The EU Packaging and Packaging Waste Regulation, or PPWR, applies from 12 August 2026. Its harmonised labelling obligations take effect later, but Article 12 already sets an important technical direction: where packaging and packaged-product information is provided digitally, one standardised, open data carrier should be sufficient.
The PPWR does not turn every QR code into a DPP
Regulation (EU) 2025/40 does not require a general Digital Product Passport for every package. It does, however, introduce several digital-information cases that overlap with DPP infrastructure.
From 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later, packaging will generally require a harmonised label showing material composition. A QR code or another standardised, open digital data carrier may additionally provide information on the destination of each packaging component to support sorting.
Reusable packaging will require a label from 12 February 2029 or 30 months after the relevant implementing act enters into force, again whichever is later. Information on reuse systems, collection points, trips and rotations should be accessible through a QR code or another open carrier.
The PPWR and a product DPP are therefore legally different data domains. They can nevertheless share the same physical entry point.
One carrier with clearly separated content
Article 12(5) states the target explicitly: where Union law requires information about the packaged product through a data carrier, a single carrier should provide both product and packaging information, with the two being easy to distinguish.
This weighs against placing several unexplained QR codes on one package. A scan should lead through a stable identifier to clearly resolved resources such as:
- the Digital Product Passport of the contained product,
- packaging material and sorting information,
- reuse, return and collection-point information,
- recycled-content information where applicable,
- other legally required records.
A GS1 Digital Link can support this separation. The identifier remains in the code while a resolver directs different link types or contexts to the appropriate information. The essential qualities are openness, persistence and machine readability.
Do not merge packaging and product identity
A consumer product may change its packaging without changing the product model. Conversely, one packaging design may be used for several products. The data architecture therefore needs at least two identities:
- the identifier of the packaged product,
- the identifier or unambiguous mapping of the packaging configuration.
The common carrier can connect these layers but should not collapse them. Otherwise, a packaging change becomes a DPP change, or a formulation update accidentally overwrites sorting information.
Composite packaging adds a component structure. A carton, inner pouch, closure and label may have different materials and disposal routes. The digital representation should mirror the real packaging structure.
Requirements for physical implementation
Labels and data carriers must be visible, legible and firmly affixed, printed or engraved. If the nature or size of the packaging makes that impossible, grouped packaging or a single electronically readable code may be used as a fallback under the Regulation.
Information must also be available before purchase in online sales. Packaging data therefore belong not only in artwork and printing processes but also in PIM, shop and marketplace feeds.
A production test should check:
- scan performance after abrasion, moisture and normal deformation,
- sufficient contrast and quiet zone,
- resolution on small formats,
- a reachable fallback URL after app or resolver failure,
- correct assignment across variants and country versions.
Privacy and separation from advertising
When information is supplied electronically, only adequate and relevant personal data may be collected for the limited purpose of providing access to compliance information. The PPWR also requires this information not to be displayed together with sales or marketing content.
A mandatory scan is therefore not a lead form. Sorting information must remain accessible without an account, newsletter consent or advertising detour. Marketing resources may be offered separately through the same resolver, but must not block or obscure the regulatory route.
Open also means portable
A data carrier often remains on a package longer than a software contract lasts. A short-lived campaign URL is therefore unsuitable as a regulatory entry point.
A durable setup includes:
- a controlled domain,
- persistent identifiers rather than changing destination URLs,
- documented resolution rules,
- exportable mappings and content,
- monitoring for resolution and target resources,
- provider portability without reprinting existing packaging.
Work to complete before the labelling dates
- Inventory all existing codes and legal information requirements per package.
- Separate product and packaging identifiers in the data model.
- Design one resolver path with clear link types.
- Store material components and reuse events as structured data rather than a PDF.
- Test compliance access without tracking or marketing barriers.
- Validate print, online and fallback views using real packages.
- Monitor the implementing acts and final dates rather than recording only the earliest possible deadline.
The PPWR is an opportunity to simplify the code landscape on packaging. The right model is not “one new QR code per regulation” but “one stable identity with clearly separated, open resources”. The same physical entry point can then serve sorting information, reuse data and a DPP without confusing their legal roles.
