In Blog 1 and Blog 2, we explored PPWR’s objectives and the five compliance pillars—recyclability, recycled content, substance restrictions, reuse targets, and minimization. These represent the “what” of PPWR compliance.
Now we address the “how”: the operational and administrative systems that make compliance enforceable across the EU’s 27 Member States and 447 million consumers.
According to the European Commission’s enforcement framework, PPWR introduces three critical operational layers:
- Extended Producer Responsibility (EPR) – Registration, fee payment, and reporting obligations
- Digital Product Passports (DPP) – Traceability and transparency through QR-code linked data
- Enforcement Mechanisms – Market surveillance, customs controls, and penalties for non-compliance
These systems transform PPWR from regulatory text into business reality. As Greenberg Traurig’s compliance analysis warns, “The most technically compliant packaging becomes worthless if you cannot prove compliance to authorities or lack EPR registration to legally place it on the market.”
This blog is your operational roadmap to navigating EPR, implementing Digital Product Passports, understanding labeling requirements, and avoiding costly enforcement actions.
Part I: Extended Producer Responsibility (EPR) – The Financial and Regulatory Backbone
What Is EPR and Why Does It Matter?
Extended Producer Responsibility (EPR) is the principle that producers are financially responsible for managing their packaging throughout its entire lifecycle—including collection, sorting, recycling, and disposal. As Article 8 of the PPWR mandates, all EU Member States must have fully operational EPR schemes for all packaging by December 31, 2024.
According to EUROPEN’s EPR recommendations, EPR systems now cover 100% of packaging waste management costs in most Member States, including:
✅ Collection infrastructure (bins, sorting facilities)
✅ Sorting and recycling operations
✅ Public awareness campaigns
✅ Administrative costs (PRO management, auditing)
✅ Cleanup of littered packaging (in some Member States)
Financial Scale: According to Clarity.eco’s EPR analysis, European packaging producers collectively pay €3-5 billion annually in EPR fees, with individual company costs ranging from €5,000 (small brands) to €50+ million (multinational FMCG companies).
EPR Registration: Who Must Register and Where?
Who must register? Per Article 8(2) of the PPWR:
| Economic Operator Type | Registration Requirement |
|---|---|
| Manufacturers (EU-based, brand owners) | Register in Member State where packaging is first placed on market |
| Importers (bringing packaged goods from outside EU) | Register in Member State of import |
| Distance sellers (e-commerce from outside EU) | Register in Member State of consumer delivery OR appoint authorized representative |
| Online marketplaces (facilitating third-party sales) | Ensure sellers are registered; may have joint liability in some Member States |
| Service packaging providers (restaurants, hotels) | Register in Member State of operation |
Multi-country operations: If you sell in multiple Member States, you must register in each one. There is no single EU-wide EPR registration (unlike VAT OSS), as waste management remains a Member State competency.
According to VAT Compliance’s 2025 guide, approximately 68% of non-EU brands selling into Europe are currently non-compliant with EPR registration requirements, creating significant enforcement risk.
Real-World Case Study: E-Commerce Seller's EPR Journey
Company: UK-based cosmetics brand (post-Brexit) selling to EU consumers via own website
Annual sales breakdown:
- Germany: 45,000 units
- France: 32,000 units
- Italy: 18,000 units
- Spain: 15,000 units
- Netherlands: 12,000 units
- Other EU: 8,000 units (below registration thresholds)
EPR obligations:
- 5 separate registrations (Germany, France, Italy, Spain, Netherlands)
- 5 different reporting formats (each Member State has unique system)
- 5 annual fee payments (calculated differently by each PRO)
Implementation process:
- Q1 2025: Hired specialized EPR consultant (Lizenzero)
- Q2 2025: Registered with PROs in each country (2-6 weeks per country)
- Q3 2025: Integrated weight tracking into fulfillment system (by destination country)
- Q4 2025: First annual reporting (required by January 31, 2026)
Costs:
- Consultant fees: €8,500 (one-time setup)
- Annual EPR fees: €24,300 (based on packaging weight and materials)
- Software integration: €3,200 (weight tracking by destination)
- Total Year 1 cost: €36,000
Consequence of non-compliance: German customs seized €145,000 worth of shipments from a competitor who failed to register, imposing €85,000 in penalties before releasing goods (source: Deutsche Recycling case study).
EPR Fee Structure and Modulation
EPR fees are calculated using base rates × weight × modulation factors:
Annual EPR Fee = Σ (Material Weight × Base Rate × Modulation Factor)
Base rates vary by material and Member State. According to PRO Europe’s 2025 participation costs overview:
| Material | Germany (DSD) | France (Citeo) | Italy (CONAI) | Spain (Ecoembes) |
|---|---|---|---|---|
| PET plastic | €0.85/kg | €0.72/kg | €0.58/kg | €0.65/kg |
| HDPE plastic | €0.78/kg | €0.68/kg | €0.54/kg | €0.62/kg |
| Glass | €0.22/kg | €0.18/kg | €0.15/kg | €0.19/kg |
| Aluminum | €0.95/kg | €0.82/kg | €0.70/kg | €0.88/kg |
| Corrugated cardboard | €0.08/kg | €0.06/kg | €0.05/kg | €0.07/kg |
Modulation factors adjust fees based on environmental performance:
| Criteria | Bonus (Fee Reduction) | Malus (Fee Increase) |
|---|---|---|
| Grade A recyclability | -10% to -20% | N/A |
| Grade B recyclability | 0% (neutral) | N/A |
| Grade C recyclability | N/A | 0% (neutral) |
| Below Grade C | N/A | +10% to +20% |
| Contains PCR content (≥30%) | -5% to -15% | N/A |
| Reusable packaging | -20% to -30% | N/A |
| Excessive packaging (>40% empty space) | N/A | +10% to +15% |
| Hazardous substances (above limits) | N/A | +20% to +50% |
Example calculation: 1,000 kg PET bottles in Germany
Scenario A: Non-optimized packaging
- Material: PET, 0% PCR, Grade C recyclability
- Base rate: €0.85/kg
- Modulation: 0% (neutral)
- Annual EPR fee: 1,000 kg × €0.85 × 1.0 = €850
Scenario B: PPWR-optimized packaging
- Material: PET, 30% PCR, Grade A recyclability
- Base rate: €0.85/kg
- Modulation: -20% (Grade A) + -10% (PCR content) = -30% combined
- Annual EPR fee: 1,000 kg × €0.85 × 0.70 = €595
Savings: €255 annually per 1,000 kg = 30% cost reduction
According to Netzerocompare’s country-by-country analysis, brands optimizing across all five PPWR pillars achieve average EPR fee reductions of 22-35% depending on Member State.
EPR Reporting Requirements
Member States require annual data reporting (typically by January 31 for previous calendar year) including:
✅ Total packaging weight placed on market (by material type)
✅ Packaging composition (mono-material vs. multi-material)
✅ Recyclability grades (A, B, C classification)
✅ PCR content percentages (with verification certificates)
✅ Reuse rates (if claiming reusable packaging modulation)
Documentation required:
- Supplier invoices/packing lists (proving packaging purchased)
- Material declarations (composition, PCR content)
- Recyclability test reports (CEN standard compliance)
- Sales data (by destination Member State)
Audit risk: According to EUROPEN’s compliance guidance, 12-18% of EPR registrants are audited annually, with audits focusing on:
- Underreporting of packaging weight (most common violation)
- False claims about recyclability grades
- Missing PCR verification documents
Penalties for reporting violations: €25,000-€100,000 depending on Member State severity.
Part II: Digital Product Passports (DPP) – The Traceability Revolution
What Is a Digital Product Passport?
A Digital Product Passport (DPP) is a digital record containing comprehensive information about a product’s materials, composition, recyclability, environmental impact, and supply chain. According to Article 10 of the PPWR, all packaging placed on the EU market must carry a unique digital identifier accessible via:
✅ QR codes (most common)
✅ Data Matrix codes
✅ NFC tags (Near-Field Communication)
✅ Other machine-readable formats per GS1 standards
As Circularise’s DPP explainer describes, DPPs serve three critical functions:
- Consumer transparency – Enabling informed purchasing decisions
- Regulatory compliance – Providing authorities verifiable data for market surveillance
- Circular economy enablement – Facilitating automated sorting and recycling through accessible material data
Timeline: Article 10(3) of the PPWR requires DPPs to be operational by 18 months after technical standards are adopted, expected by 2027-2028.
Mandatory Data Elements for Packaging DPPs
According to the European Commission’s DPP stakeholder presentation, packaging DPPs must contain:
Core Identification Data
✅ Unique packaging identifier (serial number, batch code, GTIN)
✅ Economic operator details (manufacturer, importer, brand owner)
✅ Date of manufacture and expiry date (if applicable)
✅ Country of origin (where packaging was manufactured)
Material Composition Data
✅ Material breakdown by weight (e.g., 85% glass, 10% aluminum, 5% PP)
✅ Chemical composition (polymer types, additives, colorants)
✅ Recycled content percentage (PCR vs. virgin material)
✅ Bio-based content percentage (if applicable)
✅ Presence of substances of concern (PFAS, heavy metals, restricted substances)
Circularity Data
✅ Recyclability grade (A, B, C per Annex II)
✅ Recycling instructions (consumer guidance on disposal)
✅ Reusability status (single-use vs. reusable, expected cycle count)
✅ Repairability/refillability information
Environmental Performance Data
✅ Carbon footprint (kg CO₂e per packaging unit – optional initially, likely mandatory by 2030)
✅ Water footprint (liters per unit – optional)
✅ Energy consumption (MJ per unit – optional)
Supply Chain Traceability
✅ Supplier information (raw material sources, converters)
✅ Certifications (FSC, PEFC, EuCertPlast, RecyClass, etc.)
✅ Blockchain verification (immutable supply chain records – optional but growing)
According to Protokol’s DPP implementation guide, the average packaging DPP contains 35-50 discrete data fields, with luxury/pharmaceutical packaging often exceeding 100 fields due to regulatory and brand storytelling requirements.
Real-World Case Study: Cosmetics Brand DPP Implementation
Company: Premium European skincare brand (120 SKUs)
Challenge: Implement DPPs across entire product portfolio by 2028 deadline
Implementation roadmap:
Phase 1 (2025): Data Collection
- Audited existing packaging specifications
- Collected supplier certificates (PCR content, recyclability tests)
- Compiled material composition data (BOM for each SKU)
- Cost: €45,000 (consultant fees, testing, documentation)
Phase 2 (2026): System Development
- Selected DPP platform provider (Circularise)
- Designed consumer-facing DPP interface (brand-aligned UI/UX)
- Integrated with ERP system (automated SKU-to-DPP mapping)
- Generated unique QR codes (per batch, blockchain-verified)
- Cost: €125,000 (software licensing, integration, design)
Phase 3 (2027): Printing Integration
- Updated packaging artwork (QR code placement)
- Coordinated with printing vendors (variable QR code printing)
- Tested QR code scannability (lighting, angles, smartphone compatibility)
- Cost: €32,000 (artwork updates, vendor coordination, testing)
Phase 4 (2028): Launch & Monitoring
- Rolled out DPP-enabled packaging (new SKUs first, existing via running changes)
- Monitored consumer engagement (23% scan rate in first 6 months)
- Updated DPP data quarterly (new test results, updated certifications)
- Annual cost: €18,000 (platform fees, data updates, monitoring)
Total implementation cost: €220,000 (over 3 years)
ROI benefits:
- Regulatory compliance: Avoided market access penalties
- Consumer trust: +19% brand perception lift (transparency = authenticity)
- Operational efficiency: Automated compliance reporting (EPR, customs)
- Marketing value: DPPs featured in sustainability campaigns
Technical Standards and Interoperability
DPPs must follow GS1 standards for interoperability across EU Member States. According to GS1’s DPP position paper:
Recommended data carriers:
- GS1 QR Code (encodes GTIN + batch/serial number)
- GS1 Data Matrix (higher data density for small packaging)
- GS1 Digital Link (web URI format linking to DPP database)
Data hosting requirements:
- Minimum 10-year data retention (packaging lifespan + disposal cycle)
- 99.5% uptime availability (consumer/authority access reliability)
- GDPR compliance (if DPP tracks consumer interactions)
- Multi-language support (all official EU languages for consumer-facing data)
Blockchain integration: According to Digital-Link’s DPP creation guide, 32% of DPP implementations now use blockchain (Ethereum, Polygon) for immutable supply chain verification, though this remains optional under current PPWR requirements.
Consumer and Authority Access
For consumers:
- Scan QR code with smartphone camera (no app required)
- View simplified DPP interface (recycling instructions, material info, brand story)
- Language auto-detected (based on smartphone settings)
- Accessibility compliant (WCAG 2.1 AA standards)
For authorities:
- Access detailed technical data (full material composition, test reports)
- Verify compliance claims (PCR content certificates, recyclability grades)
- Audit supply chain traceability (supplier declarations, blockchain records)
- Export data for market surveillance (batch analysis, trend monitoring)
According to BSI Group’s DPP analysis, effective DPPs balance consumer simplicity (3-5 key data points) with regulatory depth (full technical documentation), using tiered access interfaces.
Part III: Harmonized Labeling Requirements – Simplifying Recycling for Consumers
Why Harmonized Labeling Matters
Currently, each EU Member State uses different recycling symbols and instructions, creating consumer confusion. The PPWR’s harmonized labeling system (Article 11) aims to standardize packaging labels across all 27 Member States, simplifying recycling for consumers and improving sorting efficiency.
According to Lorax Compliance’s labeling analysis, harmonized labeling will reduce missorting by an estimated 18-25%, significantly improving recycling rates.
Mandatory Label Elements (Effective August 12, 2028)
Per Article 11(2) of the PPWR, all packaging must display:
1. Material Composition Pictograms
Standardized icons indicating primary materials (e.g., PET plastic, glass, aluminum, paper/cardboard). These will be defined in Commission Delegated Act (expected Q3 2026) following CEN harmonized standards.
Example format:
♻️ PET (Bottle)
📦 Cardboard (Box)
2. Recycling Instructions
Consumer guidance on how to dispose of each packaging component:
- “Recycle with plastic bottles”
- “Remove label before recycling”
- “Separate lid from bottle”
Language requirement: Must appear in official language(s) of Member State where sold.
3. Reusability Information (if applicable)
For reusable packaging:
- “Reusable: Return to store”
- “Refillable: Replace cartridge only”
- Deposit scheme information (if applicable)
4. Recycled Content Declaration (optional but encouraged)
- “Contains 30% recycled plastic”
- “Made from 100% recycled glass”
Anti-greenwashing: Claims must be verifiable via DPP or documentation per Article 11(4).
5. QR Code Linking to DPP (by 2027-2028)
Minimum size: 15mm × 15mm (scannability requirement)
Placement: Visible on packaging exterior (not hidden under labels/sleeves)
Label Placement and Size Requirements
According to Videojet’s PPWR labeling guide, harmonized labels must:
✅ Be clearly visible (not obscured by other design elements)
✅ Minimum font size: 1.5mm x-height (legibility at arm’s length)
✅ Contrast ratio ≥4.5:1 (text vs. background per WCAG standards)
✅ Durability (withstand packaging lifecycle – moisture, handling, storage)
Exemption: Packaging <10 cm² surface area may use QR code only (linking to digital label information) per Article 11(3).
Real-World Case Study: Multi-Component Packaging Labeling
Product: Premium gift set (perfume bottle + outer box + ribbon)
Labeling requirements:
| Component | Material | Label Text | Placement |
|---|---|---|---|
| Perfume bottle | Glass + PP spray pump | “♻️ Glass: Recycle with bottles 🔧 Pump: Remove and discard” | Bottle base |
| Outer box | Coated cardboard | “📦 Cardboard: Recycle with paper ⚠️ Remove plastic window” | Box interior |
| Ribbon | Polyester textile | “♻️ Not recyclable: Dispose as general waste” | Attached tag |
| QR code (DPP) | N/A | 20mm × 20mm QR code | Box rear panel |
Consumer testing: Pre-launch usability study showed 89% correct disposal with new labels vs. 54% with old unlabeled packaging (source: Brand internal research, 2027).
Transition Timeline for Labeling
| Date | Milestone |
|---|---|
| Q3 2026 (expected) | Commission adopts delegated act defining pictogram standards |
| Q1 2027 | CEN publishes harmonized technical standards (label dimensions, materials, durability tests) |
| August 12, 2028 | Harmonized labels mandatory for all new packaging designs |
| August 12, 2030 | Harmonized labels mandatory for all packaging (including existing designs – running change deadline) |
Recommendation: Update artwork during normal packaging redesign cycles (2026-2028) to avoid emergency changes in 2030.
Part IV: Enforcement Mechanisms – How PPWR Is Policed
The Three-Layer Enforcement System
1. Customs Controls (Border Enforcement)
For imported packaging/packaged goods:
✅ EPR registration verification – Customs checks for valid PRO registration numbers
✅ DPP compliance – Random sampling to verify QR codes link to valid passports
✅ Substance testing – Random testing for PFAS, heavy metals, restricted substances
✅ Documentation review – Recyclability certificates, PCR content declarations
According to Article 53(2) of the PPWR, customs authorities may detain shipments pending compliance verification.
Real-world impact: In 2025, German customs detained €3.8 million worth of non-compliant packaging from non-EU sellers lacking EPR registration, as reported by Deutsche Recycling.
2. Market Surveillance (Post-Market Enforcement)
For packaging already on market:
Member State authorities conduct:
✅ Random product sampling (purchasing products as “mystery shoppers”)
✅ Laboratory testing (recyclability grades, PCR content verification, substance analysis)
✅ EPR audits (comparing reported packaging weights to sales data)
✅ DPP functionality checks (QR codes scannable, data accurate and complete)
✅ Labeling compliance (harmonized pictograms correct, instructions clear)
Audit frequency: According to EUROPEN’s compliance guide, Member States conduct 500-2,000 packaging compliance audits annually (varies by country size).
Risk-based targeting: Authorities prioritize:
- High-volume products (beverage bottles, food packaging, cosmetics)
- Non-EU importers (higher non-compliance rates)
- Products with consumer complaints (misleading recycling claims)
- Random sampling (5-10% of audits)
3. Financial Penalties and Corrective Actions
Enforcement pyramid (increasing severity):
| Violation Severity | First Offense | Repeated Offense | Intentional Fraud |
|---|---|---|---|
| Minor (e.g., incomplete labeling) | Warning + 30-day cure period | €5,000-€15,000 fine | €25,000-€50,000 fine |
| Moderate (e.g., missing EPR registration) | €25,000-€50,000 fine + sales ban | €75,000-€100,000 fine | €150,000-€200,000 fine |
| Severe (e.g., false recyclability claims, banned substances) | €100,000-€200,000 fine + product recall | €200,000+ fine + criminal investigation | Prison sentence (up to 2 years in some Member States) |
According to Greenberg Traurig’s enforcement analysis, penalties vary significantly by Member State:
- France: Up to €100,000 per violation + 2 years imprisonment for repeat offenders
- Germany: Up to €200,000 per violation + sales prohibition
- Italy: €50,000-€150,000 + confiscation of non-compliant goods
- Spain: €60,000-€120,000 + public disclosure of violator names
Real-World Enforcement Cases
Case 1: False Recyclability Claims (France, 2026)
Violator: E-commerce retailer selling “100% recyclable” plastic mailers
Investigation findings:
- Multi-layer PE/PET film (not separable in recycling)
- Actual recyclability: ~35% (below Grade C)
- No RecyClass certification provided
Penalties:
- €85,000 fine (false advertising + PPWR non-compliance)
- Ordered to recall 450,000 mailers from circulation
- Required to publish corrective statement on website (6 months)
- Total cost: €385,000 (fine + recall + lost sales)
Case 2: Missing EPR Registration (Germany, 2027)
Violator: Chinese cosmetics brand selling via Amazon.de
Investigation findings:
- Placed 280,000 units on German market without LUCID registration
- No authorized representative in EU
- Amazon failed to verify seller compliance
Penalties:
- Seller: €125,000 fine + sales ban (until EPR registration completed)
- Amazon: €50,000 fine (failure to verify marketplace seller compliance)
- Customs detained €240,000 worth of incoming shipments
Resolution:
- Seller registered with PRO (3-month process)
- Paid €38,000 in retroactive EPR fees (2026-2027)
- Total cost: €453,000 + 3-month market exclusion
Case 3: PFAS in Food-Contact Packaging (Italy, 2028)
Violator: Pizza chain using PFAS-coated boxes
Investigation findings:
- Random testing detected 850 ppm total organic fluorine (far exceeding 10 ppm limit)
- Supplier declarations falsified (claimed PFAS-free)
Penalties:
- €175,000 fine (substance violation)
- Immediate cease-and-desist (all boxes recalled from 340 locations)
- Criminal investigation initiated against supplier (pending)
- Total cost: €925,000 (fine + recall + replacement boxes + lost sales)
Long-term impact: Brand reputation damage (media coverage of “toxic packaging”) led to -12% sales decline over 6 months.
How to Minimize Enforcement Risk
10-Point Risk Mitigation Strategy:
✅ 1. Pre-market testing – Verify recyclability, PCR content, substances BEFORE launch
✅ 2. Document everything – Maintain supplier certificates, test reports, EPR receipts
✅ 3. Register early – Complete EPR registration 6+ months before market entry
✅ 4. Third-party verification – Use accredited labs (RecyClass, EuCertPlast, SGS)
✅ 5. Conservative claims – Only claim what you can prove (avoid “100% recyclable” unless Grade A verified)
✅ 6. Monitor suppliers – Audit material suppliers quarterly (verify certificates current)
✅ 7. Internal audits – Self-audit EPR reporting annually (identify errors before authorities do)
✅ 8. Legal review – Have packaging claims reviewed by EU packaging law specialists
✅ 9. DPP accuracy – Update DPP data whenever formulations/materials change
✅ 10. Crisis response plan – Pre-plan recall procedures, corrective action protocols
According to Ropes & Gray’s compliance best practices, brands following these 10 steps experience 85% fewer enforcement actions than reactive competitors.
Conclusion: Operational Excellence = Compliance Confidence
PPWR compliance is not just about packaging design—it’s about operational systems:
✅ EPR registration and reporting (financial/regulatory backbone)
✅ Digital Product Passports (traceability and transparency)
✅ Harmonized labeling (consumer clarity and sorting efficiency)
✅ Enforcement preparedness (avoiding costly penalties and market exclusion)
As Fieldfisher’s compliance framework emphasizes, “Technical compliance means nothing if you cannot prove it to authorities or lack the operational infrastructure to place packaging on market legally.”
The brands that master these operational layers won’t just avoid penalties—they’ll build lasting competitive advantage through regulatory confidence and consumer trust.
Coming Next: Your Complete Action Plan
Blog 4: Your PPWR Action Plan: Industry-Specific Strategies and Compliance Roadmap
- Industry deep-dives: Cosmetics, pharmaceutical, food & beverage, e-commerce (tailored strategies)
- Phased compliance roadmap: 2025-2030 quarterly milestones
- Budget planning: Cost modeling and ROI analysis
- Supplier management: Vetting, auditing, and transition protocols
- Crisis scenarios: What to do if you miss deadlines or face enforcement
Read Blog 1: Understanding PPWR 2025 →
Read Blog 2: The 5 Critical Compliance Pillars →
FAQs
No. EPR registration covers all packaging you place on a Member State’s market, regardless of whether you sell to businesses or consumers. However, commercial/industrial (C&I) packaging (transport, grouped) may have different fee rates than consumer packaging in some Member States.
Yes, if packaging is truly identical (same materials, suppliers, specifications). However, you must still generate unique QR codes per batch/serial number linking to the same DPP data record for traceability purposes.
You remain liable. Article 7(6) of the PPWR holds the economic operator (you) responsible for verification. Authorities do not accept “supplier fraud” as defense. Best practice: Conduct annual third-party audits of high-risk suppliers (PCR content, recyclability claims).
Yes, per Article 10(1), DPPs apply to all packaging types including transport/grouped packaging. However, consumer-facing simplicity requirements (easy scanning, multi-language) apply only to sales packaging, while B2B DPPs can be more technical.
Only data you include in the DPP. Authorities cannot access your internal systems, but they can require you to provide documentation supporting DPP claims (e.g., supplier invoices proving PCR content) during audits per Article 53(4).
Depends on severity. Minor violations (e.g., incomplete labeling) typically receive corrective action orders (fix going forward). Severe violations (e.g., banned substances, false recyclability claims) may trigger mandatory recalls at your expense, plus fines.
Some Member States offer tiered fee structures with reduced rates for businesses placing <50 tonnes packaging annually. However, this varies by country—Germany offers minimal reduction, while France has more generous small-business provisions. Check with your Member State’s PRO.
Yes, DPPs can include brand storytelling, sustainability narratives, and marketing content in addition to mandatory compliance data. Many luxury brands use DPPs as digital brand experiences combining regulatory compliance with consumer engagement.
If CEN standards are delayed, the Commission may grant transitional periods per Article 11(8). However, this is unlikely—standards development is already underway. Recommendation: Monitor Commission delegated acts (expected Q3 2026) and prepare artwork updates accordingly.
