For producers, importers and retailers, the key question is: What labelling requirements does the PPWR introduce, when do they apply, and who is affected? The good news is that not all requirements will apply from 12 August 2026. Most harmonised labels will only become mandatory once the relevant EU implementing acts have been adopted.
There is also good news for businesses: national labelling requirements for disposal and sorting instructions, such as the French Triman logo, will ultimately be replaced by the PPWR’s harmonised EU labelling requirements. This will help standardise labelling across the EU and reduce the administrative burden. However, businesses should prepare early, as many types of packaging will need to be relabelled.
When do the new labelling requirements come into force?
The PPWR generally applies from 12 August 2026. However, most harmonised labelling requirements will apply from 12 August 2028, or 24 months after the relevant implementing acts enter into force – whichever is later.
For businesses, this means that while the legal framework applies from 2026, practical implementation of the harmonised labelling requirements will largely take place from 2028.
Material labelling for packaging
In future, most packaging must carry a harmonised label indicating its material composition. The aim is to help consumers sort packaging correctly and ensure it enters the appropriate collection and recycling systems.
The European Commission is developing a standardised EU-wide system based on easy-to-understand pictograms. This will gradually replace national solutions and harmonise waste sorting across the EU.
Exemptions apply, in particular, to transport packaging, packaging covered by deposit and return schemes and, under certain conditions, other types of packaging specified by the PPWR.
Standardised labelling of collection bins
Collection bins for packaging waste will also receive harmonised labels. These labels are intended to correspond with those on packaging, helping consumers immediately identify the correct bin and reducing incorrect disposal.
QR codes and digital labelling
The PPWR will increasingly rely on QR codes and other standardised digital data carriers. Depending on the application, these may provide information on material composition, correct disposal or other legally required details. For packaging containing substances of very high concern, the PPWR also provides for a standardised digital label.
Importantly, this digital information must serve the legally prescribed information purposes and may not be used for advertising.
Producer details on the packaging
The PPWR also expands producer labelling requirements.
From 12 August 2026, manufacturers must ensure that packaging bears their name or brand, postal address and means of electronic communication. Where this is not possible due to the size or nature of the packaging, the information may be provided via a QR code or another digital medium.
Packaging that has already been produced and is in stock but has not yet been placed on the market by 12 August 2026 does not need to be destroyed, reworked or relabelled.
Under Article 15(5) and (6), packaging must bear a unique identification number as well as the name and address of the producer. Where permitted, this information may be provided in an accompanying document. This also applies to reusable packaging already placed on the market.
For packaging produced after 12 August 2026, an accompanying document may only be used where it is not possible to affix the required information directly to the packaging. This is clarified in the EU PPWR FAQ of 31 July 2026, Chapter X, Question 5.
Importers are subject to similar labelling requirements.
Labelling in online retail
The PPWR introduces new requirements for distance selling. If required information is provided exclusively via a QR code or other digital medium, it must be accessible to consumers before they make a purchase in the online shop.
Companies should therefore ensure that their product pages are prepared in good time and provide all required information.
Which companies are affected?
The labelling requirements primarily concern packaging manufacturers. They apply to manufacturers from 12 August 2026 and, from 12 August 2028, also to producers. Depending on their role in the supply chain, importers, authorised representatives and other economic operators may also have obligations.
In principle, any company that places packaging on the EU market for the first time or markets it under its own name may be affected. This includes packaging manufacturers, retailers, private-label producers, importers and many online retailers.
Who supports companies in implementing the PPWR labelling requirements?
The new requirements affect more than the packaging itself. Product labels, disposal and separation instructions, user manuals and country-specific requirements may also need to be considered. This can be particularly challenging for companies selling across multiple EU Member States.
The trade-e-bility labelling check provides practical support by systematically checking existing product and packaging labelling for compliance. Depending on the requirements, the review can cover product labels, packaging labelling, disposal and disassembly instructions, as well as user manuals. Companies can request an EU-wide review or focus on individual target countries.
Especially in view of the PPWR, an early review is recommended. As many detailed requirements will only be established through future implementing acts, businesses can adapt their labelling step by step and avoid costly last-minute changes. The audit can also be combined with other product compliance services, such as marketability assessments, EU Declarations of Conformity and ongoing legal monitoring.
Is the labelling on my packaging compliant?
Would you like to know whether your packaging labelling complies with the applicable requirements? You can request your personalised labelling review via the Fast Lane, with no obligation.
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