From 2028, there will be a harmonised labelling obligation for packaging in the European Union. Whether this applies to your packaging depends on the type of packaging you place on the market and on the precise implementation that the European Commission still needs to establish. For some packaging categories the direction is clear, for others it is not yet.
In short: the obligation initially affects packaging placed on the market for the first time after the entry into force date, not stock produced earlier. The Regulation sets out the main principles, but the exact design of the label, the categories for which it becomes mandatory and any transitional periods are worked out in implementing acts that have not all been published yet. Anyone seeking certainty now about the precise pictograms would be well advised to continue following the official text on EUR-Lex rather than building on assumptions.
What the label must show according to the Regulation
The harmonised labelling is intended to show two things: what the packaging is made of and how the packaging must be returned separately. This is a different purpose from the national sorting logos that have existed in some Member States for longer, such as the well-known recycling symbols on Dutch packaging. The EU obligation does not automatically come on top of this, but the relationship between the national and European system has not yet crystallised in every country.
Whether a label is mandatory per packaging unit, per material type or per product category is expected to differ depending on the implementing act. This makes it difficult now to make generic statements that apply to every packaging. What is established: the obligation applies at the level of the packaging you actually place on the market, not at the level of your enterprise as a whole.
Who this is relevant for
The labelling obligation in practice mainly affects parties classified as a manufacturer or filler: anyone who fills a package, has it filled or places it on the market in the EU for the first time. A wholesaler that sells ready-packaged products without changing the packaging usually falls into a different category under the Regulation's system than the party that originally assembled the packaging. Which role exactly applies to your business differs depending on the packaging type and the country in which you supply.
Because that role determination involves quite a few variables — the type of packaging, the country of destination, who fills the packaging — it is difficult in an article like this to make a statement that is correct for every reader. in a few questions see which role fits your situation provides an indication for this without you needing an account immediately.
What is probably not covered
The Regulation distinguishes between packaging that reaches the consumer and packaging that is used exclusively between businesses, such as transport packaging that is never seen by an end user. For the latter type, a lighter or different labelling obligation is more likely, although that too has not yet been confirmed in detail. Packaging that is reused within a closed deposit system may have its own regime, since that is already identifiable through other mechanisms.
It is therefore too early to conclude that every box, bag or bottle must bear a new pictogram from 2028 onwards. Some packaging that already complies with other labelling requirements, such as certain packaging for hazardous substances, may fall outside the new obligation. A definitive answer per packaging type will be provided in the later implementing acts, not in the main text of the regulation itself.
How you can prepare now
Although the exact label text has not yet been finalised, preparation begins earlier than 2028. Packaging design, printing and inventory planning typically have long lead times, and a change to the label often immediately affects the rest of the packaging. It therefore makes sense to map out now which packaging you supply, in which countries they are placed on the market and who in the supply chain qualifies as the manufacturer — this is precisely the information also needed for role determination and the packaging file.
Anyone wishing to keep track of this overview once the implementing acts are published would be best advised to link it to an ongoing file per packaging type rather than reconstructing it all at once later. In the knowledge base, organised by topic the status of calendar obligations is tracked once the Commission provides further clarity. The underlying structure of that file, including how changes are communicated to you, is explained on the page with the subscription options.
For the exact statutory text and the status of the implementing acts, the official publication on EUR-Lex remains the appropriate source; supervisory authorities and guidelines provide further clarification on specific points once available.
Would you like to know first whether this obligation applies to you, before you invest time in preparation? The free quick-scan provides an initial indication for this, and the frequently asked questions addresses the questions that other businesses have already raised on this topic.