The basic harmonised material composition label is to apply from 12 August 2028 or later, depending on the implementing act. Reusable packaging has a separate label from 12 February 2029 or later under the same later-date mechanism.
The PPWR aims to harmonise packaging labels
Article 12 of the PPWR establishes common packaging labelling rules to help consumers sort waste and receive information about packaging characteristics.
1. The harmonised material composition label
From 12 August 2028 or 24 months after the relevant implementing act enters into force, whichever is later, packaging covered by Article 12(1) must carry a harmonised label with material composition information. It is to use pictograms and be easy to understand, including for people with disabilities.
2. Exemptions from the basic label
Except for e-commerce packaging, the obligation in Article 12(1) does not apply to transport packaging or packaging covered by a deposit and return system. Deposit and return systems have separate labelling requirements.
3. Compostable packaging
For certain compostable packaging, the label is to provide additional information on compostability and the appropriate way to handle the waste.
4. QR codes and digital data carriers
In addition to the harmonised label, an operator may use a QR code or another standardised, open digital data carrier to provide certain information, for example about separate packaging components.
5. Reusable packaging: 2029
Reusable packaging placed on the market from 12 February 2029 or 30 months after the relevant implementing act enters into force, whichever is later, must carry a label informing users that it is reusable. Further information on the reuse system is to be available digitally.
6. Labelling recycled content
If packaging covered by Article 7 is labelled with recycled content information after the applicable deadline, the way this information is presented should follow the relevant implementing act's specifications and the PPWR methodology.
7. Biobased plastic content
The PPWR also regulates how information on biobased plastic content is presented where an operator chooses to communicate that content.
8. Deposit and return systems
Packaging covered by a deposit and return system must be clearly and unambiguously labelled in accordance with the PPWR and the relevant system's requirements.
9. Substances of concern: digital marking
The PPWR also provides for digital marking of information about substances of concern, following a methodology developed by the Commission.
10. Labelling and manufacturer identification
Independently of consumer labelling, the manufacturer has identification duties relating to matters such as type, batch, serial number or another identifier, as well as contact details. This serves a different purpose from sorting labels.
11. How should the artwork process be prepared?
- identify all marking locations;
- reserve space for the harmonised label and QR code;
- control the artwork version;
- link material data to product lifecycle or product information management systems;
- provide translations;
- check e-commerce requirements;
- plan the transition of old packaging stock and change control.
12. Common mistakes
- reducing a legal deadline to a single date without checking the later-date rule;
- treating a supplier declaration as complete compliance evidence without linking it to the specific packaging;
- failing to manage design and documentation versions;
- confusing voluntary certification with a formal PPWR requirement;
- failing to update after a material, component, supplier or methodology change.
FAQ
Does the harmonised label apply from 12 August 2026?
No. Article 12 sets later deadlines, mainly from 2028 or later depending on the implementing acts.
Does a QR code replace the material label?
Generally, no. A QR code is an addition or a carrier for specific information under Article 12.
Does reusable packaging have a separate marking?
Yes. The PPWR provides for a separate label for reusable packaging and additional digital information.