Packaging and Packaging Waste Regulation (PPWR) labelling requirements: Changes from Article 12

The Packaging and Packaging Waste Regulation (PPWR) introduces new harmonised packaging labelling requirements across the EU. From waste sorting labels and reusable packaging markings to new rules around digital labelling, businesses placing packaging on the EU market need to understand what is changing, when requirements will apply and how to prepare for compliance.


OPRL label

The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and generally applies from 12 August 2026. It introduces new harmonised packaging labelling requirements for packaging placed on the EU market. Different requirements apply at different times and several depend on the adoption and entry into force of implementing acts.

Why are labelling requirements changing?

The new harmonised requirements aim to:

  • Enable the correct separation of packaging waste.
  • Remove unclear labelling elements which could confuse consumers’ recycling efforts.

What are the main mandatory labelling changes?

Key mandatory updates include:

  • EU Harmonised Waste Sorting Label
  • Reusable Packaging Label
  • Digital presentation of EPR participation symbols
  • Restricting potentially misleading or conflicting labels

What is the EU Harmonised Waste Sorting Label?

Packaging placed on the EU market will need to display the harmonised label from the applicable date, subject to the exemptions in Article 12. The principal requirement does not apply to transport packaging, except e-commerce packaging, or to packaging subject to a deposit and return system. The detailed design, specifications and format will be set through implementing acts, and the application date depends on when the relevant acts enter into force.

The PPWR states that the label must be based on pictograms and contain information on material composition to help consumers sort packaging waste. It must be easily understandable, including for people with disabilities. Economic operators must not display labels, marks, symbols or inscriptions that are likely to mislead or confuse users about matters covered by harmonised PPWR labelling.

What are the PPWR requirements for reusable packaging?

Reusable packaging must be clearly labelled as reusable. Information on re-use systems and collection points must be available through a QR code or another standardised, open digital data carrier. Reusable sales packaging must also be clearly identified and distinguished from single-use packaging at the point of sale. The requirement does not apply to open-loop systems without a system operator in accordance with Annex VI.

When will the changes come into effect?

Requirement Date
Harmonised waste sorting label From 12 August 2028 at the earliest, or 24 months after the relevant implementing acts enter into force, whichever is later.
Reusable packaging label From 12 February 2029 at the earliest, or 30 months after the relevant implementing act enters into force, whichever is later. A three-year transitional exemption applies to reusable packaging already in circulation before the requirement becomes applicable.
Digitalising the Green Dot By 12 February 2027, where packaging is identified as participating in an extended producer responsibility scheme, the identification must be provided through a corresponding symbol in a QR code or another standardised, open digital-marking technology. The PPWR does not require the use of DigiDot.
Prohibiting national labels in the EU The PPWR restricts labels, marks, symbols or inscriptions that are likely to mislead or confuse users about matters covered by harmonised labelling. Deposit and return system labels remain subject to separate provisions.

Note that this is not an exhaustive list of the new labelling requirements introduced by the PPWR.

How Valpak can help

PPWR Advisory Service

This service provides a PPWR Compliance Kit to introduce the complex requirements of the PPWR. Valpak provides a bespoke impact assessment to determine how the PPWR will impact your business on an article-by-article basis. This is delivered alongside a PPWR Labelling Report, tailored to your business. Your company will have a dedicated PPWR specialist to help navigate the requirements, define the next steps for your business towards PPWR compliance and keep your company up to date with the evolving regulation.

PPWR Packaging Portfolio Assessment

As an add-on to the PPWR Advisory Service, Valpak will determine the impact each article requirement of the PPWR will have on your company’s packaging. This article-by-article analysis will be delivered in the form of a report that includes a specification sheet, timeline and qualitative write-up specific to each packaging unit.

Visit our PPWR web page or make an enquiry to speak to a PPWR export.

Key takeaway

The labelling changes should improve clarity and make the sorting of packaging waste easier. Valpak’s assistance will help your business stay up to date with the latest labelling changes, contributing to a circular economy.

Written by: Daisy Mclean

Work Experience

Topics:

Blog, PPWR

FAQs

PPWR labelling requirements introduce harmonised packaging labels across the EU to help consumers correctly sort and dispose of packaging waste.

Implementation dates vary depending on the requirement. The harmonised waste sorting label applies from 12 August 2028 at the earliest, or 24 months after the relevant implementing acts enter into force, whichever is later. Reusable packaging labelling applies from 12 February 2029 at the earliest, or 30 months after the relevant implementing act enters into force, whichever is later.

The harmonised waste sorting label is a pictogram designed to help consumers identify material composition and sort packaging waste appropriately for disposal.

The PPWR restricts labels, marks, symbols or inscriptions that are likely to mislead or confuse users about matters covered by harmonised labelling. It does not impose a blanket ban on all national packaging labels.

Reusable packaging must be clearly labelled and consumers must be able to access information on reuse systems and collection points through a QR code or another standardised digital data carrier.

Businesses should understand how the requirements apply to their packaging, review upcoming implementation dates and keep up to date with developing PPWR guidance.