PPWR labelling: what information must appear on the packaging?

Article 15 of Regulation (EU) 2025/40 sets out two independent obligations that are almost always confused with each other, because both fall under the umbrella term "PPWR labelling".

Paragraph 5 requires an identification mark: the packaging must bear a type, batch or serial number, or another element that allows it to be clearly identified. The purpose is traceability during market surveillance or a recall.

Paragraph 6 additionally requires the manufacturer's contact details: name, registered trade name or trademark, postal address and, where available, electronic contact details.

A printed brand name alone satisfies neither obligation — it is neither an identification number nor a complete postal address with a way to make contact. Both duties have applied independently in every EU member state since 12 August 2026, directly and without national implementation.

Technically yes, but the legal basis differs between the two paragraphs — worth knowing if it ever comes up with a market surveillance authority.

For the contact details under para. 6, the regulation explicitly names a QR code or other data carrier as an equally valid alternative to printing directly on the packaging.

For the identification number under para. 5, the wording is different: the text does not mention a QR code as a separate alternative there. The only exception named is an accompanying document — and only if the size or nature of the packaging makes direct marking impossible.

In practice, most companies still put both pieces of information into the same QR code — that's allowed and common. But when it comes specifically to the identification number, this practice rests more on the general legibility requirement in Art. 15(7) than on an explicitly named QR alternative. For day-to-day implementation this usually makes no difference; for a clean legal justification, it does.

Only as an exception, not as a default route — and the conditions differ depending on which piece of information is at stake.

For the identification number (para. 5), an accompanying document is explicitly provided for, but tied to a condition: the size or nature of the packaging must make direct printing impossible. A common example from official guidance is a small yoghurt cup where there simply isn't room.

For the contact details (para. 6), a staged order applies: first printing on the packaging, if that's not possible a QR code or other data carrier, and only if neither works, an accompanying document.

In the normal case — where there is still room on the packaging — referring to an accompanying document is therefore not enough to replace the direct labelling duty. The exception is narrowly drawn and shouldn't be used as a convenient default.

No, and this mix-up is one of the most common reasons companies have the wrong deadline in mind.

Art. 15 — the subject of this page — covers the identification number and manufacturer contact details. It has already applied directly since 12 August 2026, without any further implementing act.

Art. 12 covers the harmonised sorting pictograms meant to tell consumers how to dispose of packaging correctly. This pictogram duty depends on an implementing act from the European Commission that has not yet been adopted, and takes effect no earlier than 12 August 2028.

If you come across a claim that mandatory recycling symbols must already appear on every package "now", it's either citing the wrong deadline or conflating the two provisions.

Art. 15 does not distinguish by packaging level. Sales packaging, grouped packaging (packaging bundling several units) and transport packaging are all covered equally, provided each is placed on the market as its own packaging within the meaning of the PPWR.

In practice: an online shop that ships goods in a branded shipping box must also label that box — it is its own packaging layer, not just a neutral shipping wrapper.

The only exception is when a packaging layer is never placed on the market independently but remains purely a component of an already-labelled larger unit — worth checking case by case against your actual supply chain.

The regulation does not literally require an exact match, but the purpose of the rule points squarely in that direction: the identification number is meant to let a market surveillance authority trace the packaging on the shelf back to the matching technical documentation and EU declaration of conformity (Art. 15(5) in conjunction with Art. 39).

If the number leads nowhere, or to a declaration covering a different packaging configuration, the identification function is effectively not fulfilled — from the authority's perspective it looks as if this specific packaging has no valid assignment at all.

The safe approach in practice: use the same number (or a clearly traceable link) on both the label and the declaration of conformity, rather than maintaining two separate numbering systems.

It depends on how uniquely that SKU is actually tied to a single packaging configuration — not on whether a number exists at all.

If the same SKU always corresponds to the same packaging — same material, same supplier, same construction — it can serve as the identification mark without issue; a separate, purpose-built packaging number isn't necessary.

It becomes a problem if the same SKU is sourced from different suppliers or different factories over time with differing packaging. Then the number no longer points uniquely to one packaging, and the identification function that Art. 15(5) is meant to serve is not met.

The European Commission's updated FAQ also clarifies that not every individual standardised piece of packaging needs its own separate number — several identical units from the same batch can share one number as long as their configuration doesn't differ.

No. Art. 15 requires neither a list of individual material components nor a statement of the materials used on the packaging itself — not as text and not hidden inside a QR code.

That information belongs in the technical documentation prepared and kept as part of the conformity assessment procedure under Art. 38. It must be made available to market surveillance authorities on request, but does not need to be shown to the public or the end customer on the packaging.

Visible on the packaging itself, only the two items described above are needed: the identification number and the manufacturer's contact details.

No — for the specific case of stock already produced but not yet placed on the market, the European Commission clarified this explicitly in its updated PPWR FAQ of August 2026: packaging manufactured before the deadline but not yet placed on the market does not need to be destroyed, remanufactured or re-labelled solely to add this marking. The information required under paragraphs 5 and 6 may instead be provided in an accompanying document during this transitional situation — this explicitly applies to reusable packaging already in circulation too.

It's worth noting the precise scope of this clarification: it applies only to the labelling duty under Art. 15(5) and (6) for existing stock at the deadline. It is not a general transition period for all PPWR obligations — substance restrictions such as the PFAS limits under Art. 5, for instance, are not covered by it.

The regulation prescribes no fixed design — what matters is only that the required information is present, legible, and assignable to the right paragraph, not a particular layout.

In the example, DE-2026-00482-A is the identification number under para. 5 — it must be printed on the packaging; a QR code is not named as an alternative for this field. The block with company name, address and contact covers para. 6 — here printing and a QR code are equally valid. The QR code in the example is an optional carrier for that second block only, not a replacement for the printed number.

A label like this, with fields automatically formatted for the destination country, can be created free of charge with the PPWR label generator.