Two things were supposed to happen on 12 August 2026. One did: the packaging regulation — the PPWR — became applicable. The other did not. On that same day the Commission was required to adopt the implementing acts that define what the packaging label looks like and what data goes into the digital marking. They did not appear. That is not a problem — in fact, if you read the regulation carefully, it is good news.
What the deadline was
It was not a target date but an obligation, in Article 12(6):
"By 12 August 2026, the Commission shall adopt implementing acts to establish a harmonised label and specifications for the labelling requirements and formats, including where provided through digital means, for the labelling of packaging referred to in paragraphs 1, 2 and 4 of this Article."
Regulation (EU) 2025/40, Article 12(6) — official English text
The same day was also the deadline under paragraph 7, for the methodology on digitally marking material composition.
What happened instead
The draft is expected after the summer. It then goes to the Waste Expert Group and a public consultation — packaging industry bodies put realistic adoption in the fourth quarter of 2026. At the time of writing, a week past the deadline, no act has been published.
Note what this does not mean: the regulation itself has not slipped. It applies from 12 August 2026, as Article 71 says. What slips is the labelling — and it slips in a rather interesting way.
The sentence that makes this good news
The first sentence of Article 12(1) does not give a date. It gives a formula:
"From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7 of this Article, whichever is the latest, packaging placed on the market shall be marked with a harmonised label containing information on its material composition…"
Regulation (EU) 2025/40, Article 12(1) — official English text
Read the highlighted part again. The deadline is the later of the two dates. And here is the point: the implementing act can now only enter into force after 12 August 2026, because that date has already been missed. Add 24 months to anything after that, and you always land later than 12 August 2028.
In other words: the 12 August 2028 deadline is already dead. Not "may slip" — it mathematically can no longer be the operative date. What applies instead is entry into force plus 24 months, and that day moves day for day until the act appears.
| If the implementing act enters into force… | …the labelling obligation starts |
|---|---|
| December 2026 | December 2028 |
| March 2027 | March 2029 |
| September 2027 | September 2029 |
And it is not only the material-composition label. The label and mandatory QR code for reusable packaging under paragraph 2 apply "from 12 February 2029 or 30 months from the date of entry into force of the implementing act, whichever is the latest" — the same structure. So does the recycled-content label in paragraph 4. The whole labelling block of Article 12 is anchored to the same missing act, and moves with it.
What does not slip
Four things stay where they are, and should not be confused with the above.
- The regulation itself. Applicable from 12 August 2026, directly in all 27 Member States (Article 71).
- EPR identification. The 12 February 2027 date in Article 12(9) is not tied to the implementing act — and it states that extended producer responsibility marking may be done only by QR code or other standardised, open digital marking.
- The single-data-carrier rule. Under the last sentence of Article 12(5), where Union law requires a data carrier for the packaged product, a single carrier must serve both the product and the packaging. Its content does not depend on the implementing act, so you can design for it today. More on that: one QR on the box.
- Supplier data. You still have to collect the material composition, whatever shape the label ends up taking. That is the work that outlasts every deadline here.
The lesson that goes beyond packaging
"Whichever is the latest" is not a PPWR quirk — EU product law is full of it. Which yields a very practical rule: a date in a compliance calendar is not necessarily a deadline.
There are two kinds of date. One is anchored to the calendar: it holds no matter what. The other is anchored to a legal act that may not even exist yet — and it keeps moving until that act appears. When someone shows you a timeline, your first question should be which kind you are looking at. The same distinction matters for the ESPR: see the ESPR and DPP deadlines overview.
This article is information, not legal advice, and it describes a moving situation. The state described here is as of 19 August 2026. Once the implementing acts are published, the calculation above can be replaced with concrete dates — the formula stays.
What to do now
Do not invent packaging data fields. This is even truer than it was two weeks ago: not only is the field list missing, the timing of its arrival is uncertain too. Anyone adding twenty fields on a guess now will likely rebuild twice.
What is worth doing: ask your packaging supplier what material-composition data they can provide, and in what format — that data will be the same whatever shape the label takes. Design for one QR code, not two. And watch the acts under Article 12(6) and (7): that is the only event after which it makes sense to touch your data model.
How does Veridyn help?
Two weeks ago we wrote that we would not add packaging fields until the implementing acts appeared. Since then the deadline has passed, the acts have not appeared — and we still have not added anything. That is not inactivity but the same decision: we do not build without a specification, because wrong data ends up behind printed QR codes, and getting it out from there is expensive.
What we do in the meantime is watch for the acts. When they land, the schema grows while your existing passports and the QR codes printed on them keep working unchanged — that is what the article on QR codes and GS1 Digital Link is about.
See it live, or start for free — the first passport takes minutes.