PPWR labelling requirements: What must be on the packaging since 12 August 2026 and what is only coming in 2028

"Labelling obligation 2026" is among the most searched-for terms around the EU Packaging Regulation, and almost every enquiry rests on a misunderstanding. The Regulation contains two different things, both of which are referred to as labelling. The details under Article 15, that is the identification and the name and address of the manufacturer, have applied to every packaging since 12 August 2026. The harmonised labelling under Article 12, that is sorting pictograms, the reusable packaging label and the QR code, arrives on 12 August 2028 at the earliest, and because the Commission has not yet adopted the associated implementing acts, probably later.

Anyone who mixes the two up either invests too early in new print templates or overlooks the fact that their packaging has carried no manufacturer details since August. This article works through the provisions along the text of the Regulation: what has applied since 2026, what is coming in 2027, 2028 and 2029, what the QR code must and may do today, and what the German Packaging Implementation Act makes of it. At the end there is a roadmap with a checklist to download.

Two obligations, two dates

The Regulation governs labelling in Chapter III (Articles 12 to 14) and the economic operators' details in Chapter IV (Articles 15 to 21). Both chapters have applied since 12 August 2026, but Article 12 contains its own, later dates for its most important paragraphs.

The practical consequence: 2026 is a year of data, not of artwork. Anyone designing pictograms now is designing them on spec, because the symbols are not yet fixed.

What has had to appear on the packaging since 12 August 2026

Article 15(5) requires that packaging bear "a type, batch or serial number or other element allowing its identification". Where this is not possible because of the size or nature of the packaging, the information "in a document accompanying the packaged product" is sufficient. Paragraph 6 additionally requires the name, registered trade name or registered trademark of the manufacturer, its postal address and, where available, an electronic means of communication, in each case "on the packaging or on a QR code or another data carrier". The postal address must indicate a single point of contact at which the manufacturer can be reached. Paragraph 7 requires that the information be clear, understandable and legible and that it neither replace nor obscure mandatory information under other legal acts.

Three clarifications by the Commission from the FAQ of August 2026 take the sting out of the obligation:

The identification means the type, batch or series, not the individual item. According to FAQ X.8, it serves to link the packaging with the technical documentation and the declaration of conformity. Batch numbers are sufficient; standard items such as adhesive tapes, neutral bags or desiccant bags are traced at production batch level. Manufacturers may choose freely between type, batch and serial number (Commission FAQ, section X).

One component is enough. For a packaging unit consisting of several parts, such as cup, lid and sleeve, the information on one component suffices.

The accompanying document is the fallback route. Whether affixing is possible is assessed case by case according to dimensions, shape and function. For packaging produced before 12 August 2026 and sitting in the warehouse, the identification and manufacturer details may likewise be provided by accompanying document; nobody has to relabel stocks (FAQ X.5 and X.7 of the second edition).

Who must affix the information is decided by the manufacturer role. For sales and grouped packaging this is as a rule the filler or the brand owner, for unmarked dimensionally stable transport packaging the maker of the packaging. Suppliers of empty packaging are not caught by the obligation; the Commission points out, however, that in practice they will often take on the marking, because it is easiest to affix during production (FAQ II.3). Importers additionally indicate their own name and address under Article 18(3), if need be on the data carrier under Article 12 or in accompanying documents. Importers and distributors placing packaging on the market under their own brand are themselves considered manufacturers under Article 21; their name must then go on the packaging. The role logic in detail: Manufacturer or producer? Which role your company has under the PPWR.

Under Article 19(2), distributors verify before making available that the manufacturer and the importer have affixed this information, and otherwise do not make the packaging available (paragraph 3). For retail, this is the point at which the manufacturer details become a purchasing condition.

What is already no longer allowed on packaging

Less noticed than the mandatory information, but in force since 12 August 2026: Article 12(8) prohibits all economic operators from providing labels, symbols or inscriptions that could mislead or confuse "consumers or other end users with respect to the sustainability requirements for packaging, other packaging characteristics or packaging waste management options". In FAQ VIII.2, the Commission refers to Directive (EU) 2024/825 on empowering consumers: misleading is whatever causes consumers to take a decision they would not otherwise have taken. The Packaging Implementation Act sanctions infringements of Article 12(8) as an administrative offence (Section 66(2) number 2 VerpackDG).

Added to this is Article 14, which has likewise applied since August: environmental claims about packaging properties for which the Regulation lays down requirements may only be made if they go beyond the applicable minimum requirements and are in line with the criteria, methodologies and calculation rules of the Regulation. In addition, the claim must specify whether it relates to the packaging unit, a part of it or to all of the company's packaging. Compliance must be demonstrated in the technical documentation. A blanket "recyclable" without reference to the assessment method of Article 6, which does not yet exist, is therefore a risk, not a selling point.

In practice this means: anyone who today prints recycling symbols, percentage figures for recycled content or climate claims on packaging should be able to substantiate every single one and use the voluntary nature of these statements to shed ballast before new templates arrive in 2028 anyway.

What applies from 2027: EPR symbols in digital form only

The first new date after the date of application is 12 February 2027. From then on, packaging that falls under an extended producer responsibility scheme may still be labelled, but "only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology" (Article 12(9)). In its guidance, the Commission reads this as a prohibition of physical EPR labelling. For Germany, this affects marks such as the Green Dot (Grüner Punkt), which indicates system participation: on this reading, as a printed logo it is no longer permitted from 12 February 2027, while as a symbol in a QR code it still is. The system operators have announced corresponding digital labels. Anyone who has print templates featuring the Green Dot should factor the date into the next artwork round.

Not affected are the material identification numbers and abbreviations under Decision 97/129/EC, in other words the numbers and abbreviations in the triangle. Under Article 70 of the Regulation, they remain valid until 12 August 2028. In Germany, Section 4 VerpackDG provides that packaging may be labelled for material identification with the numbers and abbreviations laid down in Annex 2 and that other numbers for the same materials are not permitted. Their use remains voluntary.

What comes from 2028: the harmonised sorting labelling

Article 12(1) requires that packaging placed on the market be "marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting". The labelling is based on pictograms and must be easily understandable, including for persons with disabilities. Compostable packaging under Article 9 must additionally indicate that the material is industrially compostable, is not suitable for home composting and does not belong in nature.

The date is a formula: "from 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7, whichever is the latest". The Commission was required to adopt these acts under paragraphs 6 and 7 by 12 August 2026. As of September 2026 it has not done so; the Joint Research Centre published a technical proposal in January 2026, and the Commission's draft is expected after the summer. It is therefore certain that 12 August 2028 cannot be met: the obligation begins 24 months after the entry into force of the legal act, in other words at the end of 2028 at the earliest. Do not rely on calendars in guides that cite 12 August 2028 as a fixed date.

Two groups are exempt from the sorting labelling: transport packaging, with the exception of e-commerce packaging, and packaging subject to a deposit and return system. The industrial pallet does not need the pictogram; the shipping carton to the end user does. What this means for everyday B2B business is set out in Does the PPWR apply to B2B? Transport packaging, pallets, stretch film, strapping and used cartons. Under paragraph 11, Article 12 does not apply to the immediate and outer packaging of medicinal products, medical devices and in vitro diagnostics where there is no space or where the labelling could jeopardise safe use.

Two rules ease the transition. First, under Article 12(12), packaging manufactured in the Union or imported before expiry of the deadline may still be made available for up to three years after the entry into force of the labelling requirements. Second, the labelling is fully harmonised: the Commission makes clear in its guidance that after the cut-off date Member States may no longer require national sorting instructions alongside the EU label and should repeal disproportionate national requirements even before then. Anyone printing different sorting instructions for several countries today will have a single system from 2028.

Voluntary, but likewise harmonised, from the same date are the labels for recycled content and for biobased plastic content (paragraph 4). No one has to print the recycled content on the packaging; anyone who does must use the harmonised specifications and the calculation methodology under Article 7(8).

QR code: from when it is mandatory, and what must go into it

The question about the QR code has four different answers, depending on which provision is meant.

Since 12 August 2026, the QR code has been permitted to carry the manufacturer details. Article 15(6) expressly allows the name and address "on a QR code or another data carrier". It is not mandatory for this purpose; the details may still be printed.

From 12 February 2027, the QR code is the only permissible place for EPR symbols (paragraph 9).

From 2028, the QR code remains a voluntary addition for the sorting labelling. Paragraph 1 allows a QR code with information on the destination of each packaging component to be placed "in addition to the harmonised label". The pictograms themselves must be physically on the packaging.

From 12 February 2029 or 30 months after the implementing act, the QR code becomes mandatory for reusable packaging. Such packaging must bear a label that provides information on its reusability, and must make further information on reuse systems and collection points available "through a QR code or other type of standardised, open, digital data carrier" that facilitates tracking and the calculation of rotations (paragraph 2). Open loop systems without a system operator are exempt from this (paragraph 3).

The requirements of paragraph 5 apply to all digital labelling: clearly visible, clearly legible and firmly affixed; in online sales the information must be accessible before the purchase; it is provided in the languages determined by the Member State; personal data may be collected only for the purpose of providing the compliance information, and the information must not be displayed together with sales or marketing content. Where other Union law requires a data carrier for the product, such as the digital product pass, a single common data carrier is to be used. Anyone who points their QR code at a marketing landing page today will have a problem in 2029.

Added to this are the substances of concern. Packaging containing such substances is marked "by means of standardised, open, digital-marking technologies" (paragraph 1, second subparagraph), in accordance with a methodology that the Commission will lay down by 1 January 2030 and that must cover at least the name and concentration per material (paragraph 7). Which substances these are is the subject of the ECHA report announced in the FAQ.

What German law adds

The Packaging Implementation Act does not add a labelling obligation of its own to the Regulation, and under the guidance document it may not. Three points remain national:

The deposit labelling. First distributors placing single use beverage packaging subject to a deposit on the market must label it under Section 46(1) sentence 3 VerpackDG "in a permanent, clearly legible manner and in a clearly visible place as subject to a deposit". The Regulation exempts packaging subject to a deposit from the harmonised sorting labelling and permits national deposit labels, supplemented by a harmonised colour labelling that the Member States may prescribe (Article 12(1) fourth subparagraph). According to FAQ VIII.3, for imports from other Member States the deposit label of the country of destination applies.

The information signs in retail. Under Section 47 VerpackDG, final distributors draw attention to the characteristics of beverage packaging at the point of sale and in distance selling with the words "EINWEG" (single use) and "MEHRWEG" (reusable), in a font size at least equal to that of the price labelling. That is an obligation at the shelf, not on the packaging.

The sanctions. A missing identification or missing manufacturer details are administrative offences under Section 66(2) numbers 5 and 6 VerpackDG, misleading labels under number 2. For these cases the fine under Section 66(3) is up to 10,000 euros per case. The real lever is a different one: distributors may not make packaging available without these details, and market surveillance can order corrective measures.

The most common mistakes

1. Confusing 2026 with 2028. Designing pictograms now, before the implementing act lays them down, or conversely forgetting the manufacturer details because "the labelling only arrives in 2028".
2. Planning 12 August 2028 as a fixed date. The 24-month period starts with the legal act, which is still outstanding in September 2026.
3. Affixing only the food information. The name and address under the Food Information Regulation do not automatically fulfil Article 15, because they name the food business operator, not necessarily the manufacturer of the packaging.
4. Taking supplier details for your own. If the name of the carton maker is on the box, that does not constitute the manufacturer details when you are the manufacturer.
5. Overlooking the Green Dot in 2027. From 12 February 2027, physical EPR symbols may appear only in the QR code.
6. "Recyclable" without a method. Since August, environmental claims have needed evidence in the technical documentation and a reference to the rules of the Regulation.
7. Coupling the QR code to marketing. Digital labelling must not be displayed together with sales or marketing content.

How to proceed in practice

1. Clarify the manufacturer role for each packaging. Only the manufacturer owes the identification and manufacturer details under Article 15; importers owe their own under Article 18. Anyone who is a supplier does not have to affix anything.

2. Take stock of your print artwork. Which packaging bears the identification and manufacturer details, which only the supplier, and which nothing at all? Prepare accompanying documents for existing stock.

3. Determine the central address. Article 15(6) requires a single point of contact. For groups with several plants, that is a decision, not a formality.

4. Review symbols and claims. Check every recycling symbol, every percentage figure and every environmental claim against Article 12(8) and Article 14; remove whatever cannot be substantiated. Move the Green Dot into the QR code by February 2027.

5. Record the material composition per component. The sorting labelling from 2028 is based on the material composition. Anyone who has it available today per component with shares by weight will only have to print an additional pictogram in 2028 instead of recording an entire product range from scratch.

6. Determine your QR strategy. One data carrier for the manufacturer details, the EPR symbol, later the sorting information, the reuse information and the product pass, kept separate from marketing content.

How Polygon One helps

Polygon One keeps the labelling obligations where they belong: in the obligations catalogue of each packaging unit. For manufacturer units, the obligation to provide identification and manufacturer details has been listed since 12 August 2026, together with the note that it can be fulfilled at type or batch level; for importer units, the reminder of the importer's own details under Article 18. The sorting labelling under Article 12 is recorded as a future obligation and blocks neither the technical documentation nor the declaration of conformity.

The foundation for 2028 emerges as a by-product: because the platform records the material composition of each component with mass fractions, the data for the harmonised labelling is available as soon as the Commission lays down the pictograms. What Polygon One does not do: design labels, check print templates or assess environmental claims legally. It holds the data from which you derive this with your agency or your packaging supplier.

If you would like to see how your packaging with its obligations looks in this structure, book a demo or read more on the product page for the PPWR module.

Download the roadmap

The roadmap brings together all labelling obligations with legal basis, date, exemptions and responsibility, contains a checklist for the details under Articles 15 and 18 for each packaging, a model text for the accompanying document for existing stock, and a checklist for environmental claims under Article 12(8) and Article 14.

• Download: PPWR labelling, roadmap and checklist (DOCX)

Frequently asked questions

What has had to appear on the packaging since 12 August 2026?

A type, batch or serial number and the name, trade name or trademark of the manufacturer with a postal address, plus, for imports, the name and address of the importer. On the packaging, in a QR code or, where that is not possible, in the accompanying documents.

Are the manufacturer details mandatory?

Yes, the details of the manufacturer under Article 15(6). What is meant is the manufacturer within the meaning of the Regulation, that is the filler, the brand owner or the maker of the packaging, not necessarily the producer within the meaning of extended producer responsibility.

From when is the QR code mandatory?

For reusable packaging from 12 February 2029 or 30 months after the implementing act. For EPR symbols it is the only permissible place from 12 February 2027. For manufacturer details and sorting information it remains voluntary.

From when do the pictograms apply?

At the earliest from 12 August 2028, in fact 24 months after the entry into force of the implementing act, which is still outstanding in September 2026. Expect the end of 2028 or later.

Does the labelling obligation also apply to transport packaging?

The sorting labelling under Article 12(1) does not, with the exception of e-commerce packaging. The identification and manufacturer details under Article 15 apply to every packaging.

May the Green Dot (Grüner Punkt) still be printed?

On the Commission's reading, only until 12 February 2027. After that, EPR symbols may appear exclusively in digital form, for instance in a QR code.

Which obligations arise under the PPWR from 2026?

Alongside the identification and manufacturer details, the substance requirements, the conformity assessment with technical documentation and declaration of conformity, and registration as a producer. The overview is in PPWR obligations from 12 August 2026: checklist and timeline.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), Articles 12 to 15, 18, 19, 21 and 70. Commission guidance document C/2026/3702, sections 13 and 14. Commission FAQ on the PPWR, 2nd edition (August 2026), sections II, VIII and X. Packaging Implementation Act, Federal Law Gazette 2026 I No 207, Sections 4, 46, 47 and 66. Status of the implementing acts under Article 12(6) and (7): not adopted (September 2026). This article describes the legal position as of September 2026 and does not replace legal advice.