Every product that gets a digital product passport also ships in packaging, and from 2028 that packaging gets its own harmonised label under Regulation (EU) 2025/40. Article 12(5) of that regulation settles what happens when the two meet: if Union law already requires a data carrier on the product, the packaging information goes through the same carrier, and the two sets of information must be easy to tell apart. The implementing act that defines the label was due on 12 August 2026. It entered the Commission register on 14 September 2026, with no draft and no feedback window yet. Here is what the article says, what the delay does to the dates, and why the design decision does not wait for the act.
Why a passport article is talking about packaging
The packaging and packaging waste regulation, PPWR for short, is not a passport law. It has no registry, no unique identifier and no delegated acts per product group. But it lands on the same physical object as the passport, and its Article 12 is written with the passport in mind. The recitals say it plainly: where the packaged product is covered by the ecodesign regulation or other Union law requiring a digital product passport, that passport should also be used to convey the packaging information.
The operative sentence is the last paragraph of Article 12(5). Where Union law requires information on the packaged product to be provided via a data carrier, a single data carrier is to be used for both the product information and the packaging information, and both sets must be easily distinguishable. That is a constraint on how you build the passport page behind the QR code, and it exists today, in a regulation already in force, even though the label it refers to does not exist yet.
What Article 12 actually requires, and when
The article stacks several obligations with separate dates. Reading them together:
- Material composition label (paragraph 1). Packaging placed on the market must carry a harmonised label with pictograms showing what it is made of, so consumers can sort it. Applies from 12 August 2028 or 24 months after the implementing act enters into force, whichever is later. Transport packaging is out, except e-commerce packaging. Packaging in a deposit return system is out.
- Substances of concern (paragraph 1, second subparagraph). Packaging containing them must be marked using standardised, open digital technologies. The methodology for that marking is due only by 1 January 2030.
- Optional component QR (paragraph 1, third subparagraph). On top of the label, you may add a QR code or other standardised, open data carrier that tells the consumer where each separate part of the packaging goes.
- Reusable packaging (paragraph 2). From 12 February 2029 or 30 months after the act, whichever is later: a label saying the packaging is reusable, plus a QR code or equivalent carrier with reuse information and enough tracking to count trips and rotations.
- Recycled content and bio-based content claims (paragraph 4). Voluntary, but if you make them on the packaging, the label and any carrier must follow the specifications of the implementing act and the calculation method under Article 7.
- Online sales (paragraph 5). Whatever is on the label must also be available to the end user before purchase when selling online. The digital information must not be mixed with marketing content, and personal data collection is limited to what is needed to show the information.
Two more provisions matter for planning. Paragraph 9 allows, until 12 February 2027, identification of packaging under an extended producer responsibility scheme through a symbol inside a QR code or other open digital marking. Paragraph 12 lets packaging manufactured or imported before the deadlines be sold for up to three years after the requirement starts.
The deadline the Commission missed
Paragraphs 6 and 7 gave the Commission until 12 August 2026 to adopt the implementing acts: the harmonised label itself, the specifications for labelling including digital labelling, and the methodology for showing material composition through digital marking. On 14 September 2026 an entry for the label act appeared in the Commission register of initiatives under number 19243, reference Ares(2026)8548456. Its stage is planning. The draft implementing decision is listed as upcoming, and no feedback window has opened. The methodology act under paragraph 7 has no visible entry at all.
The consequence is arithmetic, and it works the way it worked for portable battery durability values: the label date is the later of 12 August 2028 and 24 months after the act enters into force. An act adopted at the end of 2026 and in force in early 2027 puts the label in early 2029. An act adopted later pushes it further. Nobody can print a compliant label today, because the pictograms do not exist, and nobody should try to guess them.
This is the same pattern we have documented in the battery regulation, where two acts were due on 18 August 2026, the legitimate-interest access rules and the recycled content methodology, and neither arrived on time. The difference here is that the PPWR ties your own date to the Commission's, so the slip protects you rather than exposing you. What it does not do is remove the requirement.
Seven thousand people wrote in about the other packaging act
The register entry for the label is empty, but its neighbour is not. The draft implementing regulation on the format for registering in and reporting to the national producer registers, entry 15352, took feedback from 6 August to 10 September 2026. When we checked on 15 September it showed more than seven thousand responses. The DPP registry draft, for comparison, collected 222.
The last three hundred responses, sorted by date, split almost evenly between companies, individual citizens and business associations, with Germany far ahead and Poland at thirteen. The recurring theme is the size threshold: the draft reserves a simplified reporting form for producers placing less than ten tonnes of packaging a year on a given national market. Small sellers, resellers and single-person businesses wrote in to say what the simplified form should and should not ask. That is the audience the passport files never reach, and it is exactly the audience that will be asked, in 2028 or 2029, to put a packaging label next to a product QR code.
What this changes in how you build a passport
The passport regulations tell you what to say about the product. Article 12(5) tells you that the packaging will speak through the same code. Three design consequences follow, and none of them needs the implementing act to be adopted first.
- One carrier, two sections. The page behind the QR code needs a packaging section that a reader can distinguish from the product data at a glance. Distinguishable is the legal word; in practice it means a separate heading, not a footnote inside the materials list.
- Packaging is a product attribute per SKU. Material composition per component, whether the packaging is reusable, whether it carries a recycled content claim. If your product data model has no place for packaging, the passport will not have one either.
- Do not put marketing on that page. Paragraph 5 forbids mixing the electronic packaging information with sales or marketing content. A passport page that doubles as a product landing page will need a clean split.
This is why a passport template should carry a packaging section from day one, as a set of fields that stay empty until you fill them. There is no obligation to fill them today. There is a good reason not to design them out.
What this is not
This is not a packaging passport. The PPWR creates labels and registers, not passports, and it does not register anything in the DPP registry.
This is not a reason to print anything now. The pictograms, formats and digital specifications come from an act that has not been drafted. Anything printed today is a guess, and paragraph 8 prohibits labels that could mislead consumers about the packaging's sustainability properties.
This is not a textile, furniture or battery rule. It is a rule for every packaged product placed on the EU market, which is why it lands on every passport.
How to check this yourself
The regulation is free to read. EUR-Lex blocks automated downloads, but the human version is at https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng; the provisions cited here are Article 12(1), (2), (4), (5), (6), (7), (9) and (12). The register entry for the label act is at https://ec.europa.eu/info/law/better-regulation/brpapi/groupInitiatives/19243?language=EN and the producer register draft at https://ec.europa.eu/info/law/better-regulation/brpapi/groupInitiatives/15352?language=EN. Both show the stage, the feedback window if any, and the response count. All figures above are as of 15 September 2026.
What to do this week
- List your packaging per product, component by component, with the material of each. This is the raw material of the 2028 label and it is also the raw material of the passport section.
- Decide where packaging lives in your data. A column on the product record is enough. A separate spreadsheet nobody updates is not.
- Put 12 August 2028 in the calendar as a floor, not a date, and add a note to check entry 19243 for the feedback window. Four weeks is the usual length, and it is your one chance to comment on the pictograms you will be printing.
- If you sell online, note that the label information has to appear before purchase. That is a product page change, not a packaging change.
FAQ
Does the packaging information go into the DPP registry?
No. The registry stores unique identifiers of product passports. Packaging information sits on the passport page behind the carrier; the registry does not see it.
My product has no passport obligation. Does Article 12 still apply?
Yes, to the packaging. The single-carrier rule only bites where Union law requires a carrier on the product. Without one, the packaging label stands alone, and you may still add a voluntary QR code for sorting.
Can I use the same QR code for the passport, the packaging label and the deposit symbol?
The regulation asks for one carrier where a product carrier is required, with the sets easily distinguishable. Deposit return packaging is excluded from the material label and has its own labelling rules under paragraphs 1 and 10.
What if I print the label early, based on a draft?
Paragraph 8 prohibits labels that could mislead or confuse consumers on the sustainability characteristics for which the regulation sets harmonised labelling. A pictogram that later differs from the adopted one is a risk with no upside.
Is the ten-tonne threshold in the producer register draft final?
No. The draft closed its feedback window on 10 September 2026 with several thousand responses on precisely that point. The adopted text may differ.
Łukasz Głuch
Builds DPPera, a digital product passport tool for small and medium-sized companies. Reads the delegated acts so you do not have to. Writes about what he checked in the registry, not about what vendors promise.
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