Articles 12-14: Labelling, Marking & Environmental Claims
Top line summary
PPWR applies from 12 Aug 2026; by then the Commission must adopt implementing acts for packaging labels, digital marking for material composition, and waste-bin labels. From 12 Aug 2028 (or 24 months after the Art. 12(6)/(7) acts enter into force, if later), packaging must carry the harmonised material-composition labeland follow the related access/language rules; compostables and DRS packs have specific label rules. Waste receptacle labels must be in place by 12 Aug 2028 (or 30 months after adoption of the Art. 13(2) act, if later). Reusable packaging labelling + QR/info starts 12 Feb 2029 (or later per the “30 months” rule).
Summary
Check here the summary
🔴 = Hard obligation date
🟡 = Starts applying / go-live date
🔵 = Commission implementing act (needed)
🟢 = Optional / if you choose to do it
🗓️ Key dates (what matters operationally)
🔵 By 12 Aug 2026 – Commission implementing acts due for:
- Harmonised packaging label + specifications/formats (incl. digital formats) (Art. 12(6)).
- Digital-marking methodology to identify material composition (Art. 12(7), first sentence).
- Harmonised labels + specifications for waste receptacles (Art. 13(2)).
🟡 From 12 Aug 2028 OR 24 months after entry into force of the Art. 12(6)/(7) implementing acts (whichever is later) – packaging labelling “go-live” for:
- Harmonised material-composition label (Art. 12(1)).
- “Placement / languages / digital access / online pre-purchase info” rules for Art. 12 labels & data carriers (Art. 12(5)).
- If you label recycled content / biobased content, the label must follow PPWR specs/methods (Art. 12(4)).
🟡 From 12 Feb 2029 OR 30 months after entry into force of the Art. 12(6) implementing act (whichever is later) – reusable packaging labelling “go-live” (Art. 12(2)).
🟡 By 12 Aug 2028 OR 30 months from adoption of the Art. 13(2) implementing acts (whichever is later) – waste receptacle harmonised labels go-live (Art. 13(1)).
🔵 By 1 Jan 2030 – Commission implementing acts due for methodology to identify “substances of concern” via digital marking, incl. marking to include at least name + concentration per material (Art. 12(7), second sentence).
🟡 Regulation-wide application date: PPWR applies from 12 Aug 2026 (unless a specific later date is set in an article).
Fast scan matrix
Topic | Who is on the hook | What you must/ may do | When it applies |
Art. 12 — Packaging labelling/marking | Economic operators placing packaging on the market (practically: packaging designers/brand owners + supply chain as applicable) | Harmonised material-composition label; specific rules for compostables, DRS, reusable; digital-marking duties + rules for digital carriers | Mainly from 12 Aug 2028 (with “whichever later” rule) |
Art. 13 — Waste receptacle labels | Member States (implementation obligation) | Ensure harmonised labels on packaging-waste receptacles; labels correspond to packaging labels (except DRS) | Mainly from 12 Aug 2028 (with “whichever later” rule) |
Art. 14 — Environmental claims | Any economic operator making claims | Claims only if exceeding PPWR minimum requirements + must state scope + must be documented | PPWR applies from 12 Aug 2026 |
Article 12 – Labelling of packaging (what to build into specs)
🔴 Mandatory harmonised label: material composition (sorting)
From the Art. 12(1) “go-live” date, packaging placed on the market must carry a harmonised label showing material composition, designed to support sorting; it must be pictogram-based and understandable, including for persons with disabilities.
🔴 Compostable packaging: mandatory statements on-pack
For packaging referred to in Article 9(1) (and where relevant Article 9(2)), the label must indicate the material is compostable and include that it is “not suitable for home composting” and “not to be discarded in nature.”
Scope carve-out: except for e-commerce packaging, this compostable-labelling obligation does not apply to transport packaging or packaging subject to a deposit and return system.
🔴 Digital marking for “substances of concern”
Packaging containing substances of concern must be digitally marked using standardised, open digital-marking technologies, using the Commission methodology (Art. 12(1) + Art. 12(7)).
- The Commission must set the methodology for identifying substances of concern by 1 Jan 2030, and the marking must include at least substance name + concentration for each material in the packaging unit.
🟢 Optional: QR / digital data carrier for component-specific sorting guidance
In addition to the harmonised label, operators may add a QR code / standardised open digital data carrier with information on the destination (sorting) of each packaging component.
🔴 Deposit & return systems (DRS): clear label + possible harmonised colour label
Packaging subject to DRS under Article 50(1) must carry a clear and unambiguous label. It may also carry a harmonised colour label set by implementing act; Member States may require that color label only if it does not create internal-market distortions or trade barriers.
Plus (cross-border principle): Member States must not prohibit DRS labels used in other Member States.
🔴 Reusable packaging: label + QR/data carrier + point-of-sale differentiation
Reusable packaging must bear a label stating it is reusable; further re-use system info (collection points, and tracking trips/rotations or an average estimate if tracking isn’t feasible) must be accessible via QR/data carrier; reusable sales packaging must be clearly distinguished from single-use at point of sale.
Derogation: the label + QR/data-carrier requirement does not apply to certain open-loop systems without a system operator (per Annex VI).
🟢 Recycled content / biobased content labelling: not mandatory, but harmonised if used
If you put a label about share of recycled content (for packaging to which Article 7 applies), that label (and any QR/data carrier) must follow the implementing-act specs and the recycled-content methodology under Article 7(8). If you label share of biobased plastic content, that label must follow the implementing-act specs.
🔴 Placement, access, languages, and “digital rules”
- Labels / QR/data carriers must be visible, legible, firmly affixed (not easily erased). The information must also be available before purchase in online sales.
- If you can’t affix due to size/nature, put it on grouped packaging; if that’s still not feasible or to ensure non-discriminatory access (esp. visually impaired), provide via a single electronically readable code or other data carrier.
- Provide the information in one or more languages determined by the Member State where the packaging is marketed.
- If information is provided electronically: collect only minimal personal data for access; don’t display it alongside sales/marketing content; and where product law also requires a data carrier, use a single carrier with product vs packaging info clearly distinguishable.
🔴 “No confusing labels” rule
Economic operators must not display labels/marks/symbols likely to mislead or confuse end users about sustainability requirements/characteristics/waste-management options where PPWR harmonised labelling exists.
🟡 Extra marking possibility: EPR identification symbol
By 12 Feb 2027, packaging in an extended producer responsibility scheme may be identified across the Member State territory via a symbol in a QR code / standardised open digital-marking tech; it must not mislead on recyclability/reusability.
🟢/🔴 Exemptions + sell-through
- Medicinal products / certain medical contexts: Art. 12 does not apply to specific immediate/outer packaging where there is no space due to other mandatory labelling or where labelling could jeopardise safe use (as described in Art. 12(11)).
- Sell-through window: non-compliant packaging (within Art. 12(1),(2),(4) scope) manufactured/imported beforethe relevant deadline may still be marketed until 3 years after the labelling requirements enter into force for those provisions.
Article 13 – Labelling of waste receptacles (collection bins)
- Member States must ensure harmonised labels for separate collection are affixed/printed/engraved on all packaging-waste receptacles; bins can carry more than one label.
- This duty does not apply to receptacles subject to deposit and return systems.
- Commission implementing acts (by 12 Aug 2026) will set harmonised labels/specs, considering national collection-system specificities and composite packaging.
- Receptacle labelling must correspond to packaging labelling under Art. 12(6), except for packaging subject to DRS.
Article 14 – Environmental claims (pack-level “green” statements tied to PPWR)
Environmental claims (as defined in Directive 2005/29/EC) about packaging properties regulated by PPWR may be made only if:
- The claim relates to properties exceeding the applicable minimum PPWR requirements, using the PPWR criteria/methodologies/calculation rules; and
- The claim states whether it refers to the packaging unit, part of it, or all packaging placed on the market by the operator.
Compliance must be demonstrated in technical documentation (Annex VII).
✅ Compliance checklists (round bullets)
Article 12 – Packaging labelling / marking
◯ Map your packaging portfolio to: sales / grouped / transport / e-commerce, DRS, reusable, compostable (Art. 9), and “substances of concern” presence
◯ Build label space + artwork rules for: harmonised material label (pictograms + accessibility)
◯ For compostables: ensure label includes compostable + “not suitable for home composting” + “not to be discarded in nature” (and validate the transport/DRS carve-out)
◯ Set up digital-marking readiness (standardised, open tech) for:
◯ material composition methodology (Commission act due 12 Aug 2026)
◯ substances-of-concern methodology (Commission act due 1 Jan 2030)
◯ DRS packs: implement clear/unambiguous label; check if any Member State requires harmonised colour label
◯ Reusable packs: label + QR/data carrier + POS differentiation; check open-loop derogation applicability
◯ If you voluntarily show recycled/biobased content: align to implementing-act specs and (for recycled content) the Art. 7 methodology
◯ Verify “mechanics”: firm/legible, online pre-purchase visibility, fallback to grouped pack / single code, language rules, and “no marketing in compliance screen” for digital info
◯ Add a control to prevent extra marks that could confuse users where harmonised labels exist
◯ Confirm whether any SKUs qualify for the medicinal/medical labelling exemption and document rationale
◯ Plan sell-through using the 3-year post-go-live allowance (only for the specific Art. 12 provisions)
Article 13 — Waste receptacle labels (for Member States/operators implementing on behalf of MS)
◯ Track the Commission implementing act (due 12 Aug 2026) for receptacle label specs
◯ Prepare rollout so receptacles are labelled by 12 Aug 2028 or later (whichever later rule)
◯ Ensure receptacle labels match packaging labels (except DRS)
Article 14 – Environmental claims
◯ Gate any pack/environmental claim: only if it exceeds PPWR minimums (for the property you’re claiming)
◯ Force the claim to specify scope: unit / part / all packaging
◯ Store Annex VII evidence trail for the claim (methods/calculations + PPWR requirement baseline)
Legal text - Law EU 40/2025
Check here the legal text
LABELLING, MARKING AND INFORMATION REQUIREMENTS
Article 12
Labelling of packaging
- From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7 of this Article, whichever is the latest, packaging placed on the market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting. The label shall be based on pictograms and be easily understandable, including for persons with disabilities. For the packaging referred to in Article 9(1) and, where applicable, packaging referred to in Article 9(2), the label shall indicate that the material is compostable, that it is not suitable for home composting and that compostable packaging is not to be discarded in nature. With the exception of e-commerce packaging, this obligation does not apply to transport packaging or to packaging that is subject to a deposit and return system. The packaging placed on the market containing substances of concern shall be marked by means of standardised, open, digital-marking technologies in accordance with the methodology referred to in paragraph 7, second subparagraph. In addition to the harmonised label referred to in this paragraph, economic operators may place a QR code or other type of standardised, open, digital data carrier on the packaging that contains information on the destination of each separate component of the packaging in order to facilitate consumer sorting.
Packaging that is subject to deposit and return systems as referred to in Article 50(1) shall be marked with a clear and unambiguous label. In addition to the national label, packaging may be marked with a harmonised colour label established in the relevant implementing act adopted pursuant to paragraph 6 of this Article. Member States may require that packaging that is subject to deposit and return systems be marked with that harmonised colour label, provided that that does not lead to distortions on the internal market or trade barriers for products from other Member States.
- Reusable packaging placed on the market from 12 February 2029 or 30 months from the date of entry into force of the implementing act adopted pursuant to paragraph 6, whichever is the latest, shall bear a label informing users that the packaging is reusable. Further information on reusability, including the availability of a local, national or Union-wide re-use system and information on collection points, shall be made available through a QR code or other type of standardised, open, digital data carrier that facilitates the tracking of the packaging and the calculation of trips and rotations, or, if that calculation is not feasible, an average estimation. In addition, reusable sales packaging shall be clearly identified and distinguished from single-use packaging at the point of sale.
- By way of derogation from paragraph 2 of this Article, the requirement to bear a label and a QR code or other type of standardised, open, digital data carrier shall not apply to open loop systems which do not have a system operator in accordance with Annex VI.
- Where packaging to which Article 7 applies is placed on the market from 12 August 2028 or 24 months from the date of entry into force of the implementing act adopted pursuant to paragraph 6 of this Article, whichever is the latest, and is marked with a label containing information on the share of recycled content, that label and, where applicable, the QR code or other type of standardised, open, digital data carrier shall comply with the specifications laid down in the relevant implementing act adopted pursuant to paragraph 6 of this Article and shall be based on the methodology established pursuant to Article 7(8). Where packaging is marked with a label containing information on the share of biobased plastic content, that label shall comply with the specifications laid down in the relevant implementing act adopted pursuant to paragraph 6 of this Article.
- Labels referred to in paragraphs 1, 2 and 4 and the QR code or other type of standardised, open, digital data carrier referred to in paragraph 2 shall be affixed, printed or engraved visibly, legibly and firmly on the packaging, so that they cannot be easily erased. The information contained therein shall also be available to end users before the purchase of the product through online sales. Where such affixing, printing or engraving is not possible or not warranted on account of the nature and size of the packaging, the label, QR code or other standardised, open, digital data carrier shall be affixed to the grouped packaging. Where even that is not possible or not warranted on account of the nature and size of the packaging or where it is relevant to provide for non-discriminatory access to information for vulnerable groups, particularly visually impaired persons, the information shall be provided via a single electronically readable code or other type of data carrier. The information contained in the labels referred to in paragraphs 1, 2 and 4 and the QR code or other type of standardised, open, digital data carrier shall be made available in one or more languages which can be easily understood by end users, as determined by the Member State in which the packaging is to be made available on the market. Where information is provided by electronic means in accordance with paragraphs 1, 2 and 4, the following requirements shall apply:
(a) adequate and relevant personal data shall be collected only for the limited purpose of giving the user access to relevant compliance information referred to in paragraphs 1, 2 and 4 of this Article in respect of Article 5(1) of Regulation (EU) 2016/679 of the European Parliament and of the Council (68);
(b) the information shall not be displayed with other information intended for sales or marketing purposes.
Where Union law requires information on the packaged product to be provided via a data carrier, a single data carrier shall be used for providing the information required for the packaged product and for the packaging, and both shall be easily distinguishable.
- By 12 August 2026, the Commission shall adopt implementing acts to establish a harmonised label and specifications for the labelling requirements and formats, including where provided through digital means, for the labelling of packaging referred to in paragraphs 1, 2 and 4 of this Article. When developing those implementing acts, the Commission shall take into account the specificities of composite packaging. When developing the harmonised label for packaging subject to deposit and return systems referred to in Article 50(2), the Commission shall take into consideration any variation which exists in the deposit charged by Member States. Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 65(2).
- By 12 August 2026, the Commission shall adopt implementing acts to establish the methodology for identifying the material composition of packaging referred to in paragraph 1 by means of standardised, open, digital-marking technologies, including for composite packaging and integrated or separate components of packaging.
By 1 January 2030, the Commission shall also adopt implementing acts to establish the methodology for identifying substances of concern by means of standardised, open, digital-marking technologies. That methodology shall ensure that the marking includes at least the name and concentration of the substance of concern present in each material in a packaging unit.Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 65(2).
- Without prejudice to requirements concerning other harmonised EU labels, economic operators shall not provide or display labels, marks, symbols or inscriptions that are likely to mislead or confuse consumers or other end users with respect to the sustainability requirements for packaging, other packaging characteristics or packaging waste management options for which harmonised labelling has been laid down in this Regulation.
The Commission shall, where appropriate,adopt guidelines in order to clarify aspects that are likely to mislead or confuse consumers or other end users.
- By 12 February 2027, packaging included in an extended producer responsibility scheme may be identified throughout the territory of the Member States in which that scheme or system applies. Such identification shall be achieved only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology in order to indicate that the producer fulfils its extended producer responsibility obligations. That symbol shall be clear and unambiguous and shall not mislead consumers or other end users as to the recyclability or reusability of the packaging.
- Packaging covered by a deposit and return system other than that referred to in Article 50(1) may, under national law, be identified by means of a corresponding symbol throughout the territory in which that scheme or system applies. That symbol shall be clear and unambiguous and shall not mislead consumers or other end users about the packaging recyclability and reusability in the Member States where it is to be returned. Member States shall not prohibit the affixing of labels related to deposit and return systems in place in other Member States.
- This Article shall not apply to immediate and outer packaging as defined in Regulations (EU) 2017/745, (EU) 2017/746 and (EU) 2019/6 and Directive 2001/83/EC, if there is no space on the packaging due to other labelling requirements as defined in those Union legislative acts or if the labelling of the packaging could jeopardise the safe use of medicinal products for human use or of veterinary medicinal products.
- Packaging as referred to in paragraphs 1, 2 and 4 that is manufactured in the Union or imported before the deadlines referred in those paragraphs and that does not comply with the criteria laid down in those paragraphs may be made available on the market until 3 years from the date of entry into force of the labelling requirements laid down in those paragraphs.
Article 13
Labelling of waste receptacles for the collection of packaging waste
- By 12 August 2028 or 30 months from the adoption of the implementing acts referred to in paragraph 2, whichever is the latest, Member States shall ensure that harmonised labels that enable the separate collection of each material specific fraction of packaging waste that is intended to be discarded in separate receptacles are affixed, printed or engraved visibly, legibly and indelibly on all waste receptacles for collection of packaging waste. A receptacle for packaging waste may bear more than one label. This obligation does not apply to receptacles subject to deposit and return systems.
- By 12 August 2026, the Commission shall adopt implementing acts to establish harmonised labels and specifications for the labelling requirements and formats for the labelling of the receptacles referred to in paragraph 1 of this Article.
When developing those implementing acts, the Commission shall take into account the specificities of the collection systems established in the Member States as well as the specificities of composite packaging. The labelling for receptacles shall correspond to the labelling for packaging as referred to in Article 12(6) with the exception of labelling for packaging subject to deposit and return systems. Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 65(2).
Article 14
Environmental claims
Environmental claims as defined in Article 2, point (o), of Directive 2005/29/EC concerning packaging properties for which legal requirements are set out in this Regulation may be made in relation to packaging placed on the market if they fulfil the following requirements:
(a) the claims are made only in relation to packaging properties exceeding the applicable minimum requirements set out in this Regulation, in accordance with the criteria, methodologies and calculation rules set out therein; and
(b) the claims specify whether they relate to the packaging unit, part of the packaging unit or all packaging placed on the market by the economic operator.
Compliance with the requirements set out in this Article shall be demonstrated in the technical documentation concerning the packaging as set out in Annex VII to this Regulation.
Source: Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation), OJ L, 22.1.2025 (EUR-Lex OJ text).
