PPWR Labelling Requirements: Pictograms, QR Codes, and Material Codes

Packaging placed on the EU market must carry harmonised EU pictograms for material composition and the correct sorting bin, from 12 August 2028 or 24 months after the labelling implementing acts take effect, whichever is later. Those acts were due on 12 August 2026 and remain unadopted, so 2028 is a floor, not a fixed date. Reusable packaging also needs a QR code or other digital data carrier from 12 February 2029.

Updated 19 August 2026: revised for the PPWR labelling timeline now that the implementing acts are delayed.

The harmonised label is meant to end the patchwork of squeezing five national logos onto one small box. Until it applies, the patchwork is still what you have to comply with.

Key takeaways

• The harmonised EU pictograms apply 24 months after the labelling implementing acts, or 12 August 2028, whichever is later.
• The acts missed their 12 August 2026 deadline, so plan for the label to arrive after August 2028, not on it.
• National schemes such as the French Triman logo stay in force in the meantime, because the old Directive 94/62/EC marking rule survives until 30 months after the new acts.
• Reusable packaging needs a QR code or other data carrier from 12 February 2029 at the earliest. A separate QR option for carrying the EPR-scheme symbol opens on 12 February 2027.

When do the harmonised labels actually apply?

Article 12 requires packaging to carry harmonised labels indicating its material composition and the correct waste sorting bin for the end consumer. The date is written as a comparison, not a fixed day: the label applies from 12 August 2028, or 24 months after the Article 12(6) and 12(7) implementing acts enter into force, whichever falls later.

The delay matters right now, because the Commission missed the deadline. The acts were due on 12 August 2026, the day the regulation became applicable, and as of 19 August 2026 they have not been adopted, with a draft expected after the summer. Every month of delay pushes the label date further past August 2028. So the honest planning position is: the design work is coming, the pictograms do not exist yet, and you cannot print to a specification the Commission has not published.

There is one piece of relief written into the text. Packaging manufactured or imported before the labelling deadline may still be placed on the market for three years afterwards (Article 12(12)), so a print run does not become worthless overnight. Map your stock against the PPWR deadline timeline rather than against a single date.

Will the PPWR replace the French Triman logo?

Eventually, yes. The regulation aims at full harmonisation, and because it is directly applicable, Member States cannot keep imposing conflicting packaging labels once the harmonised pictograms apply. The French Triman logo and the Italian environmental sorting codes will be displaced by the EU standard.

The trap is the gap in between. Directive 94/62/EC was repealed on 12 August 2026, but its Article 8(2) marking rule was deliberately kept alive until 30 months after the new labelling act enters into force. National marking law therefore still binds. Navigating EPR in France still means printing Info-tri sorting instructions that differ from what Spain or Portugal expect, and that stays true until the harmonised label lands.

The harmonised pictogram will replace the national logos. Until the Commission publishes it, the national logos are the ones you can be fined for missing.

How do QR codes work for reusable packaging?

If you use reusable formats, such as returnable delivery totes or refillable cosmetic jars, you will have to affix a digital data carrier such as a QR code to the packaging. Article 12(2) sets that date at 12 February 2029 or 30 months after the labelling implementing acts, whichever is later, so it moves with the same delay. The code must link to a system that tracks the packaging's rotations and tells the consumer how to return it.

The law requires that reusable packaging under Article 11 operates within a structured system. As the EU pushes for ambitious reuse targets, the physical item must be digitally traceable. The QR code must inform the end user about the available return points, how to properly clean or handle the item before return, and the environmental benefits of the system. This digital tracking will also serve as evidence when you need to prove your packaging recyclability and reuse rates to market surveillance authorities.

Can you use digital labels to save space on packaging?

Partly. Article 12 allows information required by the regulation to be carried on a digital data carrier alongside the physical label, which helps when printing full technical detail on a small container would ruin the design.

One digital option already has a date attached: from 12 February 2027, the symbol identifying the EPR scheme a producer belongs to may be carried by a QR code rather than printed.

Beyond that, how far the material-composition detail can move off the physical label depends on the implementing acts that have not been adopted, so the exact split between printed and scanned information is not yet knowable. What is clear from the text is that the sorting information the consumer needs has to reach the consumer, so treat "put it behind a QR code" as an open question rather than a plan.

Stop worrying about changing your packaging designs for every European border crossing. Let Gramta track it for you and keep your packaging record ready for the pictograms when the Commission publishes them.

Sources:

• Regulation (EU) 2025/40 – Article 11: Reusable packaging
• Regulation (EU) 2025/40 – Article 12: Labelling of packaging
• EU misses deadline for PPWR labelling rules (19 August 2026)
• European Commission: PPWR FAQs
• European Packaging and Packaging Waste Regulation Summary of Provisions and New Guidance – Latham & Watkins LLP
• FAQ: What You Need to Know About the EU Packaging and Packaging Waste Regulation (PPWR) – SGS