EU PPWR FAQs Updated August 2026 - Flipbook - Page 36
VIII.
LABELLING
1) Will labelling requirements for reusable packaging under Article 12(2) apply at the
level of each individual packaging?
Reusable packaging must be designed to ensure a minimum number of rotations, which
will be established in the delegated act to be adopted under Article 11(2). The obligation to
calculate and report on the number of rotations for reusable transport packaging will
depend on the type of reuse system. Namely, open-loop reuse systems without a system
operator are exempted from this obligation and from the obligation to bear a reusable
packaging label and a QR code.
According to Article 12(2), reusable transport packaging circulating within closed-loop
systems will have to bear a reusable packaging label and a QR code or another standardised
open digital data carrier that will allow for tracking of the individual packaging and the
calculation of its rotations. The detailed rules, including the label informing consumers that
a packaging is reusable, will be clarified in the implementing act to be adopted under
Article 12(6). This act will also specify situations when it is considered that an individual
QR code and tracking of rotations is not feasible and the calculation of rotations can thus be
made based on an average estimation.
2) Under what circumstances are labels, marks, symbols, or inscriptions considered
misleading?
Marks, symbols, labels, or inscriptions should not mislead consumers regarding sustainability
requirements of packaging such as its recyclability, recycled content, reusability, compostability,
bio-based content, hazardous substances content or waste management options (Article 12(8)).
To further understand the notion of misleading claim please refer to Directive (EU)
2024/825218Empowering Consumers for the Green Transition9. Claims are considered misleading
if they cause the consumers to make decisions that they would not otherwise make.
3) Should a packaging bear a national DRS label when it is imported from one Member
State to another?
Labelling of packaging covered by the mandatory deposit and return systems has not been
harmonised in the PPWR. Therefore, products will have to comply with the DRS label of the
Member State where they are made available on the market. Member States may require that such
packaging be marked with a 8harmonised colour label9 as specified in Article 12(1), fourth
subparagraph. If products are imported in the context of private imports, i.e. directly by the end
user and with no intention to commercialise them, this is not considered 8making available on the
market9. Member States cannot prohibit the affixing of DRS labels in place in other Member States.
4) Which are the substances of concern that need to be identified by the labelling
requirements in Article 12(7), second subparagraph?
The European Chemicals Agency (ECHA) is currently conducting a study to identify the substances
of concern (SoC) in packaging that could affect human health and those that can impact packaging
reusability and recyclability. Based on this input, the Commission will develop an implementing
act establishing the methodology for labelling of SoC by means of digital labelling.
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Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives
2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection
against unfair practices and through better information (OJ L, 2024/825, 6.3.2024)
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