From exactly when does the PPWR labelling obligation apply?

Since 12 August 2026, four items are mandatory on packaging: company name or trade mark, postal address, unique packaging identifier, and an electronic means of contact (Art. 11(2) PPWR). More extensive requirements such as material codes, recycled content declarations or a mandatory QR code will follow once the European Commission adopts the required delegated acts, which have not yet been issued.

Does the PPWR also apply to small businesses and craft enterprises?

Yes, the Regulation applies in principle to all economic operators placing packaging on the EU market, regardless of company size. Individual delegated acts may provide for simplifications for micro-enterprises — check this for your specific sector.

Are harmonised material codes on packaging already mandatory today?

No. The obligation to label packaging with harmonised material codes (e.g. plastic numbers 1–7) is not yet in force. It depends on delegated acts of the European Commission that have not yet been issued. What is mandatory today are the four items under Art. 11(2): name/trade mark, postal address, packaging identifier, and electronic means of contact.

From when must I declare the recycled content on packaging?

The obligation to state the recycled content share for plastic packaging is not yet in force. It depends on delegated acts that the European Commission has not yet adopted. Mandatory minimum quotas for recycled content only apply from 2030.

Where can I obtain binding information for my specific case?

For legally binding assessments, contact your local Chamber of Commerce and Industry or a specialist lawyer in food and packaging law. The Chamber of Commerce and Industry offers free initial consultations and refers to sector-specific guidance from the competent authorities.

PPWR Knowledge

Labelling Requirements: What Must Appear on the Packaging?

Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026. From that date, four pieces of information are mandatory on packaging. More extensive requirements — harmonised sorting pictograms, material labelling, recycled content declarations and a mandatory QR code — only become applicable once the European Commission adopts the required delegated acts, which have not yet been issued. This article explains clearly what is required today and what is not.

See a worked example — how the labelling looks in practice

What Has Been Mandatory Since 12 August 2026 — Four Items (Art. 11(2))

Article 11(2) of Regulation (EU) 2025/40 requires four pieces of information on every packaging item placed on the EU market for the first time on or after the cut-off date. These can be printed statically — no technical infrastructure is needed.

1. Name of the company or trade mark

Full company name or registered trade mark of the responsible party (producer, importer or authorised representative). Anyone who places their name or trade mark on the packaging is deemed a producer under Art. 21 PPWR and assumes the obligations of Art. 15 (conformity assessment).

2. Postal address

Full contact address (street, city, country) of the responsible party — the company's business address, not necessarily the place of production.

3. Unique packaging identifier

A unique identifier that makes the packaging unit identifiable.

It has not yet been finally clarified whether it is sufficient for the packaging ID to be stored behind the QR code, or whether it must be legible directly on the packaging. We therefore recommend placing the individual packaging ID in the centre of the QR code — this covers both cases permanently.

4. Electronic means of contact

A permanently reachable electronic contact option — typically a website URL or an e-mail address. A telephone number alone does not satisfy this requirement.

What Will Be Added from 12 August 2028 (Art. 12)

From 12 August 2028, packaging must bear EU-harmonised sorting pictograms showing material composition and sorting instructions for consumers. The exact design of these pictograms will be specified by the Commission through delegated acts — which are still pending.

What Still Depends on Delegated Acts

The following requirements are foreseen in the PPWR but are not yet applicable, because the necessary delegated acts have not been adopted:

Harmonised material codes: The obligation to label packaging with material codes (plastic numbers 1–7 etc.) is not yet in force.
Recycled content declaration: The obligation to state the recycled content share for plastic packaging depends on delegated acts. Mandatory minimum quotas apply only from 2030.
Digital product label (QR code/Data Matrix): Art. 11(3) provides for a digital data carrier, but the technical specifications and entry-into-force date depend on delegated acts that have not yet been adopted.

Why a QR Code Still Makes Sense Today

The four mandatory items can be printed statically — that is sufficient under current law. Anyone already using a QR code with dynamically changeable content avoids reprinting an entire production run when delegated acts enter into force: the printed code stays the same; only the content of the linked page is updated.

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

Frequently Asked Questions

From exactly when does the PPWR labelling obligation apply?: Since 12 August 2026, four items are mandatory on packaging: company name or trade mark, postal address, unique packaging identifier, and an electronic means of contact (Art. 11(2) PPWR). More extensive requirements such as material codes, recycled content declarations or a mandatory QR code will follow once the European Commission adopts the required delegated acts, which have not yet been issued.
Does the PPWR also apply to small businesses and craft enterprises?: Yes, the Regulation applies in principle to all economic operators placing packaging on the EU market, regardless of company size. Individual delegated acts may provide for simplifications for micro-enterprises — check this for your specific sector.
Are harmonised material codes on packaging already mandatory today?: No. The obligation to label packaging with harmonised material codes (e.g. plastic numbers 1–7) is not yet in force. It depends on delegated acts of the European Commission that have not yet been issued. What is mandatory today are the four items under Art. 11(2): name/trade mark, postal address, packaging identifier, and electronic means of contact.
From when must I declare the recycled content on packaging?: The obligation to state the recycled content share for plastic packaging is not yet in force. It depends on delegated acts that the European Commission has not yet adopted. Mandatory minimum quotas for recycled content only apply from 2030.
Where can I obtain binding information for my specific case?: For legally binding assessments, contact your local Chamber of Commerce and Industry or a specialist lawyer in food and packaging law. The Chamber of Commerce and Industry offers free initial consultations and refers to sector-specific guidance from the competent authorities.

Stand: 17.08.2026 · geprüft von Erik Eggerth

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