PPWR and the Digital Product Passport: One Data Carrier for Product and Packaging

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026. Many packaging teams now ask whether packaging will get its own digital product passport. It will not. The PPWR does, however, say how packaging information and the product's passport should live together, and that part needs planning now.

This week Recycling Today reported on Verso, a project led by Aimplas, the Spanish plastics technology centre. Verso pilots the Digital Product Passport on plastic packaging and validates reuse systems. It works with the packaging producer ITC Packaging and the recycler Reciclemás, with funding from the Valencian institute IVACE+i and ERDF funds. Below is what the regulation text itself says.

Does the PPWR require a digital product passport for packaging?

No. The PPWR does not create a passport for packaging. Recital 9 explains that the PPWR complements the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR), "under which packaging is not addressed as a specific product category". The same recital notes that ESPR delegated acts for specific products may still add packaging requirements for those products.

What the PPWR does require is labels and, in some cases, a QR code or another "standardised, open, digital data carrier". The definition of "data carrier" is taken directly from the ESPR (Article 3(1) of the PPWR points to Article 2(29) of the ESPR). So both regulations use the same term for the code on the pack.

One data carrier for product and packaging

The rule that ties them together is in Article 12(5). Where Union law requires information on the packaged product to be provided through 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."

Recital 70 gives the reason: "There should be no multiplication of labels on packaging." It then names the passport directly. Where the packaged product is covered by the ESPR "or other Union law requiring a digital product passport, that digital product passport should also be used for providing the relevant information under this Regulation."

So if the product inside the box will carry a digital product passport, the packaging information required by the PPWR should travel in that same passport, reached through the same code, and kept clearly separate from the product data. The nearest date is for batteries: from 18 February 2027, EV batteries, LMT batteries and industrial batteries above 2 kWh placed on the EU market need a battery passport under Article 77 of Regulation (EU) 2023/1542.

What Article 12 asks for, and when

Article 12 sets several labelling duties with different dates. The ones that involve a QR code or data carrier:

Requirement	Data carrier	Applies from
Harmonised label on material composition (Art. 12(1))	Optional QR code on where each component goes, to help sorting	12 August 2028, or 24 months after the implementing acts, whichever is later
Reusable packaging label (Art. 12(2))	Mandatory QR code or other open data carrier with reuse information	12 February 2029, or 30 months after the implementing act, whichever is later
Recycled content label, where used (Art. 12(4))	QR code, where applicable, must follow the implementing act	12 August 2028, or 24 months after the implementing act, whichever is later
Packaging with substances of concern (Art. 12(1) and 12(7))	Standardised, open digital marking	Methodology by implementing act, due by 1 January 2030
EPR scheme symbol (Art. 12(9))	Only via QR code or other open digital marking	Possible by 12 February 2027

The regulation asked the Commission to adopt the label specifications by 12 August 2026 (Article 12(6)). Each obligation starts on the later of two dates: the fixed date, or 24 months (30 for reusable packaging) after the implementing act enters into force. A late act pushes the obligation back.

What the data carrier must do for reusable packaging

For reusable packaging, Article 12(2) says what the data carrier must contain. The QR code or other data carrier must give information on reusability, "including the availability of a local, national or Union-wide re-use system and information on collection points". It must also facilitate "the tracking of the packaging and the calculation of trips and rotations", or an average estimate where that calculation is not feasible.

Article 12(3) exempts open loop systems that have no system operator. Every other reuse system needs a data model that can count how many times a container went around. Validating reuse systems is also one of the goals of the Verso project.

Rules for what sits behind the code

Article 12(5) also sets rules for any information given by electronic means under paragraphs 1, 2 and 4:

the label and data carrier must be affixed, printed or engraved visibly, legibly and so they cannot be easily erased;
the same information must be available to buyers before an online purchase;
personal data may be collected only to give access to the compliance information;
the information "shall not be displayed with other information intended for sales or marketing purposes";
the language is the one set by the Member State where the packaging is sold.

The marketing rule affects page design. A QR code that opens a sales page with offers would mix the two, so the compliance information needs its own view.

What to do now

For most packaging the binding dates are two to three years away, but collecting data from suppliers takes time. Four steps to start with:

Map which of your products will carry a digital product passport, and when. Batteries have the nearest date, and other groups follow as ESPR delegated acts are adopted. For those products, plan the packaging data inside the same passport instead of a second code.
List the packaging data you already hold (material composition, recycled content, reusability) and who in your supply chain owns each item. The technical documentation you prepared under PPWR Annex VII is a good starting point.
Keep compliance data apart from marketing content. One code can open a structured passport page, but not a sales page.
Keep your documents in order. Under Article 62(1) of the PPWR, a missing or incorrect declaration of conformity, a QR code or data carrier that does not give access to the required information, and incomplete technical documentation all count as formal non-compliance. Our guide to the PPWR declaration of conformity covers the first of these.

Hoken Pass is digital product passport software for SMEs. Each published passport gets a public page with a QR code and a qualified eIDAS timestamp from InfoCert, and you can start on the free plan with 3 passports. For the wider ESPR picture, see our ESPR compliance page.

Frequently asked questions

Does the PPWR require a digital product passport for packaging?

No. The PPWR does not create a separate passport for packaging, and packaging is not a product category under the ESPR (PPWR recital 9). The PPWR requires labels and, in some cases, a QR code or other open data carrier.

What does Article 12(5) of the PPWR say about data carriers?

Where Union law requires information on the packaged product through a data carrier, a single data carrier must provide the information for both the product and the packaging, and the two must be easy to tell apart.

When does the QR code for reusable packaging become mandatory?

From 12 February 2029, or 30 months after the Commission's implementing act enters into force, whichever is later (Article 12(2)). Open loop systems without a system operator are exempt (Article 12(3)).

Can the packaging QR code link to marketing content?

Not for the compliance information. Article 12(5) says that information given by electronic means shall not be displayed with information intended for sales or marketing purposes.

When does the harmonised packaging label apply?

From 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later (Article 12(1)).

Sources

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