PPWR Harmonised Packaging Labelling (2028)

The Packaging and Packaging Waste Regulation (PPWR, (EU) 2025/40) has applied since 12 August 2026. Its most visible change, however, has not arrived yet: the harmonised packaging label. The label that tells consumers which bin a package belongs in comes 42 months after the regulation's entry into force — around August 2028 — through implementing acts, and is set to replace national schemes such as France's Triman and Italy's environmental labelling.

Our article on packaging, PPWR and the DPP covers the regulation's general framework; here we focus only on the labelling rule, its timeline and its link to the Digital Product Passport.

The PPWR timeline

What stays on the label, what can go digital?

The label exists for sorting: it shows the packaging's material composition in the same visual language as the matching mark on the waste receptacle. The core information — material class and sorting pictogram — therefore stays printed on the packaging. The regulation allows some additional information to be provided through a QR code or another digital carrier; return points and reuse-system information on reusable packaging are the typical example. Which elements must stay printed and which may move to digital will be clarified by the implementing acts.

We see the same "printed core, digital detail" split in the digital labelling of the CLP revision and the digital label under the Detergents Regulation. For a producer of chemical products, packaging can create a third QR demand on the same surface, which is why the carrier strategy should be decided per product family.

One QR or two?

Should the product passport QR and the packaging label QR be the same square? Three principles:

1. The passport carrier must be on the product. Packaging is thrown away; for a passport that must stay reachable for the product's lifetime, packaging cannot be the only carrier. Our article on DPP QR code design covers this trap in detail.
2. A QR on the packaging can describe the packaging. Pointing to the packaging record, a return point or sorting information is natural.
3. Two targets can share one carrier. GS1 Digital Link defines several link types for one identifier; the same code can route to the passport or to packaging information as requested. That routing is the job of the resolver service.

The practical rule: a passport QR on the product; the harmonised label on the packaging plus, if needed, a second code to packaging information — or a single code with a resolver.

Where packaging data sits in the passport

Packaging is not the product, so its data does not go into the product passport's composition fields. A separate packaging record linked to the product record holds it: material per component (body, closure, label, ink, adhesive), recyclability grade, recycled-content share and its evidence, reusability, and the harmonised label code. The same record feeds the eco-modulation of EPR fees; as we explain in extended producer responsibility, better-designed packaging pays lower fees. For plastic packaging, recycled-content evidence rests on a supplier certificate; our article on the DPP for plastics and polymers describes that chain.

What to do before 2028

1. Build a component-level material inventory of your highest-volume packaging formats.
2. For each format, note today's national labels (Triman and the like) and the post-2028 transition; artwork changes must be planned with your packaging supplier.
3. Estimate the recyclability grade and flag the formats that need a design change.
4. Link the packaging record to the product record; decide the QR strategy (one code or two) per product family.
5. Follow the draft implementing acts; the method in how to read a draft delegated act works for implementing acts as well.

For carrier and access rules see the EN 18220 section of the standards guide.

Frequently asked questions