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The Packaging and Packaging Waste Regulation (PPWR) timeline includes several transition periods that overlap, and one distinction we hear about constantly from manufacturers and suppliers is the exact sunset date for current packaging labels. Specifically: material identification symbols, like the Mobius loop with material numbers, run on a different clock than the digital EPR identifier that is replacing physical EPR markings such as the Green Dot.
The two deadlines sit 18 months apart, which is exactly where the confusion starts. Here’s what the regulation says, with the article numbers and official sources behind each date.
Material Identification: You Have Until August 12, 2028
There has been significant discussion around whether traditional material identification symbols would be prohibited as early as February 2027. That’s not correct.
Commission Decision 97/129/EC, which set out the numbering and abbreviation system behind the Mobius loop back in 1997, remains valid under Article 70(2) of the PPWR (Regulation (EU) 2025/40) until 12 August 2028. The European Commission’s official guidance document for the PPWR, published via EUR-Lex, confirms this same date directly.
Worth noting: the original 1997 system was voluntary and applied inconsistently across member states. The PPWR converts it into a mandatory, harmonized system, which is part of why the Commission needs the runway to finalize the exact pictogram specifications.
- What this means: You can keep using traditional material identification symbols (Mobius loop plus material code) up to 12 August 2028.
- What comes next: A new, harmonized waste sorting labeling system replaces the legacy codes across all EU member states, once the Commission’s implementing act on the methodology is in place. The EU Joint Research Centre has published a technical proposal for these labels earlier this year.
- The catch: That implementing act was due by 12 August 2026, but the Commission has signaled it isn’t treating this one as a priority. Since the harmonized labeling requirement applies from 12 August 2028 or 24 months after the implementing act enters into force, whichever is later, the practical deadline could slide past 2028 if the act is delayed.
Physical EPR Markings: The Digital EPR Identifier Takes Over From February 12, 2027
While material identification gets the longer runway, physical markings for Extended Producer Responsibility (EPR), most notably the Green Dot (“Grüner Punkt”), face a much tighter deadline.
Under Article 12(9) of the PPWR, affixing physical EPR compliance symbols directly on packaging is banned as of 12 February 2027.
- The rule: Physical on-pack symbols indicating EPR compliance or scheme membership are no longer permitted on standard packaging from that date.
- The solution: Optional EPR information moves to a digital EPR identifier instead, delivered through a QR code or other standardized, open digital-marking technology, so it can indicate that the producer fulfills its extended producer responsibility obligations.
A practical implication worth planning around: a single QR code will likely end up carrying more than one layer of information over time (EPR proof now, material composition and sorting data later). It’s best to design the digital carrier with that long-term view in mind rather than issuing a new code for every requirement that lands. We’ve covered this unified approach for Article 15’s identification and contact-detail obligations, which apply from 2026 and are smart to address at the same time.
These dates apply to packaging placed on the EU market generally. Some categories, such as medical device packaging, sit under different labelling obligations elsewhere in Article 12, so it’s worth confirming your specific product’s exemptions before locking in an artwork timeline.
What You Should Do Now
| Focus Area | Current Practice | Deadline | Legal Basis | Action Required |
| EPR Markings (e.g., Green Dot) | Physical affixing on packaging | 12 February 2027 | Article 12(9), PPWR | Audit artwork and prepare to transition to a digital EPR identifier (QR code). |
| Material Identification | Mobius loop + material code | 12 August 2028 (or later, if the implementing act is delayed) | Article 70(2), PPWR; Commission Decision 97/129/EC | Plan an artwork update roadmap for the upcoming harmonized EU labeling standard. |
Frequently Asked Questions
Can I still add the Mobius loop and material code after 2027?
Yes. Material identification symbols under Commission Decision 97/129/EC remain valid until 12 August 2028, per Article 70(2) of the PPWR. The February 2027 deadline applies only to physical EPR markings, not to material identification.
What replaces the Green Dot after February 2027?
A digital EPR identifier. Article 12(9) of the PPWR requires this information to move from a printed symbol to a QR code or other standardized, open digital-marking technology.
Can the same piece of packaging carry both markings at once?
Yes. A single pack can carry a material identification symbol (valid until August 2028) alongside a digital EPR identifier (required from February 2027), since the two serve different purposes under different articles of the PPWR.
Is the August 2028 date guaranteed?
Not entirely. The 2028 date is tied to the Commission’s implementing act on harmonized labeling. If that act is finalized late, the 24-month countdown only starts once it enters into force, which could push the practical deadline beyond August 2028.
How PAQR Helps
Managing these overlapping deadlines across a large SKU portfolio depends on clean, structured packaging data. PAQR helps manufacturers and suppliers track material compositions and manage digital labeling requirements in one place, so a QR code rollout or an artwork update doesn’t turn into a last-minute print re-run.
Click “Try now for free” on paqr.com to start a free trial:
