When must I use the new packaging label?

The new label applies from 2028; the precise form is yet to be determined

The harmonised packaging label becomes mandatory from 2028, but the exact model is not yet established. Article 12 of Regulation (EU) 2025/40 requires labelling of packaging — including information on material composition and collection options — but the precise design, symbols and technical specifications of that label are still being developed. Until that development is published, it is not possible to determine exactly what the label will look like or which pictogram must be placed where.

What is already established is that the underlying obligations from the PPWR apply regardless of this label. The name and postal address of the responsible party must already appear on or with the packaging, and the EU declaration of conformity according to Annex VIII with accompanying technical documentation is already part of the packaging file. The new label will be added on top of this in 2028, as a separate, harmonised way to inform consumers about recycling and collection. If you are building a packaging file now, you are building something that will be supplemented by the label later, not replaced.

Where this follows from Article 12

Article 12 of Regulation (EU) 2025/40 establishes the obligation to label packaging and refers for the development of the exact format to further legislation to be adopted by the European Commission. As long as that development has not been published, the form of the label — colours, symbols, placement — remains undetermined, whilst the obligation itself and the year 2028 flow from the regulation itself. For the exact content of the label, the text of Article 12 itself and announcements from the Commission are the appropriate sources to follow.