EmpCo, FSC® changes & PPWR - What manufacturers need to consider now about their packaging artwork*

The EU is tightening its requirements regarding environmental communication and manufacturers’ obligations. Companies must adapt their packaging and print designs to new legal requirements by 12 August 2026 and 26 September 2026 at the latest – particularly regarding EmpCo, FSC® trademarks and the PPWR.

(Proposal)*

This page provides packaging experts with a comprehensive overview and shows how brands can position themselves in compliance with the law at an early stage

EmpCo – Clear rules against greenwashing (effective from 27 September 2026)

The Empowering Consumers for the Green Transition (EmpCo) Directive sets stricter standards across the EU for sustainability claims. The aim is to protect against misleading claims, symbols and labels. In practice, this means, for example, that products cannot simply be labelled with terms such as ‘sustainable’ or ‘environmentally friendly’ without these claims being clearly substantiated by data. The responsibility lies with the producer or distributor of the packaged products.

Important deadline:

From 27 September 2026, only packaging with legally compliant, verifiable environmental and sustainability claims may be placed on the market.
There is no transition period for existing packaging on the market.

Possible consequences of non-compliance include warnings, fines and sales bans.

The following claims will no longer be permitted in future

Terms such as ‘sustainable’, ‘environmentally friendly’ and ‘green’ without supporting evidence
Own labels/seals without independent certification
Climate-neutral claims based solely on offsetting or environmental promises without a clear benchmark
Images/symbols suggesting sustainability without evidence
Advertising based on obvious facts (statutory minimum requirements)

This does not mean that labels or sustainability claims may no longer be printed on packaging in future, but rather that labels must come from an official source and claims must be verifiable and substantiated - ideally via a QR code linking to the relevant documents.

Impact on FSC® labelling

From September 2026, the use of the logo add-on “Forests For All Forever” will no longer be permitted. The FSC® logo itself may still be used, but without this addition.

Outlook: Adaptation and clarification of the FSC® logo by 2029

Furthermore, FSC® has decided on a fundamental revision of its trademark rules to further increase transparency for consumers.

New FSC© trademark standards will come into force on 1 July 2026.
A transition period will apply until 1 January 2029.

Plans include, amongst other things:

the inclusion of a URL or QR code on or within the label,
a clearer description of what the FSC® certification specifically refers to,
mandatory additional information elements to prevent misinterpretation.

Document | FSC® Connect

There is no immediate need for action here, but it is advisable to generate a new logo via the FSC® website for new print designs from July 2026 onwards.

PPWR – New regulations for manufacturer identification and sorting labels

The PPWR (Packaging and Packaging Waste Regulation) also brings changes to the artwork of packaging.

From 12 August 2026 – Mandatory information regarding the manufacturer

In future, all packaging must be clearly attributed to a responsible economic operator.

Required information:

Name/company of the manufacturer or importer
Contact address (postal + digital)
Optional: Authorised representative for manufacturers outside the EU
Information must be displayed directly on the packaging or label

The requirements apply throughout the EU and to all types of materials. This information must be legible, durable and affixed directly to the packaging or label. In addition, packaging must bear an identification mark in the form of a type, batch or serial number.

From August 2028: standardised separation and sorting labels

The EU-wide harmonised separation and sorting labels (material pictograms for waste separation) will come into effect from August 2028; the European Commission is expected to publish the templates in August 2026.

A technical proposal from the Joint Research Centre (JRC) is currently available; the final design is still being developed. With the new labelling requirements, all previous separation and sorting instructions on packaging, such as material codes or the Triman, will be phased out.