What does the PPWR require for packaging labelling?

The PPWR requires all packaging placed on the EU market to carry standardized, harmonized labels that help consumers sort waste correctly and identify which materials have been used. The legal basis is Article 12 and Annex VII of Regulation EU 2025/40, which entered into force on February 11, 2025.

Three categories of marking apply:

1. Sortability/waste sorting markings: helping consumers place packaging in the correct waste stream
2. Material composition/identification markings: identifying the materials the packaging is made from
3. Reuse markings: indicating that packaging is part of a formal reuse system (only applies to reusable packaging)

The core principle behind the PPWR labelling framework is harmonization. Instead of 27 member state schemes that can conflict and overlap, one EU-wide system applies from August 12, 2026. Companies selling packaged goods across multiple EU markets today often manage between five and ten different national labelling requirements simultaneously, the PPWR reduces that to one labelling system across all 27 member states.

Labelling is one element of a broader set of PPWR obligations. For importers and distributors, it sits alongside the Declaration of Conformity and recyclability requirements.

What are the three types of PPWR packaging markings?

Sortability markings

Sortability markings tell consumers which waste stream a piece of packaging belongs to: paper, plastic, glass, metal, textile, or composite. Article 12 of PPWR requires consumer-facing packaging to carry labels describing the material composition through pictograms. The clear labelling helps consumers sort their waste correctly.

Further details regarding the exact content of the pictograms, as well as further designs and formats are yet to be determined by the European Commission in an implementing act.

{{custom-cta}}

Material composition / identification markings

Material composition markings identify the material or materials a piece of packaging is made from. The PPWR builds on Commission Decision 97/129/EC, the existing identification system for packaging materials based on numbering and abbreviations, but converts what was previously a voluntary identification system into a mandatory requirement.

The exact material codes and formats will be confirmed by the European Commission via an implementing act due by 12 August 2026. Commission Decision 97/129/EC will continue to apply until it is formally repealed on 12 August 2028, when the new harmonized system supersedes the 1997 framework under Article 70 of the PPWR.

Accurate material coding also feeds directly into recyclability assessments. For companies working through PPWR recyclability grades and recycled content targets, the material identification step is a shared foundation.

Reuse markings

Reuse markings apply only to packaging that is part of a formal reuse system, meaning packaging designed to be returned, cleaned and refilled rather than discarded after a single use. Not all packaging requires a reuse marking.

Reuse markings must convey information about the reuse system the packaging belongs to, including collection points. The specific format will be defined in the Commission's implementing acts. Companies operating reuse systems need to ensure their packaging artwork communicates clearly what the system is and where packaging can be returned.

When do PPWR labelling requirements apply?

Labeling requirements in PPWR are still not finalized by the European Commission. By August 12 2026 the European Commission will define how the pictograms and other labelling conventions will look. From the date of the EC's implementing act, companies have 24 months to transition to the new EU-wide labeling conventions.

Does the PPWR replace national labelling schemes like France's Triman?

Yes. The PPWR replaces all national packaging labelling schemes with a single harmonized EU system. Member states cannot require national labels alongside or instead of the harmonised EU labels after August 12, 2028, or within 24 months of the Commission implementing act entering into force.

France's Triman logo and Info-tri

France currently requires the Triman logo and associated Info-tri sorting instructions on all consumer packaging subject to extended producer responsibility (EPR). The European Commission views the mandatory Triman requirement as a barrier to the single market and incompatible with the PPWR harmonization objective.

The Commission initiated infringement proceedings against France on November 14, 2024, and referred France to the Court of Justice of the European Union (CJEU) on July 17, 2025, according to BIVDA Newsletter. Companies currently selling in France should prepare artwork incorporating PPWR harmonized labels while monitoring the CJEU proceedings for guidance on the transition timeline.

Italy's environmental labelling

Italy introduced mandatory environmental labelling for household packaging under Decreto 116/2020, requiring material identification codes and sorting instructions on consumer packaging. Under the PPWR, the Italian scheme will be replaced by the harmonized EU labelling system. Companies operating in Italy should plan for a single-label transition rather than running parallel Italian and EU labels during the transition period.

Germany's Verpackungsgesetz (VerpackG) markings

Germany's packaging law requires manufacturers and importers to register with and participate in a dual take-back system for consumer packaging. The PPWR's harmonized sortability and material composition labels will take over the consumer-facing waste communication function previously handled by national symbols. Companies should verify with their German EPR compliance partner how the two systems interact during the transition.

What are the PPWR labelling exemptions?

Small packaging

Packaging below a minimum surface area threshold does not need to carry physical labels. Under Article 12 of the PPWR, small packaging may instead use a QR code or digital data carrier that links to the required labelling information. The QR code option exists for cases where there simply is not enough physical space to display a legible pictogram, not as a general alternative for companies that prefer digital labels over printed ones.

Transport and industrial packaging

Packaging that does not reach end consumers directly, such as transport and industrial packaging, has lighter labelling requirements under the PPWR. Material identification markings still apply, but sortability pictograms are less relevant for packaging that never reaches households. Companies should confirm the classification of each packaging unit in their portfolio before assuming lighter treatment applies.

{{ppwr-document-checker}}

Who is responsible for PPWR labelling?

Responsibility for PPWR labelling falls on the party that places the packaging on the EU market.

- The manufacturer applies the correct labels before placing packaging on the market. For companies producing their own packaging within the EU, this responsibility is straightforward.
- The importer is responsible when the manufacturer is based outside the EU. Importers must verify that the packaging they bring into the EU meets labelling requirements, and a non-EU manufacturer's declaration alone is not sufficient.
- The distributor must not place non-compliant packaging on the market. Distributors carry a secondary duty to check that packaging already placed on the market by others meets the requirements before they sell it.

The Article 21 rule, where an importer takes on the role of manufacturer for PPWR compliance purposes, also applies to labelling. If an importer places packaging on the EU market under their own name or trademark, they assume the full obligations of a manufacturer, including correct labelling.

How can companies prepare for PPWR labelling compliance?

The August 2026 deadline leaves limited runway. Packaging artwork changes require design, approval, print and production lead times that add up quickly, so preparation should start now.

1. Audit your current packaging labels across all EU markets. List every label, symbol and marking currently in use and note which country or regulation requires each one.
2. Map which national marking schemes apply to your products. Identify where you currently use Triman, Italian environmental labelling, German dual system marks or any other national requirement.
3. Identify your packaging materials using the Decision 97/129/EC coding system. Verify the material composition of every packaging unit in your portfolio, as this data feeds both labelling and recyclability assessments.
4. Prepare artwork templates with space for harmonized labels. Design teams need to build pictogram placeholders into packaging layouts before the final implementing act designs are confirmed.
5. Monitor the Commission implementing act for final pictogram designs. The JRC proposal is the working reference, but the implementing act contains the legally binding specifications. Track official European Commission packaging regulation publications.
6. Communicate with suppliers about labelling changes on supplied packaging. Suppliers providing packaging to you need to understand what markings the finished packaging must carry, particularly if you are the importer and therefore bear responsibility for compliance.
7. Plan the transition. Decide whether to run dual labels during the transition period or shift entirely to harmonized EU labels on August 12, 2026.

Coolset helps companies manage PPWR compliance, and packaging labelling sits alongside recyclability tracking, recycled content documentation and Declaration of Conformity management in one place.

Frequently asked questions

What are the PPWR labelling requirements?

The PPWR requires three types of markings on packaging placed on the EU market: sortability pictograms to guide consumers on waste sorting, material composition codes identifying packaging materials, and reuse markings for packaging in formal reuse systems. The legal basis is Article 12 and Annex VII of Regulation EU 2025/40. All three markings will apply from 12 August 2028 or 24 months after the implementing act of the European Commission.

Does the PPWR replace France's Triman logo?

Yes. The PPWR replaces national labelling schemes including France's Triman and Info-tri, Italy's environmental labelling decree and other country-specific markings. The European Commission opened infringement proceedings against France in November 2024 and referred France to the CJEU in July 2025 over the Triman requirement conflicting with PPWR harmonisation.

What are the PPWR labelling exemptions?

Small packaging below a minimum surface area may use a QR code or digital data carrier instead of physical labels under Article 12. Transport and industrial packaging has lighter requirements. Packaging manufactured before August 12, 2026 can be sold for up to 36 months under the transition provision.

Who is responsible for PPWR labelling: the manufacturer or the importer?

The manufacturer must apply correct labels before placing packaging on the EU market. If the manufacturer is outside the EU, the importer is responsible for verifying labelling compliance. Under the Article 21 rule, importers who place packaging under their own name or trademark take on full manufacturer obligations, including labelling.

Can companies use a QR code instead of physical PPWR labels?

Only for small packaging that lacks sufficient surface area to display a legible label. Article 12 permits a QR code or digital data carrier linking to the required information in these cases. For standard-sized consumer packaging, physical labels are required, and the QR code option is a size-based exemption.

‍