When does PPWR take effect?

It already has. Regulation (EU) 2025/40 has applied since 12 August 2026. Recycled content targets phase in from 2030.

Does PPWR require a Digital Product Passport for packaging?

No. PPWR requires digital labelling and data availability for packaging, but there is no packaging passport. What matters for passport design is Art. 12(5): where both the product and its packaging need a data carrier, there must be a single carrier, so plan for one QR that serves both.

What recycled content targets apply?

By 2030, contact-sensitive plastic packaging needs 30% recycled content, and non-contact plastic packaging needs 35%. These increase further by 2035 and 2040.

Are small packaging producers affected?

PPWR applies to all packaging placed on the EU market. However, micro-enterprises and small producers may benefit from some exemptions or extended timelines.

How does SUP interact with PPWR?

The Single-Use Plastics Directive remains in force. PPWR adds broader rules. Products affected by SUP (like plastic cups with markings) must comply with both.

Can LabelEU generate consumer sorting labels?

Yes. You can create digital sorting instructions in the passport that consumers access by scanning the QR code, complementing or replacing physical sorting marks.

EU product compliance · Packaging

Digital Product Passport for Packaging

PPWR is overhauling packaging rules across the EU. The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026. It sets recycled content targets, recyclability requirements and digital labelling for packaging. There is no packaging passport, but Art. 12(5) requires a single data carrier where both the product and its packaging need one, which is a design decision worth making early.

PPWR applies (binding)

12 Aug 2026

Packaging Regulation

2025/40

PPWR passport status

No passport

Applicable EU regulations

Regulations covering packaging

Packaging and Packaging Waste Regulation

(EU) 2025/40 (PPWR)

Active

Applies since 12 August 2026, replacing the Packaging Directive with directly applicable rules on recyclability, recycled content, reuse targets and digital labelling. It does not create a packaging passport.

Key articles

Art. 12(5) - One data carrier for the product and its packaging where both are required

Single-Use Plastics Directive

(EU) 2019/904 (SUP)

Active

Bans certain single-use plastic items, requires labelling of others, and sets collection targets for plastic bottles.

Key articles

Art. 4 - Consumption reduction
Art. 7 - Marking requirements
Art. 9 - Collection targets

Ecodesign for Sustainable Products Regulation

(EU) 2024/1781 (ESPR)

Active

ESPR may apply to packaging materials or packaging products in future delegated acts, adding DPP requirements.

Key dates

Compliance timeline for packaging

Each entry is tagged with how firm it is. Binding means the date is fixed in the Official Journal. Adopted means the instrument exists but the date has not arrived. Indicative means it comes from a Commission working plan or our own estimate and is not law.

3 Jul 2021

Binding

SUP bans take effect

Single-use plastic cutlery, plates, straws and other listed items left the EU market.

Directive (EU) 2019/904

12 Aug 2026

Binding

PPWR applies

Regulation (EU) 2025/40 is now in application. Art. 12(5) requires a single data carrier for the product and its packaging where both are required, so the passport QR and the packaging QR must eventually be one code.

Reg. (EU) 2025/40 Art. 12(5)

~2030

Adopted, not yet applicable

Recycled content targets

Recycled content minimums for plastic packaging phase in, at 30% for contact-sensitive packaging and 35% for other packaging.

Reg. (EU) 2025/40

What compliance reviewers look for

DPP data requirements for packaging

Where no delegated act has been adopted for this category, the list below is our reading of the likely data set, not a legal requirement. Collecting it early is still the work that takes the longest. Everything below is supported out of the box in LabelEU.

Materials and recyclability

Packaging material composition breakdown
Recyclability assessment and design for recycling
Recycled content percentage per material
Compostability certification (if claimed)

Labelling and marking

Harmonized sorting label for consumers
Material identification marking
SUP marking (if applicable)
Reuse scheme information (if applicable)

Targets and compliance

Recycled content targets met (2030 milestones)
Packaging minimization demonstration
Producer responsibility scheme registration
GS1 Digital Link URL and QR code

How LabelEU helps

Built for packaging compliance

Recyclability assessment tools

Record design-for-recycling criteria, material layers, and barrier coatings. Track whether your packaging meets PPWR recyclability grades.

Recycled content declarations

Enter recycled content percentages per material type. LabelEU compares your data against 2030 and 2035 PPWR targets.

Digital sorting labels

Generate consumer-facing sorting instructions linked from a QR code. Meet harmonized labelling requirements digitally.

Product examples

Common packaging and their key requirements

PET beverage bottle

25% recycled PET by 2025, 30% by 2030
Tethered cap requirement
Collection scheme participation

Corrugated shipping box

Recycled fiber content percentage
Design for recycling assessment
Packaging minimization evidence

Flexible plastic pouch

Mono-material design or recyclability plan
Material identification marking
Consumer sorting instructions

Glass food jar

Reuse scheme compatibility
Closure material declaration
Sorting and recycling label

Frequently asked questions

Common questions about Digital Product Passports for packaging.

Ready to create packaging passports?

Ship the QR with confidence today and keep updating the passport as your supply chain evolves.