Labelling Requirements: What Must Appear on the Packaging?
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) enters into force on 12 August 2026 and introduces concrete labelling obligations for virtually all companies placing packaging on the market. Any business that packages, imports or distributes products must ensure, from that date onwards, that its packaging bears the legally required information. This article explains what information the PPWR requires and what this means for your packaging design.
Mandatory Information from 12 August 2026
The PPWR establishes in Article 11 which information must be accessible either directly on the packaging or via a digital data carrier. The requirements apply to packaging made available on the EU market for the first time on or after the cut-off date.
1. Material Identification and Material Codes
Every packaging component (body, closure, label) must be marked with the corresponding material code in accordance with the harmonised EU standard. The coding follows the system established by Decision 97/129/EC, further specified through delegated acts of the Commission under the PPWR. Plastics retain their well-known numbers (1–7 with resin abbreviation); paper/cardboard, glass, metal and composite materials each receive their own codes.
2. Recyclability and Collection Stream
The packaging must clearly indicate whether it is recyclable and to which collection stream it belongs (e.g. lightweight packaging, paper/cardboard, glass, residual waste). The basis is the classification according to the recyclability classes defined in Article 6 of the PPWR. A further refinement of the classes is expected from 2028; for the cut-off date of 12 August 2026, the first tier of labelling obligations applies.
The specific presentation (symbol, text or both) will be governed by delegated acts that the European Commission must adopt before the cut-off date. Companies should monitor these acts closely, as they will prescribe the visual implementation in a binding manner.
3. Recycled Content in Plastic Packaging
For plastic packaging, the PPWR requires the declaration of the share of recycled content. The minimum quotas increase in stages: from 2030, quotas of between 10 % and 35 % recycled plastic will apply depending on the packaging category. The obligation to declare the recycled content exists regardless of whether the quota is already met — the actual percentage must be stated.
4. Digital Product Label (QR Code / Data Matrix)
Article 11(3) of the PPWR requires a digital data carrier to be affixed to the packaging. It must link to a publicly accessible digital information source containing at minimum the following:
- Complete material composition of the packaging
- Recyclability information per component
- Sorting and disposal instructions
5. Exemptions and Transitional Arrangements
The smallest packaging items (surface area below 10 cm²) are exempt from certain labelling requirements, provided the information is retrievable via the digital data carrier. For packaging produced and stocked before 12 August 2026, sell-through provisions apply; their exact duration will be set out in the delegated acts.
What You Should Do Now
Review your entire packaging portfolio against the new requirements. Coordinate with your packaging supplier on standardised material markings. Plan the technical infrastructure for the QR code (stable URL, multilingual content) at an early stage. For binding legal assessments of your specific situation, contact your local Chamber of Commerce and Industry or a lawyer specialising in packaging law.
Häufige Fragen
- From exactly when does the PPWR labelling obligation apply?
- The cut-off date is 12 August 2026. From that date, packaging newly made available on the EU market may only be placed on the market with the prescribed labelling. Stocks already produced are subject to sell-through provisions under the delegated acts.
- 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.
- Does every individual packaging component need its own material code?
- Yes, packaging bodies, closures and labels must each be marked separately, provided they consist of different materials and are easily separable. If a component is too small for direct labelling, the information may be made available via the digital data carrier.
- What if the recycled content in my plastic packaging is currently zero per cent?
- Even then, the share — i.e. 0 % — must be declared. The labelling obligation is independent of the actual value; it serves market transparency. The minimum quotas that must mandatorily be met come into force in stages only 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.
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