Nederland Verpakt

Labelling under the PPWR

The PPWR changes what appears on your packaging at four moments between 2026 and 2029. That means every print form, every label design and every film has to be adjusted at least twice in that period.

Anyone treating those moments separately pays twice for the same print work. Anyone planning them together with an existing redesign pays once.

12 August 2026 — name, address and identification number

This is the obligation missing from most Dutch summaries of the PPWR, and the first of all the labelling requirements to take effect. From 12 August 2026 the packaging must show — or make accessible via a QR code on the packaging: the manufacturer’s name, postal address, and an electronic means of communication. In addition, every packaging gets a type, batch or serial number. If that is physically impossible on the packaging, it goes on the packaged product.

The importer adds its own details. If you sell under your own brand, you are the manufacturer — even if someone else prints the box, and even if you are a café with your own printed cups.

12 February 2027 — the Green Dot disappears

From that date the Green Dot symbol may no longer appear on the packaging, unless it is made accessible via a QR code. The reasoning: the symbol tells the consumer nothing about what to do with the packaging, even though it looks as if it does. Verpact has in fact advised against using it for years.

Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check

12 August 2028 — the harmonised EU label

This is the big one. From 12 August 2028 every packaging placed on the EU market carries a harmonised label with two parts: the material composition (a pictogram plus an alphanumeric code) and a sorting instruction.

CodeMaterial
PP01paper and cardboard
PP02a–gplastics, subdivided by type
PP03glass
PP04steel
PP05aluminium
PP06wood
PP07textile
PP12composite

These codes come from the regulation. The exact design of the pictograms and the wording of the sorting instructions are not yet fixed: they will be set in an implementing act. The Joint Research Centre issued its advisory report on the disposal-instruction logos in January 2026, which serves as the basis. The implementing act must be in force by 2028 at the latest.

The subdivision of PP02a through PP02g by plastic type is also specified there. So you now do know that the label is coming and what information it must carry, but not the pictogram yet. Reserve the space in your design; fill it in later.

The end of clashing national labels

Article 12 bans labels that confuse the consumer about characteristics for which the PPWR has a harmonised label. That is unmistakably aimed at national systems such as the French Triman logo. The European Commission referred France to the Court of Justice on this in July 2025. At the time of writing there was no ruling yet. If you sell in several member states, this is the point at which you can go from seven label variants to one — but not before that case is settled. Check the state of play before you redesign your labels.

12 February 2029 — reusable label and QR code

Reusable packaging gets, from that date, a permanently applied reusable label and a QR code (or other open data carrier) that points to the return points and how the reuse system works. Permanent means: it must last the entire lifespan. A sticker does not. On the same date a harmonised label arrives for packaging covered by a deposit-return system.

The QR code is not a replacement

Important misconception. From 2028 the data carrier is mandatory as a supplement to the physical label, for additional information. It does not replace the pictogram. That is a deliberate choice and a precursor to the digital product passport.

What this means in practice

A packaging going into production today is outdated on three points by 2029: no manufacturer details, no identification number, no harmonised label. Three print-form changes, or one. So plan:

  1. 2026 — add name, address, contact means and type/batch/serial number. Remove the Green Dot if it is still on there.
  2. 2027–2028 — reserve space for the harmonised label, once the implementing act sets the design.
  3. 2028–2029 — reusable label and QR code, if you place reusable packaging on the market.

And link it to your recyclability grade: the sorting instruction on the label must match what actually happens to the packaging in practice.

Take the free PPWR Check

Answer eight questions about your role, market, material and packaging type. You receive your personal scorecard by email — including a timeline with your deadlines and an overview of suppliers per bottleneck.

Go to the PPWR Check

Informative self-check. Not legal advice.

Disclaimer. The PPWR Check on Nederland Verpakt is an informative self-check, based on Regulation (EU) 2025/40 as published in the Official Journal of the EU on 22 January 2025 and on publicly available guidance from the European Commission and specialised law firms. The outcome is not legal advice and may be incomplete or outdated — parts of the regulation will be filled in over the coming years through delegated and implementing acts, and Member States may impose additional or stricter requirements. Nederland Verpakt accepts no liability for decisions taken on the basis of this check. When in doubt: consult a specialist or the official text at eur-lex.europa.eu.

Last checked against the official EUR-Lex text on 9 July 2026.