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13 minute read
The PPWR labelling requirements are usually reduced to the new EU label on material composition. That falls short: since , labelling requirements under Regulation (EU) 2025/40 already apply, the harmonised label follows on 12 August 2028 at the earliest, and the regulation makes a QR code mandatory only in specific cases.
For product and marketing teams this is more than a question of dates. Whoever plans print files, packaging designs and digital data carriers today decides whether the packaging will be compliant in 2028 and 2029 without another redesign. And if you see the QR code on your packaging mainly as a marketing channel, you should know Article 12(5) before the next print run.
This article sets out what already applies under Articles 12, 15 and 18 of Regulation (EU) 2025/40 on EUR-Lex, what is still to come, when a QR code is mandatory and which rules govern digital labelling.
What the PPWR labelling requirements cover
The PPWR labelling requirements are all the requirements of Regulation (EU) 2025/40 on which information must be provided physically on the packaging or via a digital data carrier. They do not sit in one place but are spread across Article 12 on the labelling of packaging and the obligations of manufacturers in Article 15 and importers in Article 18 of the PPWR.
At the core of Article 12 is the harmonised label: a pictogram-based label, uniform across the EU, that states the material composition and is meant to make sorting easier for consumers. Alongside it, the regulation works with the digital data carrier, meaning a QR code or another standardised, open digital data carrier that provides information which does not fit, or does not fit completely, on the packaging.
In practice, three levels help. First, information that has been mandatory since the date of application. Second, labelling whose obligation only bites once the Commission's implementing acts are in place. Third, voluntary information for which the regulation sets a binding format as soon as you use it.
| Level | What it includes | Legal basis |
|---|---|---|
| Applies since 12/08/2026 | Identification element, manufacturer details, importer details, ban on misleading labels | Art. 15(5) to (7), Art. 18(3) and (4), Art. 12(8) |
| Obligation with a dynamic deadline | Harmonised label on material composition, labelling of reusable packaging with a data carrier, digital marking of substances of concern | Art. 12(1), (2) and (7) |
| Voluntary, but format-bound | Information on recycled and bio-based plastic content, QR code on the destination of individual components, symbol for fulfilling extended producer responsibility | Art. 12(1), (4) and (9) |
Key point: The labelling requirements are not a single label. They consist of current, upcoming and format-bound voluntary information.
What has to be on the packaging since 12 August 2026
The part of the labelling requirements that gets the least attention already applies. Under Article 15(5), every packaging must bear a type, batch or serial number or another element allowing its identification. Where the size or nature of the packaging does not allow this, the information goes into the documents accompanying the packaged product.
Article 15(6) also requires the manufacturer's name, registered trade name or registered trademark, postal address and, where available, electronic means of communication. The interesting part is where: the information may appear on the packaging or be provided via a QR code or another data carrier. The postal address must indicate a single point at which you can be contacted. Who counts as a manufacturer under the regulation is explained in Who is affected by the PPWR?.
Where an importer brings packaging into the EU from a third country, Article 18(3) requires it to add its own details on the packaging. Only where that is not possible may it use the digital data carrier under Article 12 or accompanying documents. For manufacturers and importers alike, the information must be clear and legible and must not replace, obscure or be confused with information required for the packaged product under other Union law (Article 15(7), Article 18(4)).
This is where we most often see a blind spot in projects: the packaging ID exists in the ERP but never reaches the packaging, or it is identical to the article number of the product. That no longer works once a product ships in several packaging variants. The same identifier is also needed for the EU declaration of conformity, under point 1 of Annex VIII.
Key point: Identification and manufacturer details have applied since August 2026. They are the part of the labelling requirements you can check today.
The harmonised label under Article 12(1)
From 12 August 2028 or 24 months after the implementing acts under Article 12(6) or (7) enter into force, whichever is later, packaging must carry a harmonised label on its material composition. It is based on pictograms and must be easily understandable, including for persons with disabilities. Compostable packaging under Article 9 must also state that it is compostable, that it is not suitable for home composting and that it is not to be discarded in nature.
Transport packaging is exempt, with the exception of e-commerce packaging, as is packaging subject to a deposit and return system. So the obligation applies to the e-commerce shipping box, but not to the pallet in the warehouse. Packaging in deposit and return systems under Article 50(1) receives its own clear and unambiguous label instead. Article 12(11) provides an exemption for the primary packaging of medicinal products and medical devices where there is no space or labelling could endanger safe use.
What the label looks like is not set out in the regulation itself. That is the job of implementing acts which the Commission should have adopted by 12 August 2026. That deadline has passed. On its "Have your say" consultation portal, the Commission lists the initiative on harmonised labels with adoption planned for the fourth quarter of 2026. The draft for public feedback has not yet been published (as at ).
This has a direct consequence for your planning, because the 24 months only start running once the act enters into force. A worked example: if it enters into force on 1 January 2027, the obligation applies not from 12 August 2028 but from 1 January 2029. 12 August 2028 is therefore a floor, not a changeover date. You will find the full deadline logic with all fixed and dynamic dates in the PPWR timeline.
Article 12(12) eases the transition further: packaging manufactured in or imported into the EU before the deadline that does not yet carry the new label may continue to be made available on the market for up to three years afterwards. This covers existing stock, not ongoing production after the cut-off date.
Key point: The label arrives in August 2028 at the earliest, probably later. What counts is the entry into force of the pending implementing act.
When a QR code has to go on the packaging
The widespread claim that the PPWR requires QR codes on all packaging is wrong. The regulation mentions QR codes and digital data carriers in several places, but only two of them create a stand-alone digital labelling obligation, and only one of those expressly requires a QR code or other data carrier. For substances of concern, the regulation prescribes standardised, open digital-marking technologies without committing to the QR code.
| Case | Legal basis | Status | From when |
|---|---|---|---|
| Reusable packaging: label on reusability, further information via QR code or other data carrier | Art. 12(2) and (3) | Mandatory, except for open loop systems without a system operator under Annex VI | 12/02/2029 or 30 months after the act under para. 6, whichever is later |
| Packaging containing substances of concern | Art. 12(1) second subpara., Art. 12(7) | Mandatory, via standardised, open digital-marking technologies | 24 months after the act under para. 7 second subpara., 2032 at the earliest (provisional, calculated) |
| Manufacturer and importer details | Art. 15(6), Art. 18(3) | Option for manufacturers, fallback only for importers | since 12/08/2026 |
| Symbol for fulfilling extended producer responsibility | Art. 12(9) | Voluntary, but digital only | from 12/02/2027 |
| Destination of individual components | Art. 12(1) third subpara. | Voluntary, in addition to the label | with the harmonised label |
| No space on packaging and grouped packaging, or accessible information | Art. 12(5) | Fallback: a single electronically readable code | with the respective obligation |
| Product requires a data carrier under other Union law | Art. 12(5) | Conditional obligation: a single data carrier for product and packaging | as soon as the product obligation applies |
Two points from the table are underestimated in practice. From 12 February 2027, Article 12(9) allows packaging to carry a symbol indicating that the producer fulfils its extended producer responsibility obligations, but only in a QR code or other standardised, open digital-marking technology. If you print such a symbol today, have it checked before the next print run whether it falls under this rule. And Article 15(6) already makes the QR code a permitted alternative for manufacturer details, which saves space, especially on small packaging.
Key point: There is no general QR code obligation. A data carrier only becomes mandatory for reusable packaging; substances of concern have their own digital marking obligation.
Rules for digital labelling
As soon as you provide mandatory information under Article 12(1), (2) or (4), the rules in paragraph 5 apply. Labels and data carriers must be affixed, printed or engraved visibly, legibly and firmly on the packaging, so that they cannot be easily erased. Where the nature or size of the packaging does not allow this, they go on the grouped packaging instead. The information must also be available to end users before purchase in online sales, in one or more languages easily understood by end users as determined by the Member State concerned.
For marketing teams, the two safeguards for electronically provided information are decisive. Personal data may only be collected for the limited purpose of giving users access to the compliance information. And the information itself has to be kept apart from advertising:
“The information shall not be displayed with other information intended for sales or marketing purposes.”
This has consequences for a common pattern: the QR code on the packaging that leads to a campaign page with a newsletter sign-up. As a carrier of legally required information, that page does not work. If you want to make mandatory information and brand communication digitally accessible via the packaging, you need an information architecture in which the mandatory information is presented clearly apart from sales and marketing content, and tracking that respects purpose limitation. What digital formats look like in detail will be set by the implementing act under paragraph 6. The principle of separation is already in the regulation.
Key point: The data carrier for mandatory information is not a marketing channel. Mandatory information and advertising stay separate, user data stays purpose-bound.
What labelling must not do: the ban on misleading labels
Article 12(8) has applied since the date of application and does not depend on the harmonised label. Economic operators must not provide or affix labels, marks, symbols or inscriptions that may mislead or confuse consumers or other end users with respect to the sustainability requirements for packaging, other packaging features or waste management options, where the regulation sets a harmonised label for them. The Commission may issue guidelines on this.
In addition, Directive (EU) 2024/825 on empowering consumers for the green transition applies from . It prohibits generic environmental claims without recognised excellent environmental performance, as well as sustainability labels that are neither based on a certification scheme nor established by public authorities. For packaging, this means that print such as "eco-friendly" or self-designed recycling seals need reviewing now, not in 2028.
Key point: Misleading sustainability claims on packaging are already not permitted. The 2028 label does not change that.
Labelling requirements and the Digital Product Passport
The PPWR does not require a Digital Product Passport for packaging. It does, however, link packaging labelling with the product at one point: where Union law requires information on the packaged product to be provided via a data carrier, Article 12(5) requires a single data carrier for the information on the product and the packaging. Both sets of information must remain easily distinguishable.
This becomes relevant as soon as your product falls under the Ecodesign for Sustainable Products Regulation and needs a Digital Product Passport, or under sector rules such as the Batteries Regulation. The packaging then carries not two codes but one, with two cleanly separated sets of information behind it. If you plan packaging labelling and the Digital Product Passport as separate projects, you will end up building that separation a second time.
Combined with the requirement to keep marketing content apart, this gives a clear architecture principle: product data, packaging data and brand content can come from one structure, but must be presented in clearly delimited areas.
Key point: If your product needs a data carrier, product and packaging information run through the same code, presented separately.
Five steps to compliant packaging labelling
The order follows the level of obligation: first what applies today, then what you can prepare before the label is fixed.
- Check the information that already applies. Check for each packaging type whether the identification element and manufacturer details under Article 15(5) and (6) are present, legible and up to date.
- Review your print files for risky claims. Check environmental claims, recycling symbols and seals against Article 12(8) and Directive (EU) 2024/825, and remove anything you cannot substantiate.
- Record the material composition per component. Record material, weight and components of each packaging component in a structured way so that the harmonised label can later be derived from the data.
- Define a data carrier strategy. Decide which information is provided physically and which digitally, and keep mandatory information apart from sales and marketing content.
- Monitor the implementing acts. Appoint a person responsible for tracking the acts under Article 12(6) and (7) and updating the changeover dates for each packaging.
Key point: Secure the information that already applies first, then structure material data. In the end, the label is just one output of that data.
PPWR labelling in numbers
12/08/2026
Since this date, identification, manufacturer details and the ban on misleading labels apply (Regulation (EU) 2025/40)
12/02/2027
From this date, the symbol for extended producer responsibility is only provided for digitally (Art. 12(9) PPWR)
Q4 2026
Planned adoption of the implementing acts on harmonised labels (European Commission, Have your say)
24 months
Transition period from entry into force of the implementing acts; the later date applies (Art. 12(1) PPWR)
12/08/2028
Earliest date for the harmonised label on material composition (Art. 12(1) PPWR)
12/02/2029
Earliest date for the label and data carrier on reusable packaging (Art. 12(2) PPWR)
Key point: Two dates are fixed. The label dates are floors that move back with every month the implementing act is delayed.
Implementation with Narravero
Narravero runs an end-to-end platform for the Digital Product Passport. More than 200 corporate customers across twelve industries use it, it handles 300 million platform accesses per month, EU-hosted and GDPR-compliant.
For PPWR labelling, this means: material composition, packaging IDs and manufacturer details sit in a versioned data foundation for each packaging type. From it, the information for the future label can be derived once the format is fixed, as can the digital information behind the data carrier, kept apart from brand content. If your product needs a Digital Product Passport, the single data carrier under Article 12(5) runs through the same structure. Our PPWR software shows what this looks like.
Thomas L. Rödding, founder and CEO of Narravero, is personally involved as Co-Chair of CEN-CENELEC JTC 24 and as Vice Chairman in German standardisation at DIN and DKE, the bodies shaping the technical framework for the Digital Product Passport in Europe. Through this involvement he brings a precise understanding of how data carriers and data models for product and packaging information are intended from a regulatory point of view.
Key point: Structured packaging data is the common source for the label, the data carrier and the Digital Product Passport.
Frequently asked questions on PPWR labelling
What are the PPWR labelling requirements?
The PPWR labelling requirements cover all requirements of Regulation (EU) 2025/40 on which information must be provided on the packaging or via a digital data carrier; they are set out mainly in Article 12 and in Articles 15 and 18.
What has to be on the packaging since 12 August 2026?
Since 12 August 2026, packaging must bear an identification element such as a type, batch or serial number under Article 15(5) and, under Article 15(6), the manufacturer's name, registered trade name or registered trademark, postal address and, where available, electronic contact details; this information may also be provided via a QR code or another data carrier.
When does the harmonised PPWR label apply?
The harmonised label on material composition applies from 12 August 2028 or 24 months after the implementing acts under Article 12(6) or (7) enter into force, whichever is later; as these acts are still pending, 12 August 2028 is only the earliest date.
Does the PPWR require a QR code on all packaging?
No, there is no general QR code obligation; a digital data carrier is mandatory for reusable packaging under Article 12(2) from 12 February 2029 at the earliest, and packaging containing substances of concern is subject to digital marking that applies 24 months after a pending implementing act and therefore, on a provisional calculation, from 2032 at the earliest.
Do the labelling requirements apply to transport packaging?
The harmonised label under Article 12(1) does not apply to transport packaging, with the exception of e-commerce packaging, or to packaging subject to a deposit and return system; the identification element and manufacturer details under Article 15 contain no such exemption.
Can I provide mandatory information and marketing via the same QR code?
Article 12(5) requires that mandatory information provided electronically is not displayed with other information intended for sales or marketing purposes and that personal data is only collected for a limited purpose; mandatory information and brand communication must therefore be clearly separated.
What happens to packaging produced without the new label before the deadline?
Under Article 12(12), packaging manufactured in or imported into the EU before the deadline that does not meet the new labelling requirements may continue to be made available on the market for up to three years afterwards.
Do I have to print the recycled content on the packaging?
No, the information is voluntary; if you state the recycled content or the share of bio-based plastic on the packaging, however, the label must comply under Article 12(4) with the specifications of the implementing act under paragraph 6, for recycled content from 12 August 2028 or 24 months after its entry into force, whichever is later.
What does Article 12(9) say about the extended producer responsibility symbol?
From 12 February 2027, packaging subject to an extended producer responsibility scheme may carry a symbol indicating that these obligations are fulfilled, but only in a QR code or other standardised, open digital-marking technology.
Does the PPWR require a Digital Product Passport for packaging?
No, the PPWR does not require a Digital Product Passport for packaging; where Union law requires information on the packaged product to be provided via a data carrier, however, Article 12(5) requires a single data carrier for the information on the product and the packaging.
Who is responsible for labelling the packaging?
Responsibility lies primarily with the manufacturer, meaning whoever manufactures the packaging or has it designed or manufactured under their own name or trademark; importers add their own details under Article 18(3), and distributors are subject to a graduated duty of care under Article 19.
