Consultation on new labelling requirements for packaging under Article 12 PPWR (Food & Drink Manufacturers)

September 23, 2025

The European Commission launched a consultancy to work on the development of implementing acts following Article 12 of the Packaging and Packaging Waste Regulation. Specifically, Article 12 of the PPWR requires the development of four physical labels and their specifications, namely:

  1. For reusable packaging (in closed loop systems)
  2. For packaging subject to DRS
  3. For recycled plastic content
  4. For bio-based plastic content

Additionally, four digital label specifications, providing further information via a digital data carrier, are being developed:

  1. Digital label for reusable packaging (in closed loop systems),
  2. Digital label to indicate the bio-based and recycled plastic content,
  3. Digital label informing consumers and recycling operators about substances of concern (SOC),
  4. Digital label informing consumers about waste sorting.

The consultancy is gathering some initial and general input regarding the development of those labels. Please find below the questions the consultants are asking. SFA members are asked to send their input to the questions below to jonathan.mcdade@sfa.ie by noon on Thursday 25th September.

Questions on the new labelling requirements under PPWR

  1. General considerations
  2. What design, size, aspect ratio, placement, and colour considerations you deem relevant (for physical labels),
  3. What existing labels with conflicting or similar messages you are aware of,
  4. What data carrier considerations you deem relevant (for digital labels),
  5. Any other input referring specifically to the harmonized digital and physical label specifications to be developed pursuant to Article 12.