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Labels

Which marking work is real, and which still waits for an act?

Material composition, sorting, recycled-content claims, digital carriers, and deposit marks are separate. A QR code is not automatic compliance.

Saved preset fields: operator_role, packaging_type, food_contact, material_category, reuse_context, market_date_category, eu_market

What this screen checks

Whether the planned mark is a physical label action, a digital action, or still dependent on an implementing act.

Who should use this screen

Packaging designers and marketplace sellers planning artwork before the harmonised pictogram exists.

Verified dates

Regulation (EU) 2025/40 applies from 2026-08-12. Article 5(5) restricts PFAS in food-contact packaging from 2026-08-12 at 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm including polymeric PFAS. Total fluorine above 50 mg/kg needs proof of PFAS or non-PFAS fluorine. Harmonised sorting marks start no earlier than 2028-08-12, or 24 months after the implementing act, whichever is later: dependent on implementing act. Reusable-packaging labels start no earlier than 2029-02-12, also dependent on implementing act. Recycled-content minimums and reuse percentages use 2030-01-01 or a later act, and are not collapsed into 2026-08-12.

Official sources

Regulation (EU) 2025/40, Commission Notice C/2026/3084, and the Commission packaging-waste pages on EUR-Lex and the Commission site. Unpublished implementing acts are not listed as adopted.

Limitations

Decision support only. This does not store supplier names, laboratory files, formulations, or a free-form legal narrative, and it does not issue a compliance certificate.

How to read the answers

Inputs

Say what you plan to print and whether a digital carrier is only a QR code.

Result

LABEL ACTIONS and DIGITAL ACTIONS describe the kind of work. PENDING IMPLEMENTING ACT means the specification is not encoded because the act is not published here. REVIEW REQUIRED includes a QR-only assumption.

Limits

Article 12(1) allows a QR code in addition to the harmonised label. It does not say the QR code replaces that label.

Limits

Does a QR code alone satisfy the sorting label?

No.

When is the earliest harmonised mark?

2028-08-12, or 24 months after the implementing act, whichever is later.

Is the recycled-content label mandatory?

If you mark the share, that mark depends on the act and on the Article 7 method.

What about reusable packaging labels?

No earlier than 2029-02-12, and also dependent on implementing act.