PPWR labelling: Art. 15 applies today, Art. 12 not before 2028

Labelling under Art. 12 PPWR is not yet in force. The sorting label applies at the earliest from 12.08.2028, realistically 2029, because the implementing act is missing. What has been mandatory since 12.08.2026 is the identifier and the manufacturer details under Art. 15(5) and (6). This article separates the two.

Mandatory today

identifier, name and address of the manufacturer (Art. 15(5)/(6))

Sorting label Art. 12

at the earliest 12.08.2028 or 24 months after the act

Reuse label with QR

at the earliest 12.02.2029 or 30 months after the act

Implementing act

Art. 12(6), initiative 19243, not adopted

Sell-off

remaining stock may be sold for 3 years

What must be on the packaging since 12.08.2026

The manufacturer affixes an identifier that allows the packaging to be identified, such as a type, batch or serial number, plus its name, registered trade name or trademark and a postal address. Both go on the packaging or, where that is not possible, in the accompanying documents. Importers add their own name and address (Art. 18(3)). Distributors verify that these details are present. Stock produced before the application date does not need relabelling; the details may then be given in the accompanying document.

Art. 12: sorting label and reuse label come later

Art. 12 requires a harmonised label on material composition so that consumers can sort the components correctly, and for reusable packaging a label with a QR code or another digital carrier pointing to the reuse system. The Commission sets the design in an implementing act. That act has not been adopted. The deadlines run from its entry into force, so today neither symbols nor colours nor a layout are known.

The QR code: mandatory only for reusable packaging

There is no general QR code duty for packaging. Art. 12 requires the digital carrier only for reusable packaging, and even there only after the act. Anyone printing a QR code voluntarily today may do so but must ensure the information is not misleading and does not cover later official labels.

What you can prepare today

• Check identifier and manufacturer details on all packaging under your own brand, alternatively in the accompanying documents.
• Know per packaging the components a consumer can separate and their material from the bill of materials. The sorting label will later be built from this.
• Design print artwork so that space remains for a later label.
• Do not build your own label logic. Symbols, colours and sizes are not known.