Two EU regulations mention digital data carriers, and they are often confused. This page sets out what the Packaging and Packaging Waste Regulation requires on packaging, what the Ecodesign Regulation requires for a product passport, and where the two can meet on a single code.
Ask us which data carrier you need
Summary
The PPWR (Regulation (EU) 2025/40) and the ESPR (Regulation (EU) 2024/1781) both rely on digital data carriers, but they regulate different things. The PPWR regulates packaging and, in defined cases, requires a QR code or another standardised, open digital data carrier on it. The ESPR creates the Digital Product Passport for product groups covered by a delegated act. A QR code on a package is therefore not automatically a passport, and a passport does not automatically replace the packaging labels.
Packaging is not on the statutory priority list in Article 18(5) of the ESPR, which names iron and steel, aluminium, textiles, furniture including mattresses, tyres, detergents, paints, lubricants, chemicals, energy-related products and ICT and other electronics. As a result there is no ESPR passport duty for packaging as such, unless and until a delegated act is adopted that covers it. The passport duty attaches to the product group, and the packaging of that product can simply be one place where the data carrier sits.
What the PPWR asks for on packaging is narrower. Reusable packaging must bear a reusability label and a QR code or another standardised, open digital data carrier that carries information on the re-use system, collection points and the tracking of trips and rotations, from 12 February 2029 or 30 months after the Article 12(6) implementing act enters into force, whichever is later. Packaging that is part of an extended producer responsibility scheme may, by 12 February 2027, be identified through a symbol in a QR code or another standardised, open digital marking.
Packaging containing substances of concern must be marked by standardised, open, digital-marking technologies. The Commission has to adopt the methodology by 1 January 2030, and it must ensure that the marking includes at least the name and concentration of the substance of concern present in each material in a packaging unit.
The point where the two regimes meet is Article 12(5) of the PPWR. Where Union law requires information on the packaged product to be provided via a data carrier, a single data carrier shall be used for the information on the product and on the packaging, and the two sets of information shall be easily distinguishable. The same paragraph says that digital information must not be displayed together with sales or marketing information and that only the personal data needed for access may be collected. On the ESPR side, the passport is linked through a data carrier to a persistent unique product identifier, and the carrier may be on the product, its packaging or accompanying documentation as the delegated act specifies.
Four things that are easy to mix up
The same QR code can serve more than one purpose, but each purpose has its own legal source.
- PPWR digital label or marking
- Information on packaging provided through a QR code or another standardised, open digital data carrier, in the cases listed in Article 12: reusability and re-use system information, an optional extended producer responsibility symbol, and digital marking of substances of concern. These belong to the packaging and to the party that places it on the market.
- ESPR Digital Product Passport
- A product-specific data set accessible through a data carrier, required only for product groups covered by a delegated act under Article 4. It belongs to the product and to the economic operator placing the product on the market.
- Unique identifier
- The ESPR requires the passport to be connected through a data carrier to a persistent unique product identifier. Article 12 of the PPWR, which sets out the labels and data carriers, does not require a persistent unique product identifier.
- Single data carrier rule
- Where Union law requires a data carrier for the packaged product, only one data carrier is used for both product and packaging information, and the two must be easily distinguishable. The rule applies from the date of the labelling requirements.
Side by side: what each regulation requires
| Article | Requirement | Who | Applies from | Status | Depends on |
|---|---|---|---|---|---|
| PPWR 12(9) | Packaging in an EPR scheme may be identified by a symbol in a QR code or other standardised open digital marking that shows the producer fulfils its EPR obligations. The symbol must not mislead about recyclability or reusability. This is an option, not a duty. | Producers | 12 February 2027 By 12 February 2027. | — | |
| PPWR 12(5) | Labels and data carriers must be visible, legible and durable. Where Union law requires a data carrier for the packaged product, a single carrier covers product and packaging information, easily distinguishable. No marketing content beside compliance information; only the personal data needed for access. | Manufacturers and importers | 12 August 2028 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later. | Implementing acts on the harmonised label and its specifications, including digital formats; Implementing acts on digital marking of material composition | |
| PPWR 12(2) | Reusable packaging bears a reusability label and a QR code or other open digital data carrier with re-use system information, collection points and tracking of trips and rotations. Not required for open-loop systems without a system operator. | Operators placing reusable packaging on the market | 12 February 2029 12 February 2029, or 30 months after the Article 12(6) implementing act, whichever is later. | Implementing acts on the harmonised label and its specifications, including digital formats | |
| PPWR 12(1) | Packaging containing substances of concern is marked by standardised, open, digital-marking technologies; the methodology act is due by 1 January 2030. | Manufacturers and importers | 1 January 2030 Methodology act due by 1 January 2030; marking follows that act. | Implementing acts on digital marking of material composition | |
| ESPR 9, 10 | A passport is required only where a delegated act covers the product group. The passport is linked via a data carrier to a persistent unique product identifier; the carrier is on the product, its packaging or accompanying documentation as that act specifies. | Economic operators placing covered products on the market | Set by the delegated act for each product group. | Depends on an act not verified as adopted | Product-specific delegated acts that create passport obligations |
| ESPR 18(5) | Packaging is not among the priority product groups the first working plan had to prioritise. | European Commission | 18 July 2024 Statutory list for the first working plan, due by 19 April 2025. | — |
Which one do you need?
If you place packaging on the market and your packaging is reusable, the PPWR requires the reusability label and a digital data carrier from the Article 12(2) date, regardless of any product passport. If your packaging contains substances of concern, the digital marking applies once the Commission has adopted the methodology. If neither applies, the PPWR does not oblige you to put a QR code on the pack, although you may choose to add one.
If you make a product that belongs to a group covered by an ESPR delegated act, the passport is a product duty, and the delegated act tells you where the data carrier must be placed. When that place is the packaging, Article 12(5) of the PPWR then means you should not add a second, separate code for the packaging data. Plan one carrier and keep the two data sets distinguishable.
If neither regime reaches your product, do not build a passport in advance on the assumption that packaging will be covered. Article 18(5) of the ESPR does not list packaging, and the ESPR text names no specific carrier format or data model. The safest preparation is to keep clean, structured data about materials and products that either regime could later ask for.
What the texts leave open
The provisions read for this page do not settle the following, and we offer no view on them.
- The concrete data format behind a PPWR data carrier, which depends on implementing acts that were due by 12 August 2026 and whose adoption we have not verified.
- Whether and when a delegated act will cover packaging as a product group.
- How a single carrier should be structured technically so that product and packaging information stay easily distinguishable.
Exemptions
Exemptions differ between the two regimes and are written article by article. For the passport, the Commission may exempt a product group where technical specifications are unavailable or where other Union law already provides equivalent digital information (ESPR Article 9(4)). PPWR exemptions for labelling are covered on the PPWR labelling page.
Acts that decide the dates
These acts determine when the digital requirements take practical effect. We have not verified the adoption status of any of them.
- Implementing acts on the harmonised label and its specifications, including digital formats (PPWR Article 12(6)). Due by 12 August 2026.
- Implementing acts on digital marking of material composition (PPWR Article 12(7)). Due by 12 August 2026; the method for substances of concern is due by 1 January 2030.
- Product-specific delegated acts that create passport obligations (ESPR Article 4). Application not earlier than 18 months after entry into force, except in duly justified cases.
Where to start
This list is a practical suggestion, not wording taken from either Regulation.
- List the QR codes and data carriers you already print on packaging and note what each one links to.
- Check whether any of your packaging is reusable or contains substances of concern, as these trigger the PPWR digital requirements.
- Check whether your product group is covered by an adopted ESPR delegated act.
- If both could apply to the same product, agree internally on one data carrier and who owns its content.
- Keep marketing content off any code that carries compliance information.
Frequently asked questions
Does packaging need a Digital Product Passport?
Packaging is not on the ESPR statutory priority list (Art 18(5)). PPWR separately requires labels and, in some cases, QR codes or other digital data carriers on packaging.
Can one QR code serve both product and packaging?
PPWR Art 12(5) requires a single data carrier where Union law requires a data carrier for the packaged product, with product and packaging information easily distinguishable.
Sources
- Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 22.1.2025: Article 12
- Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, OJ L, 28.6.2024: Articles 9, 10, 18
Facts last checked against the Official Journal text on 6 November 2026.
This page is general information, not legal advice. Obligations depend on your role, packaging and Member State. Check the official text on EUR-Lex.