May I design the QR code on the packaging in colour or with a logo?

Regulation (EU) 2025/40 does not prescribe a specific colour or uniform design for the PPWR QR code – it is formulated in a technology-neutral manner. You are generally permitted to design the code in colour or embed a logo in the centre, provided that scannability is guaranteed.

Three mandatory technical criteria are decisive:

Contrast: Sufficient luminance contrast must exist between the dark elements (finder patterns, data modules) and the background. The common recommendation is a ratio of at least 4:1; light modules on a white background or dark modules on a black background are not permissible.

Minimum size: The QR code must be machine-readable – in practice, a minimum size of 10 × 10 mm is considered the lower limit for standard commercial scanners. Smaller areas increase the risk of read errors significantly.

Quiet zone: A white border of at least four module widths must be maintained around the code. Logos or coloured areas encroaching on this zone can render the code unreadable.

Logo embedding is technically feasible because QR codes have a built-in error correction capability (level M or H recommended). The logo must not cover more than approximately 30 % of the code area.

From the deadline of 12 August 2026, all affected packaging must comply with the requirements of Regulation (EU) 2025/40. Non-scannable codes are treated as missing labelling and may trigger sanctions.

For a binding assessment of your specific packaging design, please contact your responsible Chamber of Commerce and Industry.