One QR code for product and packaging: what PPWR Article 12 requires

Since 12 August 2026 every package placed on the EU market falls under the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. Most of the attention has gone to recycled content, reuse targets and a sorting label that does not exist yet. The sentence that decides how many codes end up printed on your pack has had far less. It sits at the end of Article 12(5):

Where Union law requires information on the packaged product to be provided via a data carrier, a single data carrier shall be used for providing the information required for the packaged product and for the packaging, and both shall be easily distinguishable.

One code per pack, then, not one code per regulation. The rule is conditional, and the condition is starting to be met. From 18 February 2027 every battery sold in the EU carries a QR code, and the first ESPR product groups follow. Whenever one of those products is sold packaged, the packaging data and the product data will share a carrier, so it is worth deciding now where that carrier points.

PPWR does not create a passport for packaging

The Packaging and Packaging Waste Regulation does not use the words "digital product passport" anywhere in its articles. Packaging gets a different set of tools. The manufacturer carries out a conformity assessment, keeps technical documentation under Annex VII and draws up an EU declaration of conformity under Article 39, which follows the model in Annex VIII and must be "continuously updated". Article 15(5) asks for a type, batch or serial number on the packaging. Article 15(6) asks for the manufacturer's name and postal address "on the packaging or on a QR code or another data carrier".

All of these have applied since 12 August 2026, and none of them is a passport. When you read that PPWR introduces a "packaging DPP" from 2027 or 2028, the claim does not come from the regulation.

It also pays to check who the manufacturer is. Article 3(1), point (13), covers anyone who "manufactures packaging or a packaged product". As a rule, a furniture maker that boxes its own wardrobes is the PPWR manufacturer of that box. The furniture maker, not the box supplier, draws up the declaration of conformity and, under Article 39(4), assumes responsibility for the packaging's compliance.

Where PPWR points to the product passport

The link between packaging and the Digital Product Passport is spelled out in recital 70 of Regulation (EU) 2025/40. It opens with "There should be no multiplication of labels on packaging" and goes on: where the packaged product is covered by the ESPR, Regulation (EU) 2024/1781, "or other Union law requiring a digital product passport, that digital product passport should also be used for providing the relevant information under this Regulation".

Recitals explain a regulation; they do not bind on their own. The binding rule is the single-data-carrier sentence in Article 12(5). Recital 70 shows what the legislator expected it to look like in practice: the packaging information travels inside the product's passport, behind the same code.

Two other provisions shape how a shared code should behave. Under Article 12(5), label information provided electronically "shall not be displayed with other information intended for sales or marketing purposes". Article 15(7) says the manufacturer's identification details must not obscure, or be confused with, information that other EU acts require for the packaged product. On a phone screen we read that as one scan, two clearly separated sets of data, and no marketing content shown alongside the label information.

Which products will need a single carrier, and from when

The single-carrier rule in PPWR Article 12(5) applies only where another EU act already puts a data carrier on the product. Batteries are the first large group. Under Article 13(6) of the Batteries Regulation, Regulation (EU) 2023/1542, all batteries carry a QR code from 18 February 2027. For EV batteries, batteries for light means of transport such as e-bikes and e-scooters, and industrial batteries above 2 kWh, that code leads to the battery passport required by Article 77. On our reading, a battery sold in a box from that date has one code to serve both regulations.

Products under the ESPR follow as their delegated acts are adopted. The Commission's own timeline expects the first one, for iron and steel, at the end of 2026, with at least 18 months before the passport becomes mandatory; textiles are expected in 2027 and furniture in 2028. These are expected dates, not fixed ones. Outside the ESPR, detergents get a passport from 23 September 2029 at the earliest under Regulation (EU) 2026/405, and toys from 1 August 2030 under the Toy Safety Regulation, Regulation (EU) 2025/2509.

If no EU act requires a data carrier for your product, Article 12(5) does not apply to you, and PPWR does not yet require a QR code on your packaging (reusable packaging will need one from 2029). The QR code mentioned in Article 12(1) is optional: economic operators "may" place one.

What packaging data will sit behind the code, and when

Regulation (EU) 2025/40 fills the packaging side of a shared code in stages. These are the dates that matter for a data carrier:

• Since 12 August 2026, the manufacturer's name and postal address may be given through a QR code or another data carrier instead of printed on the pack (Article 15(6)).
• From 12 February 2027, if your packaging shows that you take part in an extended producer responsibility scheme, as the Green Dot does, that identification is lawful only inside a QR code or another open digital carrier (Article 12(9)).
• From 12 August 2028, or 24 months after the Commission's implementing acts if that is later, packaging carries a harmonised label on material composition to help consumers sort it (Article 12(1)). The acts were due on 12 August 2026 and have not been adopted, so the date may move.
• From 12 February 2029, or 30 months after the implementing act if that is later, reusable packaging carries a label, with further information through a QR code or similar carrier (Article 12(2)).
• From 1 January 2030, or later if the Commission's acts are late, plastic packaging must meet minimum recycled content, for example 30% for contact-sensitive PET packaging and 35% for most other plastic packaging (Article 7), and packaging must be designed for recycling and reach performance grade A, B or C, with some exemptions (Article 6).

Each step adds data to the same place. None of them needs a new code, as long as the first code points to a record that can grow.

What to settle before a second code goes to print

The expensive mistake is a second QR code: one for the product's passport, another for the packaging, run from a different system and printed side by side. PPWR Article 12(5) rules that out wherever its condition applies. Replacing a printed code across a product range means new artwork, new print runs and months with both versions on the market.

Some of the groundwork can be done now. List your packaging per product, with material, weight, supplier and the markets it is sold in. Establish who the PPWR manufacturer is for each pack, because that company draws up the declaration of conformity. Then choose a code that will not change, one that carries a permanent identifier such as a GS1 Digital Link address and resolves to a record you can extend as the 2028 and 2030 data arrive.

This is how we approach packaging with our clients. The packaging data goes into the product's passport as a separate, clearly labelled part, behind the same permanent QR code, so the harmonised label data can be added later without changing the code. Our page on DPP for packaging explains how we set it up with you, and our PPWR overview tracks the dates as the implementing acts arrive.

PPWR will not give your packaging a passport of its own. If your product gets one, the packaging belongs in it.