PPWR: labelling and QR code obligations for packaging

What the PPWR governs - and since when

The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It entered into force on 11 February 2025 and has applied generally since 12 August 2026 - as confirmed by the European Commission on its topic page for packaging waste, which announced the start of application in August 2026 separately. The PPWR replaces Packaging Directive 94/62/EC. The difference is more than formal: a regulation applies directly in every member state, without a national implementing law.

Since 12 August 2026 packaging has been treated in regulatory terms like a product. What applies includes:

• Substance restrictions (Article 5): lead, cadmium, mercury and hexavalent chromium together at no more than 100 mg/kg; for food-contact packaging, strict PFAS limits in addition.
• Proof of conformity: technical documentation and an EU declaration of conformity - for the packaging, not just for the packaged product.
• Producer information (Article 15): name or brand, postal address and an electronic means of contact, plus a type, batch or serial number to identify the packaging.
• Ban on misleading claims: no symbols or wording that mislead about material properties, sustainability or disposal routes.
• Registration and platform obligations: producers have to be entered in the national registers, and online marketplaces have to verify this.

What does not apply since August 2026 is, of all things, what most people associate with the PPWR: the uniform sorting label and the QR code on the packaging. Both are still outstanding.

PPWR labelling is not a Digital Product Passport

This confusion is the most common error of reasoning in practice. Both instruments work with QR codes, both aim at the circular economy, both come from the Green Deal - but they govern different objects:

• The Digital Product Passport under the Ecodesign Regulation (EU) 2024/1781 describes the product: materials, origin, repair information, certificates, circularity.
• PPWR labelling describes the packaging: material composition, correct waste stream, reusability.

A T-shirt in a shipping box may therefore end up carrying both: the DPP data carrier on the product and the PPWR labelling on the polybag and box. Two legal acts, two deadline logics, two chains of responsibility.

Which role your company takes on for the product passport is clarified in the guide Who is responsible for the DPP?; the fundamentals of the underlying regulation are explained in ESPR explained.

Which labelling obligations apply

Article 12 of the PPWR bundles the labelling requirements and staggers them over several years:

Separately from this, Article 13 governs the labelling of waste collection containers. That is a task for the member states, not for brands - the aim being that the same pictogram appears on the packaging and on the bin.

The QR code on the packaging

There is currently no general QR code obligation for packaging - that is the most important correction to a lot of market information. The PPWR provides for digital data carriers in clearly defined cases:

• Reusable packaging has to carry a QR code or another standardised, open data carrier from 12/02/2029 at the earliest, providing information on the reuse system, return points and traceability.
• As a complement to the sorting label, a QR code can indicate where the individual packaging components belong. The details are set by the implementing act.
• Producer information may be provided digitally where the packaging is physically too small for printing.
• Producer responsibility symbols may be provided exclusively digitally from 12/02/2027.
• Substances of concern are to be indicated via a standardised, open digital labelling technology.

Important for planning: if packaging already carries a QR code because of other EU legal acts, that code should be used as well and not duplicated. One data carrier, several layers of information - which is an argument for holding product and packaging data in a single data base from the start rather than in two projects.

The overdue implementing act

Here the honest answer begins. The harmonised label - pictograms for material composition and separate collection, intended to replace the old codes under Decision 97/129/EC - does not yet exist. The European Commission was obliged to adopt the corresponding implementing act (Article 12(6) and (7) as well as Article 13(2)) by 12 August 2026. That deadline has passed. As at 3 September 2026 the act has not been published; the Commission points to an additional need for coordination with stakeholders, and no publication date has been given.

The legal consequence is unambiguous - and a relief for companies. Article 12(1) ties the obligation to “12 August 2028 or 24 months after the entry into force of the implementing act, whichever is later”. The clock therefore only starts on publication: every month of delay in Brussels shifts the binding key date back by the same month, and the two-year changeover period remains fully intact. Nobody has to label to a standard that does not exist.

From this follows an inconvenient but useful rule: anyone selling you finished PPWR pictograms, binding layout specifications or a guaranteed key date today is selling you an assumption. A technical proposal from the Joint Research Centre (JRC) of January 2026 is circulating in the industry, but it is not legally binding and may still change in the final act.

What applies to online retailers and shipping packaging?

For Shopify and e-commerce retailers three points are decisive.

First: you are often the producer yourself. Anyone who fills shipping boxes and dispatches goods is responsible for that packaging in regulatory terms. The declaration of conformity, producer information and register entry are down to you, not to your box supplier. Contractual arrangements can distribute the costs, not the obligation.

Second: shipping packaging is not exempt. Transport packaging is partly exempt from the future material label - e-commerce packaging, by contrast, is expressly covered. Anyone regarding the box as a purely logistical shell underestimates its regulatory status.

Third: the empty space ratio. Article 24 limits empty space in grouped, transport and e-commerce packaging to a maximum of 50 per cent. The limit applies from 1 January 2030, or three years after the entry into force of the calculation rules that the Commission has to present by 12 February 2028. Filling material such as air cushions, paper or chips does not count as filled space. Adapting box sizes is a range and logistics project, not a labelling project - anyone starting on it in 2029 is starting too late.

How the distance selling information obligations for the product passport differ from this is shown in the guide DPP in e-commerce.

What brands should do now

1. Take stock of your packaging. Which packaging types do you use, made of which materials, in which quantities, from which suppliers? Without this list none of the following obligations can be planned.
2. Work through the obligations that have applied since 12/08/2026. Producer information, identification number, declaration of conformity, register entry - that is applicable law and is not deferred by the missing implementing act.
3. Review old symbols. Printed EPR symbols have to disappear from the packaging by 12/02/2027, and the material codes under 97/129/EC will expire later. Both already affect current printing and procurement cycles.
4. Capture material data cleanly. The material composition per packaging component is the data basis for the coming label - and you need it in the same quality for the product passport.
5. Monitor the implementing act rather than guessing. Set a reminder and plan on the basis of 24 months from publication. For your own DPP deadlines the ESPR deadline checker will help; small teams will find a leaner approach in the SME roadmap.

One closing note: this article is intended for orientation and does not replace legal advice - assessing your specific packaging belongs in expert hands.

And to be clear about our own position: SolveDPP covers the Digital Product Passport, not packaging labelling. You will not be generating PPWR pictograms in our app. What overlaps is the data basis - material composition, supplier information, recycled content and origin are the same work for both sets of rules. Anyone who is structuring this data for the Digital Product Passport anyway has already done the most laborious part for PPWR labelling. Which product groups are up when is shown in the deadline overview.