PPWR Article 12: Harmonised Labelling of packaging in the EU
As of 12 August 2026, key obligations under the new EU Packaging and Packaging Waste Regulation (PPWR) have become applicable. Shortly after this milestone, the next major PPWR requirement is already approaching: the harmonised labelling of packaging under Article 12 PPWR. The labelling requirements are expected to apply from 12 August 2028 or 24 months after the entry into force of the relevant implementing acts, whichever is later.
What is the objective of the harmonised labelling of packaging?
Today, different packaging labelling systems and requirements apply across the European Union. Article 12 PPWR aims to create a harmonised approach by introducing a common label containing information on the material composition of packaging.
The objective is to facilitate consumer sorting, improve the separate collection of packaging waste, support recycling processes and ultimately contribute to a stronger circular economy. At the same time, harmonised labelling is intended to make packaging information more consistent, transparent and understandable throughout the EU.
What are the requirements defined in PPWR Article 12?
Based on Article 12 PPWR, the labelling of packaging will be expected to:
- provide information on the material composition of packaging;
- be based on pictograms uniform throughout the EU;
- be easily understandable,
- especially for persons with disabilities;
- indicate whether certain packaging is compostable where required; and
- be accompanied, where applicable, by a QR code or another type of standardised, open, digital data carrier.
The future system will therefore go well beyond traditional material identification symbols and will become an important element of consumer information.
Specific requirements for certain packaging formats
Article 12 establishes additional requirements for specific packaging types. In particular, compostable packaging will need to be clearly identified as compostable. The label must also indicate that such packaging is not suitable for home composting and should not be discarded in nature.
Reusable packaging placed on the market will be required to bear a label informing users that the packaging is reusable. Additional information on reuse systems, collection points and reusability can be provided through a QR code or another type of standardised, open, digital data carrier.
What does this mean for logos of PROs?
Article 12 also introduces important restrictions regarding PRO (Producer Responsibility Organisation) logos on packaging. According to Article 12(9), PRO logos that merely indicate compliance with producer responsibility obligations may only be added through a corresponding symbol contained in a QR code or another standardised, open, digital-marking technology. The purpose of this is to ensure that consumers are not misled regarding the recyclability or reusability of packaging.
Furthermore, Article 12(8) prohibits economic operators from displaying labels, symbols or inscriptions that are likely to mislead or confuse consumers with regard to packaging sustainability requirements, packaging characteristics or packaging waste management options.
What does the PPWR mean for existing national labelling schemes?
Until the harmonised labelling requirements become applicable, existing national labelling requirements will continue to apply. However, companies should continue to comply with national labelling obligations in their target markets while also preparing on time for the future EU framework.
How does the new packaging labelling systems look like?
Although Article 12 establishes the legal framework, key implementation details remain outstanding. The European Commission must still adopt implementing acts defining among other details the harmonised label design, technical specifications and formats.
How should companies prepare?
Even though the final label specifications have not yet been published, companies can already take important steps, including:
- preparing structured packaging data
- reviewing the material composition of packaging
- analysing composite and multi-material packaging
- assessing existing packaging artwork and printing processes
- monitoring national labelling obligations
- clarifying responsibilities between marketing, procurement, quality management, legal teams and suppliers; and
- planning future packaging design adaptations at an early stage.
The new requirements extend far beyond the visual design of a label. They may affect packaging data management, supplier communication, artwork processes, internal approval procedures and international packaging strategies.
Conclusion
The new harmonised packaging labelling framework established by Article 12 PPWR will fundamentally change how packaging is labelled across the European Union. While businesses will benefit from a more consistent regulatory framework across Member States, they will also need to adapt their packaging data, design and compliance processes to meet the new requirements. Companies that begin preparing today and closely monitor future implementing acts will be best positioned to manage the transition efficiently and minimise compliance-related effort.
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The recyclability of packaging plays a central role in the PPWR regulation. This requires recyclable packaging with an increasing proportion of recyclate from 2030. Companies should therefore optimise their packaging design now in order to meet legal requirements and strengthen the circular economy.
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