Labelling is the first thing the consumer sees, and it is often the last thing to change in a packaging project. The PPWR makes this display a compliance matter in its own right. The regulation introduces Union-wide harmonised labelling, designed so that the sorting action is the same from one country to the next. For French companies, already accustomed to the national marking, this opens a transition period to be managed with care. The PPWR’s harmonised labelling becomes mandatory from 12 August 2028, which makes it a near-term deadline when measured against artwork cycles.
PPWR harmonised labelling: what becomes mandatory
The regulation’s principle is to replace the diversity of national markings with a common visual language. Packaging will have to carry harmonised labelling indicating its material composition, in order to guide consumer sorting correctly. This marking relies on common pictograms, the precise format of which is defined at European level to ensure legibility and uniformity.
The aim is clear: that a bottle, a film or a tray be sorted in the same way everywhere in the Union, without the consumer having to relearn the codes in each country. For brands present across several markets, this is ultimately a simplification, following a phase of adaptation.
What stays optional: the QR code
A common confusion deserves to be cleared up. The regulation provides for the possibility of adding a digital carrier, such as a QR code, to give more detailed information about the packaging and its sorting. But this digital marking is optional, complementing the pictograms. It does not replace the mandatory harmonised labelling and is not required in itself. Presenting the QR code as an obligation is a common mistake: it is an option, useful for enriching the information, not a regulatory requirement.
Coexistence with the French marking
This is the sensitive point for French companies. The national marking, rolled out under the AGEC law, represents years of investment in artwork and in consumer education. The arrival of the PPWR’s harmonised system will gradually replace it on the topics it covers, creating a period in which the two logics overlap. Part of the existing investment will be written down, with no automatic compensation. We have set out this tension in our article on the divergences between AGEC and PPWR.
Why anticipate now
Packaging artwork has a long life cycle, often more than three years. Designing a redesign today based solely on the current marking, without reserving space for the harmonised labelling, amounts to scheduling a second costly redesign before 2028. Conversely, any packaging project carried out now stands to gain from allowing for the space and compatibility with the future system. This simple habit avoids printing twice and smooths the investment.
Where to start
Three actions make it possible to get ahead without waiting for the last technical detail. First, list the packaging whose artwork will be reworked before 2028; these are your priority projects. Next, build a zone reserved for harmonised labelling into every new design from today, so you do not have to come back to it. Finally, follow the publication of the detailed pictogram specifications, which set out the exact formats and arrangements.
To place this deadline among the others, the regulatory roadmap sets it within the overall timeline, and the complete PPWR guide details each requirement. To clarify your obligations according to your role, the EPR Responsibilities tool guides you in a few questions.
A question about your specific labelling? Write to us at contact@packaginghub.fr.