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Entitlement · LAB-04

Packaging made or imported before the labelling deadlines may still be sold for three years after those requirements enter into force, so existing stock and pre-printed material do not have to be written off on the deadline.

Economic operators holding pre-deadline packaging stock are given a right, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 12(12), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From the Art. 12 labelling deadlines (Art. 12(12)). as of 2026-08-18
  • It names 7 industries by name: Plastics converting, Paper and board, Glass, Aluminium, Wood, Food and drink and Retail. as of 2026-08-18
  • Compliance is checked by none, continuous. as of 2026-08-18
Addressee Economic operators holding pre-deadline packaging stockAct Regulation (EU) 2025/40, base actArticle Art. 12(12)Class Businesses

What changes

Everyone holding packaging stock or pre-printed film at the labelling deadlines. A sell-through window, not a permanent exemption.

The rule

New — no predecessor
Trigger

packaging manufactured in the Union or imported before the Art. 12(1), (2) or (4) deadlines

Entitlement

Packaging made or imported before the labelling deadlines may still be sold for three years after those requirements enter into force, so existing stock and pre-printed material do not have to be written off on the deadline.

Who is affected

Addressee
Economic operators holding pre-deadline packaging stock
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Retail and distribution · Reaches Waste and landfill
Applies
From the Art. 12 labelling deadlines (Art. 12(12))

Burden drivers

No burden drivers recorded on this provision.

No size threshold.

Source text

Verbatim

Packaging as referred to in paragraphs 1, 2 and 4 that is manufactured in the Union or imported before the deadlines referred in those paragraphs and that does not comply with the criteria laid down in those paragraphs may be made available on the market until 3 years from the date of entry into force of the labelling requirements laid down in those paragraphs.

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