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PPWR labelling requirements: which label applies when — and why the EU label does not exist yet

The PPWR has applied since 12 August 2026, but the implementing acts that define the packaging label are overdue. What is already mandatory, why 12 February 2027 is the next hard deadline, and when the harmonised sorting label actually arrives.

Author: myDPP Team

PPWR labelling requirements: which label applies when — and why the EU label does not exist yet

The Packaging and Packaging Waste Regulation (EU) 2025/40 has applied since 12 August 2026. That includes Article 12, which harmonises packaging labelling across the EU: a pictogram for material composition, a reuse label, a digitally readable pointer to the producer responsibility scheme. There is one problem. Nobody knows what that label looks like. The Commission was required to adopt the implementing acts setting out shape, colour, size and codes by 12 August 2026. It did not. The deadline passed and the label does not exist.

Many companies read that as a reprieve. It is not. Three obligations already apply, and a fourth kicks in on 12 February 2027 — one that depends on no outstanding act at all. It requires that a particular piece of information leave the packaging only in digital form, through a QR code. That is exactly where the PPWR meets the digital product passport: the data carrier you are building for the passport is the same one packaging labelling will demand from 2027.

Key takeaways

  • The harmonised sorting label applies from 12 August 2028 at the earliest — or 24 months after the implementing acts enter into force, whichever is later. Since those acts were due in August 2026 and are still missing, the date moves back automatically.
  • The 12 August 2026 deadline was missed. Three acts were due: the harmonised label with its specifications and formats (Art. 12(6)), the methodology for stating material composition through digital means (Art. 12(7)), and the matching labelling for waste receptacles (Art. 13(2)). None has been adopted.
  • The next hard date is 12 February 2027, not 2028. From then, a marking indicating that packaging is covered by an extended producer responsibility scheme may be applied only digitally — as a symbol in a QR code or another standardised, open digital marking technology (Art. 12(9)).
  • Already mandatory today: the producer’s name, registered trade name or trade mark and postal address on the packaging, the ban on misleading markings, and the substantiation duty for voluntary environmental claims.
  • The old numeric system is ending. The material codes under Decision 97/129/EC — PET 1, PAP 20, ALU 41 — are repealed as of 12 August 2028 and replaced by the harmonised label.
  • Reusable packaging needs its own label plus a QR code from 12 February 2029, carrying information about the reuse system and collection points (Art. 12(2)).
  • Transport packaging is exempt — e-commerce shipping packaging is not. If you sell online, the shipping box falls under the labelling obligation.
  • Existing stock is protected. Packaging manufactured or imported before the relevant date may be placed on the market for up to three years afterwards (Art. 12(12)).
  • National labels disappear — but only once the EU label arrives. The French Triman, German disposal notices and the Italian environmental labelling cannot be maintained permanently alongside the harmonised label. Deposit systems are the exception.

The label that does not exist yet

Article 12 of the PPWR describes a label whose appearance the regulation itself does not define. That is standard practice in EU product law: the base act creates the duty, an implementing act supplies the detail. In the PPWR there are three such acts, and all three were due on 12 August 2026 — the same day the regulation became applicable.

Due were:

  • Article 12(6) — the harmonised label itself: pictograms, specifications and formats, including provision through digital means.
  • Article 12(7) — the methodology for indicating material composition through digital marking technologies.
  • Article 13(2) — the matching labelling for waste receptacles, so that packaging and bin speak the same visual language.

As of late August 2026, none of these acts has been adopted. The only thing publicly available is a technical proposal from the Commission’s Joint Research Centre — useful, but not legally binding.

The regulation anticipated this. Article 12(1) ties the obligation to a double condition: 12 August 2028 or 24 months after the implementing acts enter into force, whichever is later. Every month of delay in Brussels pushes the date back by a month. If the act appears in, say, spring 2027, the obligation starts in spring 2029.

That is a planning statement, not an all-clear. The conversion work — prepress, packaging specifications, supplier alignment, running down old stock — does not start on the deadline but on the day the act is published. Companies that only start collecting material data then will lose the first six of their 24 months.

What has applied since 12 August 2026

Three duties are in force regardless of the missing acts.

Identification details on the packaging. The producer must state its name, registered trade name or registered trade mark, and the postal address at which it can be reached, together with a type, batch or serial number identifying the packaging. This is a traceability duty rather than an environmental label — and it applies now.

Ban on misleading markings. Packaging must not carry marks, colours or statements that mislead consumers about material composition, recyclability, reusability or the correct disposal route. Green leaves, unsupported circular arrows and phrasing such as “environmentally friendly packaging” without evidence fall under this. How the ban interacts with general advertising law is covered in our articles on the Green Claims Directive and the Empowering Consumers Directive.

Substantiation of voluntary environmental claims. If you voluntarily claim something about the properties of the packaging, the claim must be technically documented and must go beyond the legal minimum requirements. The evidence belongs in the technical documentation you already have to keep for the PPWR declaration of conformity.

12 February 2027: producer responsibility moves into the QR code

This is the rule most overviews lose, because it sits between two more prominent dates.

Article 12(9) provides that from 12 February 2027, a marking indicating that packaging is subject to an extended producer responsibility scheme may be applied only through a symbol in a QR code or another standardised, open digital marking technology.

Two clarifications matter, because the provision is often reported more sharply than it reads.

First, the marking itself is not mandatory EU-wide. The provision governs the form, not the whether. From that date, Member States may require nationally that packaging in an EPR scheme be identified — and if they do, the digital route is the only permissible one.

Second, the printed mark stops working as EPR identification. A company printing a scheme mark such as the Green Dot on packaging to show participation in a take-back system can no longer use it as compliant identification under Article 12 from 12 February 2027. The information has to move into the code.

In practice this creates demand, over the next few months, for a machine-readable open data carrier on European packaging — independent of the product passport, but built on exactly the same technology. Companies that have treated QR codes as a marketing device now face a regulatory requirement with format constraints: standardised, open, not proprietary. What that means concretely is covered in QR code vs GS1 Digital Link.

12 August 2028: the harmonised sorting label

This is the obligation most people mean when they say “PPWR labelling” — and the one hanging on the implementing acts.

What is required. Packaging placed on the market must bear a harmonised label indicating its material composition to help consumers sort it. The intent is pictograms for the material streams — paper, plastic, glass, metal, wood, textile, composite — that look identical across the EU.

What it replaces. The existing identification system under Decision 97/129/EC, with its numeric codes PET 1, HDPE 2, PAP 20, ALU 41, is repealed as of 12 August 2028. It was never mandatory in the first place, only a voluntary identification scheme. The PPWR turns it into a duty and changes the visual language at the same time.

Who is affected. In principle all packaging reaching end users. Transport packaging is exempt — with one exception that is decisive in online retail: e-commerce shipping packaging is covered. An online shop’s shipping box does not count as transport packaging for the purposes of the exemption. Packaging subject to a deposit and return system is also exempt; it carries the deposit marking instead.

Small packaging. Where packaging falls below a given surface area, the required information may be provided through a QR code or other digital data carrier instead of being physically printed. This is a size-based exception, not a general option — the carrier replaces the label only where there is genuinely no room.

Compostable packaging. It must be labelled as compostable and must additionally make clear that it is not suitable for home composting. That is the legislator’s answer to a familiar misunderstanding: industrially compostable does not mean garden compostable.

Waste receptacles: the same visual language on the bin (Article 13)

Article 13 supplies the counterpart to packaging labelling. Member States must ensure that harmonised labels are affixed, printed or engraved visibly, legibly and indelibly on all receptacles for collecting packaging waste, matching the fractions identified on the packaging itself. Receptacles under deposit and return systems are excluded.

The purpose is obvious: a consumer should recognise the pictogram from the packaging and map it to a bin. For companies this is not a duty of their own, but it is a strong indication that the Commission will publish the packaging and receptacle pictograms together — and that the two acts are delaying each other.

12 February 2029: reusable packaging with label and QR code

Packaging in a formal reuse system has its own deadline. From 12 February 2029 — again subject to the 24-month rule — reusable packaging needs, under Article 12(2):

  • a label identifying the packaging as reusable, and
  • a QR code or equivalent data carrier pointing to the reuse system: how to return it, where the collection points are, how many rotations are intended.

In addition, it must be visible at the point of sale which offer is reusable and which is single use.

For reuse system operators this is the point at which packaging labelling and product data management become the same technical exercise. A data carrier that serves rotations, return points and scheme membership is functionally a product passport — with a different legal basis.

Voluntary claims: recycled content and bio-based plastics

Statements about recycled content and the share of bio-based plastics are voluntary under Article 12(4). Those who make them, however, are bound by the specifications in the implementing acts — so there is no third route between saying nothing and saying it exactly as the Commission prescribes.

This matters because from 2030 Article 7 imposes binding minimum recycled content in plastic packaging. The share then becomes a mandatory entry in the technical documentation, while packaging labelling initially stays separate. The links between material requirements and documentation duties are set out in our PPWR overview.

What happens to Triman, national disposal notices and Italian labelling

Article 12 labelling is fully harmonised. Once it becomes applicable, Member States may not require additional national sorting instructions alongside it. The only exception concerns markings related to deposit and return systems.

Affected are, among others, the French Triman with its sorting instructions, the Italian environmental labelling with material code and disposal note, and the national disposal notices that have become customary in German packaging practice. The conflict predates the PPWR: the Commission opened infringement proceedings against France over the Triman in November 2024 and referred the case to the Court of Justice in July 2025.

For companies serving several markets this means today’s variety of national symbols is a transitional state with an expiry date. If you are redesigning packaging now, do not plan permanent space for national symbols — but do not clear it prematurely either, because national duties apply unchanged until the cut-off.

The three-year rule for existing stock

Article 12(12) contains a transitional rule worth a great deal in procurement planning: packaging manufactured or imported before the relevant labelling date may be placed on the market for up to three years after the obligation takes effect.

No warehouse has to be destroyed and no print run cancelled. What counts is the date of manufacture or import, not the date of sale — which presupposes that this date can be evidenced. Batch numbers and goods-receipt records thereby become compliance documents.

Where packaging labelling meets the digital product passport

Three of the duties described require a machine-readable data carrier on the packaging: EPR identification from 2027, the small packaging exception from 2028, and the reuse label from 2029. The digital product passport requires the same carrier for the product.

The obvious conclusion is to solve both with one code. Technically that works, but only on two conditions.

First, the code has to be resolvable and open. The PPWR calls for a “standardised, open” technology. A QR code pointing at a proprietary vendor domain, whose content is lost when you change vendor, does not meaningfully satisfy that. The reasoning behind GS1 Digital Link is set out in GS1 QR code: the 2D code replaces the barcode.

Second, packaging and product are different objects. The passport describes the article, the PPWR label describes the wrapper. Forcing both into one identity breaks down as soon as the same product ships in two packaging variants, or one package holds several articles. A clean data model keeps packaging and product as separate objects with their own history and lets a resolver decide which view a scan returns.

Preparing in five steps

1. Complete packaging master data

For every packaging unit: materials by fraction, weight per fraction, coatings and laminates, recycled content, supplier, date of manufacture or import. Without that base none of the coming labels can be generated — and the technical documentation demands the same fields already today.

2. Settle the EPR question for 12 February 2027

For each target market, check whether an EPR marking is required or intended, and how the scheme mark currently on your packaging got there. Wherever it is printed as EPR evidence, it needs a digital replacement by early 2027.

3. Decide a data carrier strategy before the act arrives

Which code type, which resolver, which domain, which granularity — article, batch or item. None of these decisions depends on the outstanding implementing act, so all of them can be brought forward. Changing code type later means new print tooling.

4. Plan surface area and stock run-down

Decide where on the packaging the future label will sit, and run the three-year rule against your stock coverage. With long print cycles, that calculation determines whether an interim run is still economic.

5. Monitor the implementing act actively

Because the deadline hangs on publication, the date the implementing act appears is the single most important metric in the project. Assign an owner and a review cycle — not a chance sighting in a newsletter.

Frequently asked questions

Do PPWR labelling requirements apply yet?

Partly. Producer identification details, the ban on misleading markings and the substantiation duty for voluntary environmental claims have applied since 12 August 2026. The harmonised sorting label does not apply yet — it takes effect on 12 August 2028 at the earliest.

What does the new EU packaging label look like?

That is currently unknown. The implementing acts setting pictograms, colours and formats were due on 12 August 2026 and have not been adopted. Anyone selling a “PPWR-compliant label” today is selling a guess.

Does 12 August 2028 move automatically?

Yes. Article 12(1) applies whichever of two moments is later: 12 August 2028, or 24 months after the implementing acts enter into force. Any delay in Brussels pushes the date back accordingly.

Will every package need a QR code from 2027?

No. Article 12(9) only governs that a marking indicating extended producer responsibility — if it is applied — may from 12 February 2027 be applied digitally only. Whether such a marking is required is for the individual Member State to decide.

Do e-commerce boxes fall under the labelling obligation?

Yes. Transport packaging is exempt, but e-commerce shipping packaging is expressly not. Online retailers must treat the shipping box as packaging subject to labelling.

What happens to our printed stock?

Packaging manufactured or imported before the cut-off may be placed on the market for up to three years afterwards, provided you can evidence the date of manufacture or import.

Can we keep printing the Triman?

Until the harmonised label becomes applicable, national requirements apply unchanged. After that, national sorting instructions may not be required in addition — with the exception of markings related to deposit systems.

Sources

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