Since 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR) has required a type, batch or serial number on packaging. The manufacturer’s name and postal address go on it too, or behind a QR code. The sorting label applies from the later of 12 August 2028 and 24 months after the labelling act enters into force. That act is pending.
Which marks apply now?
Packaging must carry a type, batch or serial number or other identifying element under Article 15(5). Where size or nature rules that out, it goes in a document accompanying the packaged product. Article 15(6) adds the manufacturer’s name, registered trade name or trademark and a single postal contact address, on the packaging or through a QR code or other data carrier. Importers add their own name and address under Article 18(3). Transport packaging has no exemption from these marks, and the traceability answer covers how far they go.
The labels still to come
| Label | Article | Applies from | Scope |
|---|---|---|---|
| Material composition label for sorting | 12(1) | 12 August 2028 or 24 months after the labelling act enters into force, whichever is later | Not transport packaging, except e-commerce, and not deposit return packaging |
| Reusable packaging label with QR code | 12(2) | 12 February 2029 or 30 months after the act enters into force, whichever is later | Open-loop systems without an operator are excluded |
| Recycled content and bio-based content labels | 12(4) | 12 August 2028 or 24 months after the act enters into force, whichever is later | Voluntary, but any such label must use the harmonised format |
| Deposit return label | 12(1), fourth subparagraph | No date of its own | The national label; a harmonised colour label is optional unless a Member State requires it |
| Extended producer responsibility (EPR) scheme symbol | 12(9) | Article wording: “By 12 February 2027” | Optional; if used, only inside a QR code or other digital marking, never as a printed logo |
What happens to the dates if the act is late?
The labelling act was due by 12 August 2026, and on 15 October 2026 the Commission’s consultation page still showed adoption planned for the fourth quarter of 2026. Example: if it enters into force on 1 March 2027, the sorting label applies from 1 March 2029 and the reusable label from 1 September 2029. Packaging made in the EU or imported before 1 March 2029 without the label could stay on the market until 1 March 2032, under Article 12(12).
Which labels are not allowed?
No label may mislead about properties that harmonised labels cover, under Article 12(8). The Commission’s guidance reads Article 12 as fully harmonised outside deposit return, so national sorting labels cannot sit beside the EU label once it applies. The Commission’s FAQ says deposit return packaging must carry the deposit label of each Member State where it is sold, because the PPWR has not harmonised that label. The deposit return answer covers the systems themselves.
Sources: Regulation (EU) 2025/40 (PPWR), Commission guidance document, C/2026/3084, European Commission initiative 19243, harmonised packaging labels, PPWR Frequently Asked Questions, 2nd edition
A review of current artwork against the marks that apply now is an early step in GreenSutra’s PPWR consulting. Label dates are tracked in the EU PPWR guide as acts are adopted.