PPWR labelling checklist Articles 12 and 13

Start by mapping each packaging unit to the Article 12 label category that actually applies. The general material-composition label is for packaging placed on the market, with specific exclusions for transport packaging other than e-commerce packaging and for packaging covered by a deposit and return system.

Reusable packaging, compostable packaging, packaging carrying recycled-content or biobased-plastic information, packaging containing substances of concern, and deposit-return packaging each need a separate label review because Article 12 treats them differently.

Article 12 uses date gates tied to Commission implementing acts, so do not publish a fixed compliance date without checking the relevant act. The general material-composition label applies from 12 August 2028 or 24 months from the relevant implementing acts, whichever is later. Reusable packaging labelling applies from 12 February 2029 or 30 months from the relevant implementing act, whichever is later.

The Commission must adopt implementing acts for harmonised packaging labels and receptacle labels by 12 August 2026, and must also adopt a methodology for digital marking of material composition by that date. A separate implementing act for identifying substances of concern by digital-marking technologies is due by 1 January 2030.

Article 12 does not only ask whether a symbol exists. It requires labels and, for reusable packaging, the QR code or other digital data carrier to be visibly, legibly, and firmly affixed, printed, or engraved on the packaging so they cannot be easily erased. Where packaging size or nature makes that unwarranted or impossible, the regulation provides fallbacks through grouped packaging or a single electronically readable code or other data carrier.

For online sales, the same information must be available to end users before purchase. For Member State rollouts, the information must be in one or more languages easily understood by end users as determined by the Member State where the packaging is made available.

Article 13 links waste-receptacle labels to the packaging labels developed under Article 12. Member States must ensure harmonised labels for separate collection of material-specific packaging-waste fractions are visibly, legibly, and indelibly placed on waste receptacles, except receptacles subject to deposit and return systems.

Close the checklist with a misleading-label review. Article 12 prohibits labels, marks, symbols, or inscriptions likely to mislead or confuse consumers or other end users about sustainability requirements, packaging characteristics, or packaging-waste management options where PPWR harmonised labelling exists.