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Colombia: EPR in force, the Article 11 label still unissued
Colombia has binding packaging extended producer responsibility and a single-use-plastics statute. What it does not yet have is the technical labelling regulation that Article 11 of Law 2232 directed the national government to issue. That enabling provision identifies the subjects a future label should address. It does not itself prescribe the content, format or conformity route. Recording the unissued regulation as a current standardised artwork requirement is a misreading of the statute.
The question this report answers
Colombia is frequently described as if a complete sustainability label were already mandatory on covered products. Article 11 of Law 2232 of 7 July 2022 directed the national government to issue a technical regulation specifying label information concerning consumer management, environmental impact, plastic content and recyclability. The legislative direction is binding on the government. The required technical instrument must exist before anyone can know the prescribed content, format and conformity route. A missed deadline does not allow a private party to invent those details and call them legally mandated.
Other obligations are already operative, and they should not be collapsed into the missing label. Resolution 1407 of 2018 and its amendments establish extended producer responsibility for packaging made from paper, board, plastic, glass and metal. Law 2232 prohibits or restricts specified single-use plastics. Resolution 0803 of 24 June 2024 implements important elements of that law, including alternatives and compliance mechanisms. These instruments can require consumer information, management plans, certification and reporting without amounting to the standardised Article 11 label. Resolution 0803 should not be used as a substitute unless its text expressly satisfies Article 11. The source review for this report did not identify it as that comprehensive technical labelling regulation.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Article 11 technical labelling regulation | not issued | Law 2232 required a technical regulation. The source record does not show a final instrument that satisfies that mandate. |
| Packaging EPR plans and reporting | mandatory | Resolution 1407 and amendments impose collection and management duties on producers of paper, board, plastic, glass and metal packaging. |
| Consumer return and management information | mandatory | Covered actors must provide information supporting return and proper management through the applicable EPR and single-use-plastics framework. |
| Banned single-use plastic products | mandatory | Law 2232 phases prohibitions and conditions by product. A label cannot legalise a prohibited format. |
What Article 11 is, and what it is not
Article 11 is an enabling and direction provision. It identifies the subjects that the future technical label should address and set a deadline for regulation. It does not reproduce a complete label, prescribe final graphics, or establish all measurement and certification details. The Atlas therefore records the measure as outstanding. That classification is a statement about the source record as of 21 August 2026, not a prediction that the regulation will never appear.
Until it does appear, enforcement has to be tied to provisions that are actually in force. Anticipated artwork is not a current Colombian duty, and a voluntary recyclability statement is not a stand-in for the missing technical regulation.
The duties that are already law
Resolution 1407 creates producer obligations for packaging waste management: formulation of, or participation in, environmental management plans; collection and achievement of targets; reporting; and consumer communication. The producer definition can reach manufacturers and importers of packaged goods, and persons placing private-label goods on the national market. The party that owns the global brand is not always the regulated Colombian producer.
Law 2232 phases bans and restrictions for listed single-use plastic products and establishes requirements for permitted alternatives and disposable plastic beverage containers. Applicability depends on product type, material and exceptions. Environmental labelling cannot cure a prohibited product. EPR participation and any required certification are not replaced by a voluntary recyclability statement. Consumer information that the existing framework already requires is a communication duty. It is not, without the Article 11 instrument, a standardised on-pack sustainability panel.
Claims while the technical label is missing
Claims about recyclability, recycled content, biodegradability or compostability should identify the package component, the applicable standard and the disposal conditions. Technical recyclability is not identical to collection and recycling in practice. Where a claim relies on an EPR programme, the evidence should distinguish programme participation and recovery results from the characteristics of the individual package. Compliance with a voluntary standard is not government certification unless an authorised conformity-assessment route exists.
Spanish wording, symbols and qualifications have to be read together for their overall consumer impression. The Ministry of Environment and Sustainable Development and competent environmental authorities administer the waste and plastics framework. The Superintendence of Industry and Commerce can address misleading consumer information. Those are parallel routes. They do not fill the gap left by the unissued Article 11 regulation.
Primary sources and verification
Colombia. Law No. 2232 of 7 July 2022, especially Article 11. Official PDF
Ministry of Environment and Sustainable Development. Resolution 0803 of 24 June 2024. Official record
Ministry of Environment and Sustainable Development. Resolution 1407 of 2018, packaging waste management. Official record
Spanish-language official texts control. Last verified: 21 August 2026.