Regulation (EU) 2025/40
For packaging and sustainability teams selling in the EU working out what PPWR means for design, labels and recyclability claims. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, sets EU rules for packaging design, recyclability and labeling. Its Article 12 brings a harmonized material composition label to help consumers sort packaging.1
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the labeling requirements the PPWR describes, according to its text and Commission guidance, and where each one applies.1,2
| Requirement | Where it applies |
|---|---|
| Harmonized sorting label | Packaging placed on the market: a label on its material composition to help consumers sort it, from August 12, 2028 at the earliest. |
| Label design | Based on pictograms and easily understandable, including for persons with disabilities. |
| Reusable packaging | A label telling users the packaging is reusable, with a QR code or other data carrier. |
| Manufacturer and identification details | Manufacturers: name and contact details and an element identifying the packaging, from August 12, 2026. |
| Misleading labels and symbols | Economic operators: none likely to mislead or confuse consumers about sustainability requirements or end-of-life options. |
| National sorting labels | Commission guidance: labeling is fully harmonized, so no national sorting labels next to the EU label once it applies. |
| Waste receptacles | Bins and containers: matching labels so consumers can sort packaging waste. |
Where it goes wrong
One approved set of product information ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up without the warnings or details these rules require.
Crispbread tray: material composition and sorting pictogram
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
Everywhere the pack is shown. The PPWR describes the harmonized label on the packaging itself,1 but once it is printed, pack shots and artwork carry it into:
Treat the sorting label as one approved element with one owner and one source file, and list every artwork, pack shot and listing that will carry it. The design is set by the Commission's implementing acts,1,2 so when they arrive you change it once and check what's live against it. Old national sorting logos are where we expect drift. Our packaging and labels page shows how teams track this.
Check every symbol and claim about recycling or sorting, on packs and in pack shots, against what you've approved. The PPWR text describes no labels or symbols likely to mislead or confuse consumers about end-of-life options,1 and other EU rules cover green claims; see our page on generic environmental claims.
How it applies to a specific claim is a question for your legal adviser. Where that claim appears across your markets and languages is a question Arbitr answers.
Packaging and sustainability teams usually own it, but the label reaches design agencies, e-commerce, marketing and translation teams, and retailers using your pack shots. Each needs to know which version is current. Other product information rules are on our product labeling hub, and UK marking rules on our UKCA marking page.
Not the harmonized label. The regulation applies from August 12, 2026, but Article 12 sets the label date at August 12, 2028, or 24 months after the Commission's implementing acts enter into force, whichever is later.1,2 Packaging Europe reported in August 2026 that those acts had not yet been adopted.3
It replaces it. According to its text, Regulation (EU) 2025/40 repeals Directive 94/62/EC, with effect from August 12, 2026 for most of its provisions, and as a regulation it applies directly in every member state.1
On February 11, 2025, according to the text of Regulation (EU) 2025/40, which was published in the Official Journal on January 22, 2025. It applies from August 12, 2026, with later dates for labeling and several other requirements.1
Yes. Each language version is checked against the approved original and your rules for that market. Where you want a person to look, it goes to your own reviewers or to one of Arbitr's experts.
