Is a QR code on packaging really mandatory from 2026?

Yes – for certain packaging types, the machine-readable code becomes mandatory on 12 August 2026. Article 11(3) of Regulation (EU) 2025/40 (PPWR) requires that every package bears a data carrier providing access to the Digital Product Passport (DPP). The standard format is the GS1 Digital Link, which typically appears as a QR code on the packaging.

What must the Digital Product Passport contain? The regulation specifically mentions: material composition and recyclability, information on recycled content, guidance on correct disposal, and manufacturer and product identification data. The detailed scope of mandatory content will be further specified by delegated acts of the European Commission, expected by mid-2026.

The obligation does not apply uniformly to all packaging: small packaging with a principal display panel of less than 10 cm² and certain primary packaging for foodstuffs are subject to different rules. For transport and grouped packaging, partially relaxed requirements apply.

Important: 12 August 2026 is the date of entry into force of the framework regulation. Deviating transition periods for individual packaging categories may apply once the delegated acts have been adopted. Products lawfully placed on the market before the deadline may exhaust existing stocks.

For a binding assessment of whether your specific packaging falls under the QR code obligation, please contact your responsible Chamber of Commerce and Industry (IHK) or equivalent national authority.