Do I need a GS1 code (EAN/GTIN) on the packaging for PPWR compliance?

Regulation (EU) 2025/40 does not prescribe a GS1 code (EAN/GTIN) as a direct obligation. What becomes mandatory as of 12 August 2026 is the application of a machine-readable data carrier containing the required product information — for example material composition, recycled content share and manufacturer details. The Regulation initially leaves open which technical format this data carrier must take.

Where GS1 nonetheless becomes relevant: through the so-called Sunrise 2027 programme, GS1 is planning the global transition to the GS1 Digital Link as the universal data carrier standard. From 2027 onwards, many retail point-of-sale systems and scanner installations will only be able to read GS1-compliant codes. Anyone using a proprietary QR code or Data Matrix code without a GS1 basis today risks incompatibilities in the checkout process from that point — particularly in the food and consumer goods trade.

A GS1 Digital Link is advisable if you distribute your products through brick-and-mortar retail or via platforms that use point-of-sale systems with mandatory GS1 scanning, or if you wish to combine the PPWR data carrier requirement and checkout compatibility in a single code. For purely B2B supply chains without end-consumer scanning, the urgency is lower.

For a binding legal assessment of whether your specific product triggers additional labelling obligations, please contact your competent Chamber of Commerce and Industry (IHK).