Is a QR code on packaging really mandatory from 2026?

No — a QR code is not yet mandatory under current law. Article 11(3) of Regulation (EU) 2025/40 (PPWR) does provide that packaging should carry a digital data carrier linking to a publicly accessible information source. However, this article only becomes applicable once the European Commission has adopted the necessary delegated acts — including technical specifications, format requirements and transition periods. These acts have not yet been issued.

What applies today: The four mandatory items under Art. 11(2) (company name/trade mark, postal address, packaging identifier, electronic means of contact) have been binding since 12 August 2026. These can be printed statically — without a QR code.

Why a voluntary QR code still makes sense today: Anyone already using a QR code with dynamically changeable content avoids reprinting an entire production run when the delegated acts enter into force: the printed code stays the same; only the content of the linked page is updated.

For binding assessments of your specific situation, please contact your local Chamber of Commerce and Industry or a lawyer specialising in packaging law.