§14 Labelling of existing reusable transport packaging

Legal provisions: According to Article 12(2) ‘(…) reusable packaging placed on the market from 12 February 2029 or 30 months from the date of entry into force of the implementing act adopted pursuant to paragraph 6, whichever is the latest, shall bear a label informing users that the packaging is reusable. Further information on reusability, including the availability of a local, national or Union-wide re-use system and information on collection points, shall be made available through a QR code or other type of standardised, open, digital data carrier that facilitates the tracking of the packaging and the calculation of trips and rotations, or, if that calculation is not feasible, an average estimation. (…)’ According to Article 12(3) these requirements do not apply to ‘open loop systems which do not have a system operator in accordance with Annex VI.’ Article 12(6) gives a mandate to the Commission to define the packaging labels: ‘By 12 August 2026, the Commission shall adopt implementing acts to establish a harmonised label and specifications for the labelling requirements and formats, including where provided through digital means, for the labelling of packaging referred to in paragraphs 1, 2 and 4 of this Article. (…)’ Article 12(12) provides: ‘Packaging as referred to in paragraphs 1, 2 and 4 that is manufactured in the Union or imported before the deadlines referred in those paragraphs and that does not comply with the criteria laid down in those paragraphs may be made available on the market until 3 years from the date of entry into force of the labelling requirements laid down in those paragraphs.’ Article 15(9) provides: ‘By way of derogation from paragraph 8 of this Article, the obligation to bring into conformity, withdraw or recall packaging which is believed not to be in conformity with the requirements laid down in or pursuant to Articles 5 to 12 shall not apply to reusable packaging placed on the market before 11 February 2025.’ Commission’s interpretation: It is necessary to distinguish between: (a) reusable transport packaging placed on the market before the entry into force of the PPWR, i.e. before 11 February 2025 and (b) reusable transport packaging placed on the market after 11 February 2025 (i.e., after the entry into force of the PPWR) but before the date of application of the implementing act on labelling for reusable packaging, which should be adopted by 12 August 2026 and apply from 12 February 2029 or 30 months from the date of entry into force of the implementing act, i.e., reusable transport packaging placed on the market between 11 February 2025 and 12 February 2029. Reusable packaging under (a) may remain in circulation until it is removed from the re-use systems due to functional obsolescence or operational limitations. Reusable packaging under (b) should comply with the labelling requirements at the latest by February 2032. Considering that the new labelling rules will be known by the industry already at the time of the adoption of the implementing act, i.e. in August 2026, a limited amount of reusable transport packaging will need to be brought into compliance. In practice, packaging that will be placed on the market during the period between February 2025 and August 2026 will have to be refurbished with labels according to the new rules by February 2032. It should be recalled that after the entry into force of the PPWR, operators no longer have legitimate expectations to not being subject to the new labelling rules. The conditions of Article 12(5) warranting the provision of information via websites or accompanying documentation are met in the case of reusable transport packaging in a business-to-business situations (i.e. consumer not being the end user of the transport packaging), managed by a system operator in a closed-loop system.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07