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PPWRChecklistEU

PPWR labelling checklist Articles 12 and 13

A cited checklist for PPWR packaging labels, digital carriers, information, deposit-return labels, and matching waste-receptacle labels.

Use it to review artwork, online product pages, QR-code content, and waste-bin labelling before packaging is placed on the EU market.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
4 sections8 primary sources
Overview

PPWR labelling work should start with the exact Article 12 label category that applies to each packaging unit, then check whether Article 13 requires matching waste-receptacle labels in the Member State collection system. This checklist focuses on what the regulation itself says: material-composition labels for consumer sorting, compostable-packaging messages, identification, recycled-content and biobased-plastic labels when used, deposit-return labels, digital access, online pre-purchase access, language, durability, and misleading-label controls.

Section 1

Classify the label requirement before artwork starts

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.

, 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.

The Commission's June 2026 guidance treats Article 12 packaging labelling as exhaustive and fully harmonised except for deposit and return systems. It also interprets the material-sorting label as inapplicable to packaging of specified medicinal products and devices that can only be used by professional end users. Keep that guidance-based professional-use conclusion separate from the narrower Article 12(11) derogation for immediate and outer medical or medicinal packaging where space or safe use creates the issue.

  • Confirm whether the item is sales packaging, grouped packaging, transport packaging, e-commerce packaging, service packaging, , or packaging covered by a deposit and return system.
  • For the general material-composition label, confirm that the label uses harmonised pictograms and is easily understandable, including for persons with disabilities, once the implementing specifications apply.
  • For compostable packaging covered by Article 9, check that the label says the material is compostable, not suitable for home composting, and not to be discarded in nature.
  • For , check that the packaging is labelled as reusable and that reuse-system and collection-point information is available through a QR code or other standardised, open, digital data carrier.
  • For deposit-return packaging, check whether a clear national label is required and whether a harmonised colour label becomes required or allowed under the relevant implementing act and Member State rules.
Recommended next step

Turn PPWR labelling into release-ready controls

This checklist helps connect PPWR label categories, artwork approval, QR-code content, online product-page evidence, Member State language checks, and waste-receptacle alignment before packaging release.

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Answer PPWR labelling questions with cited source material.

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Review Article 12 and Article 13 labelling scope, evidence, and rollout steps with Sorena.

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Section 2

Check timing, transition stock, and implementing-act dependencies

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. 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.

  • Record which Article 12 paragraph drives the deadline for the packaging unit: paragraph 1 for material composition, paragraph 2 for , or paragraph 4 for voluntary recycled-content or biobased-plastic labels.
  • Track whether the relevant implementing act has entered into force before converting the statutory fallback dates into artwork-release deadlines.
  • For packaging manufactured in the Union or imported before the relevant Article 12 deadline, check the Article 12 transition rule allowing continued market availability for three years from entry into force of the relevant labelling requirements.
  • Keep a dated source reference for any claim about substances-of-concern digital marking because the detailed methodology is tied to the 1 January 2030 implementing-act deadline.
  • Flag stock-keeping units that depend on Member State deposit-return or language choices, because those decisions may affect packaging before central artwork is finalised.
Section 3

Review visibility, digital access, online sales, and languages

Article 12 does not only ask whether a symbol exists. It requires labels and, for , 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.

  • Check that the physical label placement survives normal handling and does not conflict with product-safety, food, medical, veterinary, or other mandatory product labels.
  • For , test the QR code or digital carrier, confirm it points to reuse-system availability and collection points, and check that it facilitates tracking and the calculation of trips and rotations or, if that calculation is not feasible, an average estimation. Record the Article 12(3) derogation where an open-loop reuse system has no system operator.
  • For online product pages, ensure the Article 12 label information is available before purchase, not only after delivery or inside downloadable artwork files.
  • When a single data carrier is used for both product information and packaging information, confirm that the two information sets are easy to distinguish.
  • For electronic information, avoid collecting personal data beyond the limited purpose of giving access to compliance information, and do not mix the required compliance information with sales or marketing content.
  • If the business identifies extended producer responsibility (EPR) participation, use only the QR-code or open digital-marking route in Article 12(9); Commission guidance states that physical EPR labels are not allowed under that provision.
Section 4

Align waste-receptacle labels and prevent misleading marks

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.

  • For each market, compare the packaging material label with the corresponding waste-receptacle label used for that material-specific collection fraction.
  • Where a receptacle collects more than one packaging-waste fraction, check whether more than one harmonised label is needed.
  • Remove voluntary disposal icons, recycling marks, colour systems, or reuse claims that could conflict with the PPWR harmonised label once it applies.
  • For deposit-return packaging, separate the deposit and return system (DRS) label review from normal waste-receptacle labelling because Article 13 excludes deposit-return receptacles.
  • Keep the final approval file with the Article 12 category, Article 13 market check, artwork version, QR-code destination, online page evidence, language set, source URL, and approver.
Primary sources

References and citations

Commission Notice - Guidance document for Regulation (EU) 2025/40
eur-lex.europa.eu3 citations
Referenced sections
  • Non-binding Commission interpretation for harmonised packaging labels, professional-use scope, EPR digital identification, and reusable-packaging transitions.
  • Non-binding Commission guidance on exhaustive harmonisation, professional-use packaging, voluntary content labels, deposit-return labels, and the medical or medicinal packaging derogation.
  • Non-binding Commission guidance confirming that Article 12(9) permits EPR identification only through a QR code or other standardised, open digital-marking technology.
European Commission overview of the Packaging and Packaging Waste Regulation
environment.ec.europa.eu2 citations
Referenced sections
  • The Commission overview explains the consumer purpose of clearer packaging labels: showing what packaging is made of, where to bin it, and how to return it for reuse.
  • The Commission overview supports the high-level implementation context that the new Regulation begins applying from mid-2026 and replaces the existing Packaging Waste Directive.
"where to bin it"
More quoted passages
"will begin to apply from mid-2026"
Regulation (EU) 2025/40 on packaging and packaging waste
data.europa.eu
Referenced sections
  • Primary legal source for PPWR Articles 12 and 13, including label categories, implementing-act timing, digital carrier rules, online access, language, transition stock, misleading-label controls, and waste-receptacle labels.
"LABELLING, MARKING AND INFORMATION REQUIREMENTS"
Regulation (EU) 2025/40, Article 12 - labelling of packaging
data.europa.eu
Referenced sections
  • Article 12 identifies the packaging label categories used in this checklist: material composition, compostability, substances of concern, reusable packaging, recycled-content and biobased-plastic labels, deposit-return labels, and digital carriers.
"Labelling of packaging"
Regulation (EU) 2025/40, Article 13 - labelling of waste receptacles
data.europa.eu
Referenced sections
  • Articles 12 and 13 support the waste-receptacle and artwork checks: harmonised material-specific labels, visible and indelible placement, the deposit-return exclusion, correspondence between receptacle and packaging labels, and removal of misleading marks.
"Labelling of waste receptacles"

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