EU Delays Packaging Labelling Rules

27-Oct-26

European Commission pushes harmonised PPWR packaging labels to Q2 2027

The European Commission has delayed the adoption of detailed rules for harmonised packaging labels under the European Union's Packaging and Packaging Waste Regulation (PPWR), moving the expected implementing act to the second quarter of 2027.

The Commission has also confirmed that it will conduct a public consultation before finalising the rules.

For packaging producers, the delay provides some additional breathing space. It should not, however, be interpreted as a relaxation of the PPWR. The direction of travel remains clear: packaging placed on the EU market will face increasingly prescriptive requirements relating to recyclability, recycled content, reuse and consumer information.

What is changing?

The forthcoming implementing rules will establish harmonised labels for packaging and waste receptacles across the EU.

The labels are intended to help consumers:

  • identify the material composition of packaging;
  • sort packaging correctly;
  • identify reusable packaging;
  • recognise packaging covered by deposit-return systems; and
  • identify recycled and bio-based content.

The European Commission's objective is to replace potentially different national approaches with a common EU-wide system. The Commission has indicated that the harmonised labelling system is expected to apply from 2028, subject to the final implementation timetable.

The Joint Research Centre has already proposed a material-based, pictogram-oriented approach to packaging and waste-sorting labels. However, the final specifications have not yet been adopted.

What does the delay mean for packaging manufacturers?

The original implementing act had been expected in August 2026. Its postponement means producers do not yet have to redesign packaging artwork around specifications that could subsequently change.

Once the implementing act is adopted, producers will have approximately two years to ensure their packaging carries the required labels. Industry organisations have warned that this could become particularly challenging for companies with large numbers of SKUs, packaging formats and customers.

For a packaging producer, changing a label is not simply a graphic-design exercise.

A change may require:

packaging composition review → recyclability assessment → artwork modification → customer approval → cylinder/plate or printing changes → inventory management → production transition → market implementation.

For companies supplying multinational customers, the process can be even more complex because the same packaging design may be used across several European markets.

The bigger issue is packaging design

The labelling requirement is only one part of the PPWR.

The regulation is progressively introducing requirements aimed at reducing packaging waste, increasing recyclability, promoting recycled materials and encouraging reuse. The European Commission states that requirements concerning recyclable packaging and recycled plastic content will become particularly important from 2030.

For packaging manufacturers, this means that label compliance should not be considered in isolation.

Companies should simultaneously examine:

  • mono-material versus multi-material structures;
  • use of recycled polymers;
  • barrier properties and their impact on recyclability;
  • adhesives, inks and coatings;
  • closures and other components;
  • recycled-content traceability;
  • packaging weight and material reduction;
  • compatibility with European recycling systems; and
  • documentation required by customers and regulators.

In other words, the PPWR is increasingly influencing the design of the package itself, not merely what is printed on it.

 

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