Although the new PPWR labeling requirements under Article 12 do not take effect until August 2028, they are already generating a lot of discussion. What often gets overlooked is that harmonized labeling requirements will already be in place starting in August 2026. Specifically, this concerns labeling regulations under Article 15(5-6) of the PPWR. We’ll tell you what you need to be aware of right now and what will apply starting in 2028. We’ll also provide you with specific recommendations for action.
Labeling regulations under Article 15(5-6) of the PPWR
Why they apply now.
The PPWR requirements outlined below are related to the general conformity assessment obligation. They generally take effect when the respective substantive requirements of the regulation come into force. Since the PPWR is directly applicable as a regulation, no national implementation is required.
What this specifically entails
Article 15(5) and (6) of the PPWR specify the information and labeling requirements related to the conformity of packaging. Accordingly, economic operators must ensure that packaging is placed on the market only if it complies with the requirements of the Regulation and this can be demonstrated through appropriate technical documentation and a declaration of conformity.
Article 15(5)
Producers shall ensure that their packaging bears a type, batch, or serial number or another mark for its identification or, if this is not possible due to the size or nature of the packaging, that the required information is provided in the documentation accompanying the packaged product.
Article 15 (6)
Producers shall indicate on the packaging, or on a QR code or other digital medium, their name, registered trade name, or registered trademark, as well as their mailing address and, where applicable, electronic means of communication through which they can be contacted. If this is not possible, the required information shall be provided together with the information made available via the QR code or other standardized and open digital media referred to in Article 12(2), or the media referred to in Article 12(1), (2), (4), or (5), or in accompanying documents for the packaged product. The postal address shall indicate a central point through which the producer can be contacted.
What applies from 2028
The likely label designs
A core element of the PPWR is the harmonized labeling under Article 12 for sales and secondary packaging as well as for industrial and commercial packaging. Pure transport packaging is excluded.
Objectives of the proposal
- EU-wide standardization
- Clarity for consumers
- Facilitating waste separation
Basic requirements
Packaging, including e-commerce packaging, must
- bear harmonized labeling,
- provide information on material composition,
- use easily understandable pictograms.
Additionally possible
- QR code or digital data carrier with additional sorting information
The requirement for harmonized labeling under Article 12 does not apply to
- transport packaging
- Packaging in deposit and return systems
Probable EU label structure
The technical proposal by the Joint Research Centre (JRC) dated January 13, 2026 outlines a uniform EU sorting system.
Basic principles
- Material-based, not country-specific
- Replaces fragmented national labeling
- Supports recycling and the single market
Design principles
- Clearly recognizable pictograms
- Unambiguous color coding (e.g., yellow = plastic)
- Material designation in 1–2 words
- Polymer code additionally for plastics (e.g., PP 05)
- Modular design for multi-component packaging
Example: Plastic labeling
- Symbol for plastic
- Yellow background
- Material designation “PLASTIC”
- Polymer code “PP 05”
- Optional QR code
- Maximum linguistic neutrality
Our recommendation for action (starting now)
Strategic implications for companies
The PPWR is not just a compliance issue! It affects:
- Packaging design
- Artwork adjustments
- Supply chains
- Material selection
- Data management
- Sustainability strategy
- Product costs
In particular, the mandatory redesign of artwork in connection with the harmonized labels should be planned well in advance.
Our Services
If you need support and would like to learn more about the details surrounding labeling, please feel free to contact us. For example, use the contact form on our PPWR Impact Assessment website.
