PPWR labelling requirements: When do they apply, and what do companies need to do?

PPWR labelling requirements – an overview

The PPWR introduces new labelling requirements across the EU for packaging. These are intended to harmonise packaging information. Standardised labelling of packaging materials is designed to help consumers sort packaging correctly. Reusable packaging must also indicate that it can be reused and provide additional information via a QR code or another digital data carrier. Special rules apply to certain types of packaging, including some compostable packaging.

The PPWR labelling requirements affect many players across the supply chain. Producers, importers, distributors and e-commerce companies are all affected. Each of these parties may manufacture packaging, place it on the market under its own brand, import it, modify it or make it available for the first time.

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The PPWR labelling requirements include different obligations and deadlines. These cover harmonised packaging labelling under Article 12, identification and producer information under Article 15, and importer obligations under Article 18. As a result, different packaging types will need different labels from different dates.

What exactly do the PPWR labelling requirements mean?

Under the PPWR labelling requirements, affected companies must distinguish between different labelling requirements and information obligations. The requirements that apply to your company depend, among other things, on the packaging type, material, use and your company’s role. Not every piece of information has to appear on every package.

Material and sorting labels

In future, packaging will need to carry a uniform EU-wide label showing its material composition. The label is intended to tell consumers what material the packaging is made of and how to sort and dispose of it correctly after use. To provide this information, your company needs to know the full structure of its packaging, including coatings, labels and closures.

The PPWR Regulation has generally applied since 12 August 2026. However, the requirement to use a uniform EU-wide material label will not apply until 12 August 2028 or 24 months after the supplementary EU legal acts enter into force.

The labelling requirement also applies to e-commerce shipping packaging. It uses easy-to-understand pictograms. The European Commission has yet to decide exactly what these pictograms will look like. There are, however, two exceptions: Standard transport packaging does not need the label, but e-commerce shipping packaging does. Deposit packaging can keep its existing deposit labels. The European Commission may also set a uniform colour for these labels in future.

Labelling reusable packaging

Reusable packaging will also need a label to inform recipients that it can be reused. This requirement will apply no earlier than 12 February 2029 or 30 months after the implementing act enters into force. Further information, for example about the reuse system and collection points, must be made available via a QR code or another data carrier. An exception applies to certain open-loop systems without a system operator. Reusable packaging must be clearly distinguishable from single-use packaging.

Labelling compostable and other special types of packaging

Certain compostable packaging is subject to specific labelling requirements. It must be labelled as compostable. The label must also state that it is not suitable for home composting and must not be discarded in nature.

Additional special rules apply to certain substances and products. These include recycled content, bio-based plastics and substances of concern, as well as medicinal products and medical devices.

When do the PPWR labelling requirements apply?

The PPWR labelling requirements will take effect in stages. The PPWR has generally applied since 12 August 2026. However, some labelling requirements will take effect later. The European Commission will still set out the details of the pictograms and formats in separate implementing acts. Delegated acts may also supplement or amend other non-essential PPWR rules. For labelling, the implementing acts are decisive. If they enter into force later, any deadlines linked to them will also be postponed.

General date of application of the PPWR vs. specific labelling deadlines

• 11 February 2025 – The PPWR Regulation officially enters into force.
• 12 August 2026 – The PPWR generally applies. The ban on misleading labels, identification and manufacturer information requirements, and rules on environmental claims take effect.
• 12 August 2026 – The European Commission must specify, by means of an implementing act, what the harmonised label will look like and which method must be used to indicate material composition.
• 12 February 2027 – In areas with an EPR system, packaging may voluntarily indicate that the producer responsibility requirements have been met. If this indication is used, it must be provided digitally via a corresponding symbol.
• 12 August 2028 (or 24 months after the implementing acts enter into force, if later) – Harmonised material and sorting labels become mandatory. If recycled content is stated, it must be labelled in accordance with the EU specifications.
• 12 February 2029 (or 30 months after the implementing act enters into force, if later) – Reusable packaging must carry the reusable packaging label. Further information must be provided via a QR code or another digital data carrier.
• 1 January 2030 – The European Commission must specify the method for labelling substances of concern by means of an implementing act.

The deadlines of particular importance to your company are 12 August 2026, 12 August 2028 and 12 February 2029. The other dates are deadlines for the European Commission or apply only to certain types of packaging.

What applies to existing packaging and stock?

The PPWR Regulation includes a transitional provision for existing packaging and stock. It covers packaging manufactured or imported into the EU before the labelling deadlines expire that does not meet the new criteria. This packaging may continue to be placed on the market for up to three years after the labelling requirements take effect.

Who is affected by the PPWR labelling requirements?

The PPWR labelling requirements that apply to producers, suppliers, manufacturers and importers depend on their respective role and the packaging concerned.

Which types of packaging should companies check?

Different requirements apply to different types of packaging. Your company should bear in mind that packaging may fall into more than one category. The PPWR links each requirement to the packaging type, material and role in the supply chain. You should therefore determine your company’s role for each type of packaging and identify which labels or evidence you need to provide.

Sales and product packaging:

This packaging forms a sales unit with the product for the end user.

• Who places it on the market?
  The company that first makes the sales packaging available on the Union market. Depending on the supply route, this may be the packaging supplier, the brand owner or, for imports from non-EU countries, the EU importer.
• What information must the responsible party be able to document?
  The responsible parties must keep the technical documentation and EU declaration of conformity available. They also need information about the material composition and packaging components. Suppliers must provide the required information.

Grouped packaging:

This type of packaging groups sales units together and can be removed without affecting the product’s properties.

• Who places it on the market?
  It is placed on the market by the company that first makes this grouped packaging available. If it is supplied empty, this may be the packaging supplier; for imports from non-EU countries, it is the EU importer.
• What information must the responsible party be able to document?
  The responsible party needs material data for the grouped packaging itself. If labelling individual packages is not possible or practical, the label may also be placed on the grouped packaging.

Transport packaging:

This packaging facilitates the transport and handling of sales units and is intended to prevent product damage. However, containers used for road, rail, sea and air transport are exempt.

• Who places it on the market?
  It is placed on the market by the company that first makes this specific packaging available. If the packaging is empty, this may be the packaging supplier; for imports from a non-EU country, it is the EU importer.
• What information must the responsible party be able to document?
  The harmonised material labelling generally does not apply to transport packaging. However, this exemption does not cover e-commerce packaging. Identification and producer information must still be checked.

E-commerce packaging:

This is transport packaging used for deliveries to end users following online sales or other distance sales.

• Who places it on the market?
  The key question is who first makes this shipping packaging available on the Union market. The online retailer is not automatically the first supplier simply because it uses the packaging for shipping. If the packaging is imported from a non-EU country, the responsible party is the EU importer.
• What information must the responsible party be able to document?
  Material labelling also applies to this type of packaging. In addition, labelling information must be available before purchase when products are sold online.

Reusable packaging:

This is packaging that can be reused multiple times for the same purpose.

• Who places it on the market?
  The company that first makes the specific reusable packaging available on the Union market. For imports from a non-EU country, this is the EU importer.
• What information must the responsible party be able to document?
  The packaging needs a label indicating that it is reusable. An open digital data carrier must provide information about the reuse system, collection points and reuse cycles. If it is not possible to calculate the number of cycles, an average estimate is sufficient. Reusable sales packaging must be distinguishable from single-use packaging at the point of sale.

Food packaging:

Food packaging is not a separate labelling category. Instead, you must also classify it as sales, grouped, transport or e-commerce packaging.

• Who places it on the market?
  The company that first makes it available on the Union market based on this classification. For imports from a non-EU country, this is the EU importer.
• What information must the responsible party be able to document?
  In addition to PPWR material data, you must meet the requirements for materials intended to come into contact with food. The relevant documentation may form part of the PPWR evidence.

Materials and composite packaging:

Material labelling applies to the packaging covered by Article 12(1). As a rule, transport packaging is exempt, but e-commerce packaging and packaging covered by deposit and return systems are not. Deposit packaging remains subject to the existing national deposit labelling.
Composite packaging consists of several materials that form a single unit and cannot be separated by hand.

• Who places it on the market?
  The company that first makes the relevant packaging, empty or filled, available on the Union market. For imports from a non-EU country, this is the EU importer.
• What information must the responsible party be able to document?
  The producer needs information about the material composition and components. Suppliers must provide the required information and documentation. The method and pictograms will be set out in the implementing acts.

Certain compostable packaging:

This may include permeable tea and coffee bags, permeable bags for other beverages, and single-portion units that soften during use.

• Who places it on the market?
  The company that first makes the relevant packaging available on the Union market. For imports from a non-EU country, this is the EU importer.
• What information must the responsible party be able to document?
  The producer needs technical information about compostability. The label must state that the packaging is compostable, is not suitable for home composting and must not be discarded in nature.

The specific first supplier therefore varies by packaging type. It can only be determined by looking at the packaging concerned and the actual supply route.

What information must packaging labels include?

Which material and sorting information is relevant under the PPWR labelling and information requirements? What rules apply to placing labels, and when can a digital data carrier be used?

Material composition and sorting information

The label is intended for consumers and waste management systems. It shows what material the packaging is made of and how it can be sorted. However, labelling material composition is not the same as making a claim about recyclability. The PPWR already prohibits labels, symbols or wording that could mislead or confuse consumers about sorting and disposal options.

The PPWR also requires producer information. Every package needs a type, batch or serial number or another identifying feature. If this is not possible because of the package’s size, the information must be included in accompanying documents. The producer must also provide mandatory information: name, trade name or brand, and postal address. If this information cannot be provided on the packaging, accompanying documents or a digital data carrier may be used.

Visibility, legibility and placement

Labels must be clearly visible, legible and firmly affixed. They must not be easy to remove. If this is not possible or practical on the packaging itself, you can place the information on the grouped packaging instead. If that is not suitable either, you can provide the information via an electronically readable code.

You must provide this information in a language that end users can easily understand. The Member State for the relevant market determines which language to use. Your company should check this separately for each destination country.

QR code or digital data carrier – requirement or option?

There is no general requirement to use a QR code. Sorting pictograms are intended to appear physically on the packaging. You may voluntarily add a QR code showing the destination of individual packaging components.

A digital data carrier is mandatory in certain cases:

• for reusable packaging from 2029,
• for packaging containing substances of concern,
• as a fallback when information cannot be physically affixed.

For digital information, two rules apply: Personal data may only be collected to the extent necessary. The information must not appear alongside marketing content.

PPWR, VerpackG, LUCID and the Green Dot: what is the difference?

PPWR labelling does not replace LUCID registration or system participation. These obligations remain separate.

How leadity supports structured PPWR implementation

The PPWR Regulation requires one thing above all: organisation. Yet packaging data, responsibilities, deadlines and evidence are often spread across procurement, product development and quality management. Bringing them together in one place helps you spot outstanding requirements earlier. Our PPWR software helps you centralise packaging data, manage evidence in a structured way and implement regulatory requirements more efficiently.

With leadity, you gain:

• A central packaging database for your packaging and material data.
• Simpler preparation of technical documentation for various PPWR requirements, such as material composition, labelling and reusability.
• A central system for preparing declarations of conformity (DoC) in line with PPWR requirements.
• Structured document and evidence management for supplier documents, certificates and declarations.
• the integration of packaging data from existing systems.

Conclusion: Prepare systematically for labelling requirements

The PPWR labelling requirements cannot be dealt with by simply adding a label to each package. Instead, you need to consider packaging types, roles, deadlines and evidence together. Organising these four areas early helps you adapt design, procurement and compliance processes in good time and avoid unnecessary costs and extra work. You do not need to print a new pictogram on every package today. But you should know which of your packages will be affected by the PPWR Regulation in 2028 and 2029.