Packaging Labels Are Changing - PPWR, SB 343 & the Green Dot

If you sell a physical product, your packaging is part of your compliance story — and in 2026 it's changing faster than at any time in the last 30 years. The EU's new packaging regulation is now in force, California's restrictions on the recycling symbol are taking effect, and the familiar Green Dot is on its way out.

In this article, we'll walk through all three: what each one requires, the key dates, and what you should be doing now so your packaging doesn't become the reason a shipment gets held up.

1. EU PPWR: The New Packaging Rulebook

The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) entered into force on 11 February 2025 and has applied since 12 August 2026. It replaces the 1994 Packaging Directive. Because it's a regulation rather than a directive, it applies directly and identically in all 27 member states — no more waiting to see how each country transposes it.

Who does it apply to?

Pretty much everyone in the chain: manufacturers, importers, distributors, fulfilment service providers and e-commerce sellers. It applies regardless of where you're based. If you're a US company shipping packaged products into the EU, you're in scope, and you may need an authorised representative in the EU for your producer obligations.

What applies now vs. later

A lot of people read "August 2026" and assume everything kicked in at once. It didn't. The 2026 date is mostly about documentation and substance limits; the big design requirements arrive in 2028 and 2030.

Date	What applies
12 Aug 2026	General application: EU Declaration of Conformity and technical documentation for packaging, PFAS limits in food-contact packaging, heavy-metal limits
12 Aug 2028 (or later)	Harmonized EU sorting label showing material composition — 24 months after the Commission's implementing act, if that comes later
1 Jan 2030	Packaging must be designed for recycling; minimum recycled content for plastic parts; weight/volume minimization; max 50% empty space for grouped, transport and e-commerce packaging; certain single-use formats banned
1 Jan 2035	Packaging must be recyclable "at scale" through real collection and sorting infrastructure
1 Jan 2038	Packaging must reach recyclability grade A or B
1 Jan 2040	Higher recycled-content thresholds for plastic

One piece of good news: packaging already produced or in stock before 12 August 2026 doesn't have to be destroyed or relabelled, according to the Commission's FAQs.

The labelling piece

For most product companies, the label is where PPWR will be most visible. The harmonized label is pictogram-based and will match symbols on waste bins across the EU, replacing today's patchwork of national sorting labels (France's Triman and Info-tri, Italy's proposed environmental labelling, and so on). The exact design hasn't been finalized yet — the Commission still has to adopt the implementing act — so plan for an artwork update in 2027–2028.

PPWR also leans heavily on data carriers (QR codes) to carry information that doesn't fit on the pack. That becomes important when we get to the Green Dot below.

What to do now

• Map your role (manufacturer, importer, distributor) for each market — it drives your obligations.

• Make sure you have a Declaration of Conformity and technical file for packaging you place on the EU market.

• Get material and substance data from your packaging suppliers, especially for food-contact items.

• Register for EPR in each country you sell into, or appoint a representative who can.

• Start designing for 2030 now: mono-materials, less void space, recycled content in plastics.

  
  

2. California SB 343: "Truth in Recycling" (Now on Hold)

SB 343 was supposed to take effect on 4 October 2026 — but a federal court blocked enforcement in July. Here's what the law says, what happened, and why you shouldn't throw your plan away.

What the law requires

SB 343, signed in 2021, treats the chasing arrows symbol as a claim that something is recyclable. Products and packaging sold in California can only carry the chasing arrows, the word "recyclable," or recycling instructions if the material is actually collected and recycled in practice. The core test is often called the "60/60" rule: programs serving at least 60% of Californians have to collect the material, and it has to be sorted into a stream that gets recycled.

A few practical details catch people out:

• Resin codes: The resin number (1–7) can't sit inside the chasing arrows unless the material qualifies. Many brands have switched to the solid-triangle resin code (ASTM D7611) instead.

• Manufacture date, not sale date: The restriction applies to products manufactured after the compliance date, even if they sit in a warehouse for months.

• Recordkeeping: Anyone making a recyclability claim has to keep documentation supporting it.

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The clock started when CalRecycle published its Material Characterization Study final findings in April 2025, which set the 18-month deadline of 4 October 2026.

The injunction

In March 2026, a coalition of packaging trade groups (including the Flexible Packaging Association and the American Forest & Paper Association) sued, arguing the law restricts truthful commercial speech and is too vague to follow. In mid-July 2026, the US District Court for the Southern District of California granted a preliminary injunction in California League of Food Producers v. Bonta. It bars the Attorney General from enforcing SB 343 until further order of the court.

The judge found the plaintiffs were likely to win on both First Amendment and vagueness grounds, and criticised the CalRecycle study for not giving producers usable guidance. That's a strong signal — but it's still a preliminary ruling. The case continues, and an appeal to the Ninth Circuit is widely expected.

Why you shouldn't relax completely

• The law could come back. An appeal or a final ruling could reinstate it, possibly with little notice.

• Private lawsuits haven't gone away. Consumer class actions over "recyclable" claims are brought under California's general false-advertising and unfair-competition laws, and those don't depend on SB 343.

• Retailers may still ask. Some large retailers had already started requiring SB 343 documentation as a condition of listing.

• SB 54 depends on the same definitions. California's packaging EPR law relies on the same recyclability criteria, so the question of what counts as "recyclable" in California isn't going away.

  
  

What to do now

• Inventory every SKU that shows the chasing arrows, a resin code inside arrows, or the word "recyclable."

• Check each material against the CalRecycle findings so you know your exposure if the law returns.

• Where you keep a claim, make sure it's substantiated and qualified (e.g. "check locally"), and keep the paperwork.

• If you were mid-redesign, consider finishing it — especially moving resin codes to the solid triangle, which is low-risk either way.

  
  

3. The Green Dot: From Printed Logo to QR Code

If your packaging carries the Green Dot, you have until 12 February 2027 to take it off. After that date, PPWR only allows EPR symbols like the Green Dot to appear in digital form — inside a QR code or similar data carrier.

What the Green Dot actually means

The Green Dot (Der Grüne Punkt) started in Germany in 1990. Despite the green arrows, it has never meant "this is recyclable." It means the producer has paid into a packaging take-back (EPR) scheme. It's a licensed trademark, managed across Europe through PRO Europe and national licensees, which is one reason it's been a headache for companies selling into many countries.

What PPWR changes

Article 12(9) of PPWR says that where packaging is identified as being part of an EPR scheme, that identification can only be done through a symbol in a QR code or another standardized, open digital-marking technology. In plain terms:

• Printed Green Dot on pack: not allowed from 12 February 2027.

• Showing EPR participation at all: still optional. You don't have to identify it.

• If you want to show it: it has to live in a digital marker, not as a printed logo.

This is separate from the harmonized sorting label coming in 2028. The Green Dot deadline arrives first, so it's the change most likely to catch you mid-reprint.

What replaces it

There are two main routes:

• DigiDot: PRO Europe's QR code with the Green Dot embedded. Scanning it gives location-specific sorting guidance. It's voluntary and requires an agreement with PRO Europe.

• GS1 digital link / next-generation barcode: Some national EPR schemes — Belgium's Fost Plus, for example — are not licensing DigiDot. They're working with GS1 so one code on the pack can eventually carry EPR status, recycled content, substances of concern and reuse information. That avoids cluttering the label with several QR codes.

  
  

If you're already planning a QR code for other EU requirements (the Digital Product Passport for some product categories, or PPWR's own data-carrier requirements from 2028), it makes sense to build toward a single code rather than adding another one.

What to do now

• Audit your artwork for the Green Dot, including inserts, outer cartons and e-commerce packaging.

• Remove it from your next print run. Don't wait for the February deadline if you're reprinting anyway.

• Check with your EPR scheme in each country how they want participation shown, and how they'll treat stock printed before the deadline.

• If you want a digital marker, decide between DigiDot and a GS1-based code, and plan it alongside your 2028 harmonised label update.

  
  

Bringing It Together

All three changes point the same way: fewer symbols printed on the box, more substantiation behind every claim, and more information moving to a QR code. The good news is that a single packaging audit covers all of them.

Deadline	Market	What to change
Now (since 12 Aug 2026)	EU	Declaration of Conformity and technical file for packaging; PFAS and heavy-metal limits
On hold (was 4 Oct 2026)	California	Chasing arrows and "recyclable" claims — enforcement blocked, but private lawsuits still possible
12 Feb 2027	EU	Remove the printed Green Dot; move EPR identification to a digital marker if you want it
12 Aug 2028 (or later)	EU	Add the harmonized material/sorting label
1 Jan 2030	EU	Recyclable design, recycled content, minimisation and empty-space limits

A practical first step: pull every piece of artwork you ship into the EU and California, and list every symbol and environmental claim on it. Then mark each one keep, qualify, move to QR or remove. If you're reprinting in the next six months, that list tells you exactly what to fix while you're already paying for new plates.

Not sure where your packaging stands? Book a free consult call 

This article is for general information only and reflects requirements as of date of publish. It isn’t legal advice, and regulations change. Before making product or compliance decisions, confirm the current requirements with the relevant authority, a notified body, or a qualified professional.