Series PPWR
PPWR 09 - What Do I Need to Write and Show on the Packaging?
2026.08.20 - 11:54
Labelling, symbols, consumer information and the new identification requirements - Article 12
- PPWR doesn't introduce a single labelling requirement - it's a package of at least five distinct obligations, each with its own application date.
- From 12 August 2026, only producer/importer identification and a traceability element are mandatory - not the sorting label many people think of as "the PPWR label."
- The harmonised EU pictogram-based label for material composition doesn't apply until 12 August 2028, or 24 months from the relevant implementing acts, whichever is later.
- A QR code or other digital carrier supplements the physical label - it doesn't replace it. PPWR does not require a QR code on every package.
- Reusable packaging gets its own label, on a separate timeline, from 12 February 2029.
- PPWR does not, in its own text, create a "Digital Product Passport" for packaging - this is a frequent mix-up with ESPR terminology.
- Companies should start preparing composition and traceability data now, even though the final label design isn't fixed yet.
A brand owner gets a message from the marketing team: "We're adding a QR code to the packaging, we're ready for PPWR."
Sounds simple. A QR code, a link to a website, a bit of extra information. But the right question isn't "did we add a QR code?" It's: "what exactly has to be printed on the packaging, what can live only behind the QR code, from what date, and for which type of packaging?"
Because under PPWR, labelling isn't a single event. It's a calendar of at least five different obligations, each with its own deadline, its own scope, and its own legal status. Treating them as one thing is the most common mistake we expect to see across the industry in the coming years.
From PPWR's general application date, packaging has to carry the identification of the producer or importer - name, brand, postal address, electronic contact details - plus an element enabling traceability, such as a batch or serial number.
This information can be physically on the pack, accessible via a QR code or other digital carrier, or provided in accompanying documents where physical marking isn't feasible.
This is the only labelling obligation that's already in force today. The sorting label most companies are expecting is not among them.
The EU-wide, pictogram-based harmonised label, indicating material composition to help consumers sort correctly, applies from 12 August 2028, or 24 months after the relevant implementing acts enter into force, whichever is later.
As of when this material was checked, the implementing acts meant to fix exactly what this label looks like were not confirmed as adopted. In other words: we know the label will exist. We don't yet know exactly what it will look like.
The same harmonised-pictogram requirement will apply to waste receptacles in shops and public spaces, so the sorting instruction on the packaging matches the instruction on the bin. But this too depends on the same implementing acts, so it runs on the same 2028 track.
Transport packaging and packaging within a deposit-return system are generally excluded from this requirement. There's an important exception, though: e-commerce transport packaging IS included, even though it's technically transport packaging. It's exactly the kind of detail that's easy to miss.
PPWR does not require a QR code on every package. There's no general rule saying every single-use package needs a QR code purely for labelling purposes.
What the Regulation actually requires: a digital carrier becomes mandatory for reuse-system information, from 2029. It becomes mandatory for substances-of-concern marking, on a much longer horizon, dependent on a methodology that doesn't exist yet. And it stays optional for supplementary component-level sorting information or for identifying participation in a national EPR scheme.
In every other case, a QR code or other open digital carrier can be added voluntarily, but it doesn't replace information that has to remain physically, durably affixed to the packaging - producer identification, the future harmonised pictogram, deposit-return marking.
From 12 February 2029, or 30 months after the relevant implementing act enters into force, whichever is later, reusable packaging placed on the market has to carry a label stating that it's reusable, plus a QR code or other open digital carrier making further reuse-system information accessible.
Here the digital carrier is no longer optional. It's mandatory - but only for this specific category.
The final design of this label isn't fixed yet. We're not inventing a specific pictogram before it's officially published.
On top of the national label, a harmonised EU colour label may be established through an implementing act, and a Member State may require its use, provided doing so doesn't create distortions in the internal market. This remains a future possibility, not a current requirement.
A QR code indicating the destination of each separate packaging component remains explicitly optional in this context.
For the Romanian market, there's a genuine open question with no confirmed public answer: how will the current SGR mark, administered by RetuRO, coexist with any future EU harmonised colour label, once one is established? We found no official clarification published on this. We're not assuming an answer.
But the direction of the transition is clear, even if the exact terms depend on implementing acts not yet adopted.
The clearest example: France's Triman/Info-tri system. The European Commission opened infringement proceedings against France in November 2024, and referred the matter to the Court of Justice of the EU in July 2025, precisely because the Triman requirement conflicts with PPWR's harmonisation objective. That's a real, dated, verifiable example - not a guess about what might happen.
The classic resin identification codes - the 1-to-7 numbered triangles, voluntarily used for decades - are expected to be replaced for newly placed packaging once the harmonised system becomes applicable. They don't, by themselves, satisfy the future PPWR labelling requirement.
The Green Dot symbol is a different story. It's essentially a symbol indicating participation in a national extended-producer-responsibility financing scheme - not a recyclability claim and not a sorting instruction. It was never, and doesn't become through PPWR, a sorting label.
Article 7 sets binding recycled-content percentages. But that doesn't automatically mean the percentage has to be printed on the pack.
We found no general requirement to display the recycled-content percentage directly on the packaging. Compliance with Article 7 is demonstrated through technical documentation and the Declaration of Conformity, not necessarily through what the consumer sees on the product.
A company can choose, voluntarily, to display a recycled-content percentage. But at that point, the statement moves into the territory of an environmental claim, which has to be accurate and evidenced, regardless of whether PPWR itself requires it.
The PPWR harmonised label is a mandatory, standardised requirement. A claim like "100% recyclable" is a separate marketing statement, which in principle remains possible, but has to be accurate, not misleading, and not contradict the official information on the harmonised label once it exists.
We don't treat the PPWR label and voluntary environmental claims as the same thing. The first is mandatory and standardised. The second remains optional and governed by separate consumer-protection rules.
For all of these, the real question is: does the label need to communicate only the dominant material, or every component separately?
We found no confirmed answer. This remains one of the most important open questions for the industry, and any answer given now would be a guess, not a confirmed fact.
We don't assume the 5% plastic-content threshold used elsewhere in PPWR (for certain Annex V restrictions, covered in PPWR 07) automatically applies to labelling as well. These are different provisions, with different purposes.
The exact surface-area threshold isn't set yet in the available sources. We're not inventing a figure.
Adding a label after import is, in practice, a common route. But that label still has to meet Article 12(5)'s visibility and durability requirements - clearly visible, not easily removed. A simple adhesive sticker that peels off easily may not meet that standard.
A non-EU symbol on the original packaging doesn't, by itself, satisfy the future EU harmonised labelling requirement.
Most of the evidence around recyclability, recycled content or minimisation - covered at length in PPWR 04, 05 and 06 - stays in the technical file, not on the label. The one direct point of overlap is the traceability element (the batch or serial number), which physically links the product back to the technical file behind it.
PPWR doesn't, in its own text, create a "Digital Product Passport" for packaging the way ESPR does for other product categories. PPWR provides for a QR code or open digital carrier, for specific, limited purposes - reuse-system information, substances-of-concern marking, optional supplementary information.
Some material in the market does, however, use the term "Digital Product Passport" to describe these PPWR provisions. That's a terminology overlap, not a real identity between the two mechanisms. "Digital Product Passport," as a formal architecture, belongs to ESPR, not to PPWR's own text.
Artwork files and printing plates, pre-printed film and sleeves, markings moulded directly into the tool for injection or blow-moulded items, laser-marking systems, artwork approval workflows with customers and retailers, market-specific SKU variants driven by language requirements and different national deposit-return marks - all of this is affected.
A company with 200 SKUs sold across 8 European markets isn't looking at one label change - potentially hundreds of SKU/market combinations to review.
Useful elements to prepare now:
False. A QR code is mandatory only for specific purposes - otherwise it's optional or not required at all.
"The recycled-content percentage has to be printed on every package."
False. Compliance with Article 7 is demonstrated through documentation, not necessarily through on-pack display.
"The resin code (1-7) is enough."
False. These codes weren't designed for PPWR's sorting function and are expected to be replaced.
"The Green Dot proves recyclability."
False. It's an EPR-financing symbol, not a sorting label.
"One EU symbol means language no longer matters."
Needs qualification. The pictogram is designed to be language-independent, but accompanying text information remains subject to national language requirements.
"Transport packaging is exempt from Article 12."
Needs qualification. It's exempt from the general material label, with the notable exception of e-commerce transport packaging.
"Imported packaging can keep its original, non-EU label."
False. The importer has to ensure PPWR-compliant information is present before EU market placement.
"PPWR creates a Digital Product Passport for every package."
False, or at least needs serious qualification. PPWR's digital provisions are narrower and purpose-specific; the formal "Digital Product Passport" architecture belongs to ESPR.
"A paper-plastic composite can automatically use the paper label."
False, or at least unconfirmed. There's no confirmation that the 5% plastic threshold, used in a different context, automatically applies to labelling too.
PPWR 05 asked: how much recycled material does it need to contain?
PPWR 06 asked: am I using more packaging than necessary?
PPWR 07 asked: am I still allowed to use this format for this application?
PPWR 08 asked: does part of this flow need to move into a system for reuse?
PPWR 09 asks a different kind of question: once the packaging has been correctly engineered against all of the above, what does it actually need to communicate - to the consumer, to the sorting system, to the reuse system, to the authorities?
Labelling is the visible end of a data chain that starts with material composition and ends with a pictogram or a QR code. A company that hasn't solved the data questions from PPWR 04-08 will find labelling unexpectedly hard, no matter how simple the final artwork looks.
Ask: "what information needs to be physically on the pack, what can live behind the QR code, from what date does each apply, and do we have the data to build it correctly?"
Prepare the data now. Don't print the final label before the final rule exists.
The PPWR series keeps developing based on the questions we get from industry. If you're not sure what needs to appear on a specific package, or how labelling connects to a deposit-return or reuse system, write to us.
Sounds simple. A QR code, a link to a website, a bit of extra information. But the right question isn't "did we add a QR code?" It's: "what exactly has to be printed on the packaging, what can live only behind the QR code, from what date, and for which type of packaging?"
Because under PPWR, labelling isn't a single event. It's a calendar of at least five different obligations, each with its own deadline, its own scope, and its own legal status. Treating them as one thing is the most common mistake we expect to see across the industry in the coming years.
What does Article 12 actually say?
Article 12 isn't a single rule. It's a structure. There's a general identification obligation, already active. There's a harmonised material-composition label, not yet active. There's a separate label for reusable packaging, with its own deadline. There's a digital marking for substances of concern, on a much longer horizon. And there's an optional symbol tied to national extended producer responsibility schemes. Each of these has its own date, its own scope, and its own level of legal certainty.What's already mandatory, from 12 August 2026
This is the point most companies get wrong.From PPWR's general application date, packaging has to carry the identification of the producer or importer - name, brand, postal address, electronic contact details - plus an element enabling traceability, such as a batch or serial number.
This information can be physically on the pack, accessible via a QR code or other digital carrier, or provided in accompanying documents where physical marking isn't feasible.
This is the only labelling obligation that's already in force today. The sorting label most companies are expecting is not among them.
The harmonised composition label - not yet active
Here we need real precision, because this confusion will cost real money in artwork redone unnecessarily.The EU-wide, pictogram-based harmonised label, indicating material composition to help consumers sort correctly, applies from 12 August 2028, or 24 months after the relevant implementing acts enter into force, whichever is later.
As of when this material was checked, the implementing acts meant to fix exactly what this label looks like were not confirmed as adopted. In other words: we know the label will exist. We don't yet know exactly what it will look like.
The same harmonised-pictogram requirement will apply to waste receptacles in shops and public spaces, so the sorting instruction on the packaging matches the instruction on the bin. But this too depends on the same implementing acts, so it runs on the same 2028 track.
Transport packaging and packaging within a deposit-return system are generally excluded from this requirement. There's an important exception, though: e-commerce transport packaging IS included, even though it's technically transport packaging. It's exactly the kind of detail that's easy to miss.
The QR code supplements the label, it doesn't replace it
This is probably the single most important practical idea in this whole article.PPWR does not require a QR code on every package. There's no general rule saying every single-use package needs a QR code purely for labelling purposes.
What the Regulation actually requires: a digital carrier becomes mandatory for reuse-system information, from 2029. It becomes mandatory for substances-of-concern marking, on a much longer horizon, dependent on a methodology that doesn't exist yet. And it stays optional for supplementary component-level sorting information or for identifying participation in a national EPR scheme.
In every other case, a QR code or other open digital carrier can be added voluntarily, but it doesn't replace information that has to remain physically, durably affixed to the packaging - producer identification, the future harmonised pictogram, deposit-return marking.
Reusable packaging labelling - a separate timeline
The connection to PPWR 08 is direct.From 12 February 2029, or 30 months after the relevant implementing act enters into force, whichever is later, reusable packaging placed on the market has to carry a label stating that it's reusable, plus a QR code or other open digital carrier making further reuse-system information accessible.
Here the digital carrier is no longer optional. It's mandatory - but only for this specific category.
The final design of this label isn't fixed yet. We're not inventing a specific pictogram before it's officially published.
Deposit-return system marking
Packaging within a national deposit-return system has to carry a clear, unambiguous national label indicating that status. This is already a functional requirement, satisfied today, wherever such a system exists, by existing national marks.On top of the national label, a harmonised EU colour label may be established through an implementing act, and a Member State may require its use, provided doing so doesn't create distortions in the internal market. This remains a future possibility, not a current requirement.
A QR code indicating the destination of each separate packaging component remains explicitly optional in this context.
For the Romanian market, there's a genuine open question with no confirmed public answer: how will the current SGR mark, administered by RetuRO, coexist with any future EU harmonised colour label, once one is established? We found no official clarification published on this. We're not assuming an answer.
What happens to the old symbols?
PPWR doesn't automatically ban every existing national symbol on day one.But the direction of the transition is clear, even if the exact terms depend on implementing acts not yet adopted.
The clearest example: France's Triman/Info-tri system. The European Commission opened infringement proceedings against France in November 2024, and referred the matter to the Court of Justice of the EU in July 2025, precisely because the Triman requirement conflicts with PPWR's harmonisation objective. That's a real, dated, verifiable example - not a guess about what might happen.
The classic resin identification codes - the 1-to-7 numbered triangles, voluntarily used for decades - are expected to be replaced for newly placed packaging once the harmonised system becomes applicable. They don't, by themselves, satisfy the future PPWR labelling requirement.
The Green Dot symbol is a different story. It's essentially a symbol indicating participation in a national extended-producer-responsibility financing scheme - not a recyclability claim and not a sorting instruction. It was never, and doesn't become through PPWR, a sorting label.
Recycled content - on the pack or documentation only?
The connection to PPWR 05.Article 7 sets binding recycled-content percentages. But that doesn't automatically mean the percentage has to be printed on the pack.
We found no general requirement to display the recycled-content percentage directly on the packaging. Compliance with Article 7 is demonstrated through technical documentation and the Declaration of Conformity, not necessarily through what the consumer sees on the product.
A company can choose, voluntarily, to display a recycled-content percentage. But at that point, the statement moves into the territory of an environmental claim, which has to be accurate and evidenced, regardless of whether PPWR itself requires it.
Can I still say "100% recyclable"?
We found no direct regulation, within Article 12, of the wording of voluntary recyclability claims.The PPWR harmonised label is a mandatory, standardised requirement. A claim like "100% recyclable" is a separate marketing statement, which in principle remains possible, but has to be accurate, not misleading, and not contradict the official information on the harmonised label once it exists.
We don't treat the PPWR label and voluntary environmental claims as the same thing. The first is mandatory and standardised. The second remains optional and governed by separate consumer-protection rules.
Multi-material packaging - still an open question
A PET bottle with a PP cap and a PE label. A flexible multilayer pouch. A paper cup with a plastic coating inside.For all of these, the real question is: does the label need to communicate only the dominant material, or every component separately?
We found no confirmed answer. This remains one of the most important open questions for the industry, and any answer given now would be a guess, not a confirmed fact.
We don't assume the 5% plastic-content threshold used elsewhere in PPWR (for certain Annex V restrictions, covered in PPWR 07) automatically applies to labelling as well. These are different provisions, with different purposes.
Small packaging
For packaging below a certain minimum surface area, PPWR allows a QR code or digital carrier to be used instead of a physical pictogram - but only for cases where there genuinely isn't enough physical space for a legible pictogram, not as a general alternative for any company that would simply prefer a digital-only label.The exact surface-area threshold isn't set yet in the available sources. We're not inventing a figure.
Imported packaging
For packaged goods manufactured outside the EU, responsibility for ensuring the required information is present before market placement rests, in principle, with the importer - the same logic we've already seen for Articles 6, 7, 10 and 25 elsewhere in this series.Adding a label after import is, in practice, a common route. But that label still has to meet Article 12(5)'s visibility and durability requirements - clearly visible, not easily removed. A simple adhesive sticker that peels off easily may not meet that standard.
A non-EU symbol on the original packaging doesn't, by itself, satisfy the future EU harmonised labelling requirement.
Labelling vs traceability
What the consumer sees on the pack isn't the same thing as the technical documentation a company has to keep and be able to produce for authorities.Most of the evidence around recyclability, recycled content or minimisation - covered at length in PPWR 04, 05 and 06 - stays in the technical file, not on the label. The one direct point of overlap is the traceability element (the batch or serial number), which physically links the product back to the technical file behind it.
Labelling vs "Digital Product Passport"
An important clarification is needed here.PPWR doesn't, in its own text, create a "Digital Product Passport" for packaging the way ESPR does for other product categories. PPWR provides for a QR code or open digital carrier, for specific, limited purposes - reuse-system information, substances-of-concern marking, optional supplementary information.
Some material in the market does, however, use the term "Digital Product Passport" to describe these PPWR provisions. That's a terminology overlap, not a real identity between the two mechanisms. "Digital Product Passport," as a formal architecture, belongs to ESPR, not to PPWR's own text.
What does this mean for a converter or a label manufacturer?
A small label change becomes, at scale, a serious industrial project.Artwork files and printing plates, pre-printed film and sleeves, markings moulded directly into the tool for injection or blow-moulded items, laser-marking systems, artwork approval workflows with customers and retailers, market-specific SKU variants driven by language requirements and different national deposit-return marks - all of this is affected.
A company with 200 SKUs sold across 8 European markets isn't looking at one label change - potentially hundreds of SKU/market combinations to review.
What data do I already need to have ready?
Because the correct label depends on material composition, country of sale, deposit-return status and reuse status, reliable, structured, component-level data is needed - not file-by-file manual management.Useful elements to prepare now:
- polymer or material identification for each component;
- layer structure and detailed composition;
- cap, label and sleeve material;
- recycled-content data, including post-consumer versus post-industrial origin;
- food-contact status;
- reusable-design status, where relevant;
- packaging weight;
- technical drawings of the packaging.
What do I ask a supplier or customer, right now?
- Which countries will the packaging be sold in?
- Is it part of a deposit-return system?
- Is it reusable, and if so, is it part of a genuine system for reuse?
- Which artwork version is required, and who has final sign-off?
- Who is responsible for the final consumer-facing label - the converter, the brand owner, or the importer?
- Are additional voluntary environmental claims wanted, and are they evidenced?
- Is the package sold individually, or as part of grouped packaging that might carry some information on its behalf?
What can I do now?
What I can do now
- take stock of existing labels across the packaging portfolio;
- map material composition at component level, for every SKU;
- build or update packaging bills of materials (BOMs);
- identify which packaging is currently within a deposit-return system;
- identify which packaging is, or is becoming, reusable;
- map national symbols in use across every market sold into;
- establish who owns artwork decisions internally, and at each customer.
What I'm preparing now
- artwork templates that reserve space for a pictogram whose final content isn't fixed yet;
- a digital-data architecture ready for a future digital carrier;
- structured supplier data collection, ahead of urgent need;
- a multilingual labelling strategy for every market sold into;
- clean-up of internal (ERP) data on composition, deposit-return status and reuse status.
What I'm tracking
- the implementing acts that will fix the harmonised label's final design;
- the implementing act for the reusable-packaging label;
- how the waste-receptacle requirements develop;
- any progress on a harmonised colour label for deposit-return systems;
- national guidance, including any Romania-specific development for the SGR system.
What I wouldn't do yet
- I wouldn't redo every artwork file before the final specifications exist;
- I wouldn't assume a QR code is mandatory where it isn't;
- I wouldn't remove existing national deposit-return marks prematurely;
- I wouldn't add voluntary recyclability claims that might contradict future harmonised information.
A few common misunderstandings
"PPWR requires a QR code on every package."False. A QR code is mandatory only for specific purposes - otherwise it's optional or not required at all.
"The recycled-content percentage has to be printed on every package."
False. Compliance with Article 7 is demonstrated through documentation, not necessarily through on-pack display.
"The resin code (1-7) is enough."
False. These codes weren't designed for PPWR's sorting function and are expected to be replaced.
"The Green Dot proves recyclability."
False. It's an EPR-financing symbol, not a sorting label.
"One EU symbol means language no longer matters."
Needs qualification. The pictogram is designed to be language-independent, but accompanying text information remains subject to national language requirements.
"Transport packaging is exempt from Article 12."
Needs qualification. It's exempt from the general material label, with the notable exception of e-commerce transport packaging.
"Imported packaging can keep its original, non-EU label."
False. The importer has to ensure PPWR-compliant information is present before EU market placement.
"PPWR creates a Digital Product Passport for every package."
False, or at least needs serious qualification. PPWR's digital provisions are narrower and purpose-specific; the formal "Digital Product Passport" architecture belongs to ESPR.
"A paper-plastic composite can automatically use the paper label."
False, or at least unconfirmed. There's no confirmation that the 5% plastic threshold, used in a different context, automatically applies to labelling too.
How this connects to the rest of the series
PPWR 04 asked: can this packaging actually be recycled?PPWR 05 asked: how much recycled material does it need to contain?
PPWR 06 asked: am I using more packaging than necessary?
PPWR 07 asked: am I still allowed to use this format for this application?
PPWR 08 asked: does part of this flow need to move into a system for reuse?
PPWR 09 asks a different kind of question: once the packaging has been correctly engineered against all of the above, what does it actually need to communicate - to the consumer, to the sorting system, to the reuse system, to the authorities?
Labelling is the visible end of a data chain that starts with material composition and ends with a pictogram or a QR code. A company that hasn't solved the data questions from PPWR 04-08 will find labelling unexpectedly hard, no matter how simple the final artwork looks.
The real question
Don't just ask: "did we add a QR code?"Ask: "what information needs to be physically on the pack, what can live behind the QR code, from what date does each apply, and do we have the data to build it correctly?"
Prepare the data now. Don't print the final label before the final rule exists.
The PPWR series keeps developing based on the questions we get from industry. If you're not sure what needs to appear on a specific package, or how labelling connects to a deposit-return or reuse system, write to us.
OFFICIAL SOURCES
- Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste - in particular Articles 9, 12, 13 and 50.
- European Commission - Guidance document for Regulation (EU) 2025/40, C(2026) 3702, 5 June 2026.
- Decision 97/129/EC establishing the identification system for packaging materials.
- European Commission infringement proceedings against France over the Triman/Info-tri requirement (opened November 2024; referred to the CJEU July 2025).
CONTEXT SOURCES
- European Commission - Packaging and Packaging Waste Regulation (PPWR).