12(1) reads "12 August 2028 or 24 months from the date of entry into force of the implementing acts, whichever is the latest", every month the act slips pushes your label date out by a month. Act in late 2026, label in late 2028. Act in 2027, label in 2029. Anyone giving you a firm date today is guessing.

The rest of the Article 12 timeline

• 12 August 2026: the Regulation itself applies (Article 71). No harmonised label obligation yet.
• 12 February 2027: the date attached to Article 12(9) on identifying packaging covered by an EPR scheme. Such identification "shall be achieved only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology".
• 12 August 2028 (or IA + 24 months): the harmonised material-composition label, plus format rules for any recycled-content or biobased-content claim you print (Article 12(4)).
• 12 February 2029 (or IA + 30 months): reusable packaging must bear a "reusable" label, and here a digital data carrier is mandatory — carrying re-use system and collection-point information and supporting the count of trips and rotations (Article 12(2)). Open-loop systems without a system operator are exempt (Article 12(3)).

Note the asymmetry that trips people up: the sorting QR under Article 12(1) is permissive. The mandatory digital carriers sit elsewhere — reusable packaging, substances of concern, and EPR-scheme identification. For the digital layer, see our guide to the PPWR digital carrier.

What happens to Triman, the CONAI marks and the Green Dot

This is where most vendor content overstates the position, so here is the careful version.

France — Triman and Info-Tri. Still mandatory. Nothing in PPWR switched them off on 12 August 2026, and you should keep printing them for the French market. Two separate forces will eventually retire them. First, Article 4(2) says Member States shall not prohibit, restrict or impede the placing on the market of packaging that complies with the labelling requirements of Articles 5 to 12 — so once the harmonised label applies, France cannot reject a compliant pack for missing a national mark (Article 4(3) allows additional national information requirements only where they do not conflict and are not used to block compliant packaging). Second, the European Commission referred France to the Court of Justice of the EU in July 2025 over mandatory Triman signage, arguing it restricts free movement of goods under Article 34 TFEU and was not properly notified. That case is pending; until it is decided, Triman applies.

Italy — the environmental labelling regime. Same pattern. The obligation rooted in Legislative Decree 152/2006 and its implementing decree continues to apply, with CONAI-published guidelines for material codes and sorting indications. CONAI's own PPWR communications frame the Italian format as running until the harmonised EU label takes over, not as already superseded.

The Green Dot. Different animal — it has never been an EU marking requirement, only a licensed trademark showing participation in a compliance scheme. Article 12(9) closes it off by allowing EPR-scheme identification only through a symbol carried in a QR code or equivalent digital marking, with the date 12 February 2027 attached. Scheme operators have already moved: Der Grüne Punkt launched a digital successor, and Fost Plus announced it is discontinuing its PRO EUROPE licence arrangement. If the Green Dot is still on your artwork out of habit, it is the easiest thing here to delete.

The bin half of the system: Article 13

A label on the pack is only useful if it matches the label on the bin. Article 13 puts that obligation on Member States, not producers: harmonised labels for each material fraction must be affixed, printed or engraved visibly, legibly and indelibly on packaging-waste receptacles, by 12 August 2028 or 30 months from adoption of the implementing acts, whichever is the latest. Deposit-and-return receptacles are excluded. Crucially, Article 13(2) requires the receptacle labelling to correspond to the packaging labelling — the pictogram you eventually print is one half of a matched pair. It is also why the JRC spent so much attention on colour coding: several national collection systems have entrenched colour conventions, and reconciling them is the hard part of the act.

What to do during your next artwork cycle

Most SKUs run a 12–24 month artwork cycle. If you are opening files in the next year, here is what is worth doing and what is not.

1. Reserve the space, do not draw the label. Leave a clean, unbranded rectangle on the back panel sized for a sorting block. You cannot design the pictograms — they do not exist. You can make sure that when they arrive, the change is a placement swap rather than a full panel relayout.
2. Keep printing today's national marks. Triman, Info-Tri and the Italian environmental label are live obligations. Do not pre-emptively remove them because a harmonised label is coming.
3. Delete anything you cannot justify. A Green Dot without a current licence, decorative Mobius loops on non-recyclable laminates, vague "eco" claims. Article 12(8) prohibits marks likely to mislead consumers about characteristics for which harmonised labelling is laid down, and Article 14 restricts environmental claims to properties exceeding the Regulation's minimums. Both are in force now, unlike the pictograms.
4. Get component-level material data straight. If your records say "box + bottle" rather than "kraft carton 24 g, PET body 18 g, PP closure 2 g, paper label 0.4 g", you will not be able to derive a label mechanically when the spec lands. It is the same BOM you need for EPR declarations — see our packaging BOM guide.
5. Fix your online product pages. Article 12(5) requires the label information to reach end users before purchase in distance sales — a CMS job with a long lead time, independent of the pictogram design.
6. Plan print runs against the sell-through window. Article 12(12) gives 3 years to sell packaging made or imported before the deadline, but you need the manufacture or import date documented to rely on it.
7. Do not commission bespoke pictogram artwork. Any agency selling "PPWR-ready" sorting icons today is selling you a guess.

Common misconceptions

• "The harmonised label applies from 12 August 2026" — No. That is when the Regulation as a whole starts to apply. The label obligation is 12 August 2028 at the earliest, later if the implementing acts slip.
• "Triman is dead, we can drop it" — Not yet. It remains a French requirement, and the CJEU case is pending rather than decided. Dropping it now creates real exposure in a major market.
• "The label tells consumers whether the pack is recyclable" — It carries material composition to support sorting. Recyclability performance is assessed under Article 6, on a separate track.
• "It replaces my EPR registrations" — No. You still register and declare per country. See PPWR vs EPR.
• "My shipper box is out of scope" — Article 12(1) excludes transport and deposit-return packaging, but explicitly not e-commerce packaging. If you ship D2C, the mailer is in scope.
• "Small producers are exempt" — There is no SME carve-out from Article 12. Volume thresholds exist in national EPR schemes, not in PPWR marking.

How Pack Declare helps

Pack Declare is built for e-commerce SMBs selling into several EU markets — self-serve, transparent pricing, no enterprise sales cycle. For labelling specifically:

• Your component-level packaging BOM already stores the per-SKU material breakdown a material-composition label is derived from — the data work is done before the pictograms are published.
• The Recycling Icons Library is a free reference for what you can legitimately print today: public-domain marks (Mobius loop, Tidyman, resin identification codes) as SVG or PNG, plus official source links for the trademarked national marks. We do not redraw trademarked artwork, and we do not invent PPWR pictograms.
• The QR Generator is a free, no-signup tool producing a scannable code that resolves to country-specific disposal guidance — useful for the optional Article 12(1) carrier and as a rehearsal for the mandatory reusable-packaging one.

Bottom line

The harmonised label is the biggest simplification in PPWR for anyone selling across borders: one panel instead of one per market, matched to the bin the consumer is standing in front of. But it is not a 2026 project, and the date depends on a Commission act that has not been adopted. Keep complying with the national marks you already owe, strip anything unjustifiable from your artwork, get component-level material data into a system, and leave room on the panel — so the eventual change is a swap, not a redesign.

Run the 2-minute Pack Declare Readiness Check →

Frequently asked questions

When does the harmonised label become mandatory?

12 August 2028, or 24 months from entry into force of the implementing acts under Article 12(6) or 12(7), whichever is the latest. Those acts were due by 12 August 2026 and were not adopted at the time of writing, so the effective date will most likely fall later.

Must I remove Triman and Info-Tri in France?

Not today — they remain a French legal requirement. The Commission referred France to the CJEU in July 2025 over mandatory Triman signage on free-movement grounds; that case is pending.

Does this mean a QR code on every pack?

No. Article 12(1) is a printed pictogram label; the component-destination QR in the same article is something operators may add. Digital carriers are mandatory only for reusable packaging (Article 12(2)) and packaging containing substances of concern.

Can I sell through stock printed with the old marks?

Yes, within limits. Article 12(12) allows packaging manufactured in the EU or imported before the deadline to be made available for up to 3 years from the date the labelling requirements enter into force.

What happens to the Green Dot?

Article 12(9) allows EPR-scheme identification only through a symbol carried in a QR code or equivalent digital marking, with 12 February 2027 attached. Scheme operators read this as ending the printed Green Dot in that role and have launched digital successors.

Who labels the recycling bins?

Member States, under Article 13, by 12 August 2028 or 30 months from adoption of the implementing acts, whichever is the latest. The receptacle labelling must correspond to the packaging labelling.

Related reading: the PPWR digital carrier and QR codes · Recyclability grades under PPWR · What is the PPWR?