PPWR labelling requirements arrive in stages. Misleading marks have been banned since August 2026, EPR marks move into QR codes from February 2027, sorting labels start no earlier than August 2028, and reusable packaging labels follow in 2029.
We make rigid gift boxes at Topvisio Packaging in Dongguan, Guangdong, China. Our 14+ automated lines produce 800,000 drawer and book-style boxes and 1,500,000 two-piece lid and base boxes a month. We offer FSC on request, with production at ISO 9001 / ISO 14001 / SEDEX audited facilities, and our packaging is PPWR compliant.
Where PPWR Labelling Requirements Come From
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026. Almost all the labelling rules sit in one place: Article 12. You can read it in full on EUR-Lex.
Article 12 doesn’t switch on all at once. Each paragraph has its own start date. Some depend on detailed rules the European Commission still has to adopt.
That second point matters more than people think. The Commission was meant to adopt the label design rules by 12 August 2026. It missed that date. In late October 2026 it moved adoption to the second quarter of 2027. The Commission’s own packaging waste page tracks progress on these acts.
So when you see a date in this article, read it as the earliest possible date. Some of them will move.
Since 12 August 2026: No Misleading Marks
This is the only labelling rule already in force without waiting for anything else. Under Article 12(8), packaging must not carry labels, marks or symbols likely to mislead or confuse people about the packaging or how to dispose of it.
For gift boxes, look hard at old artwork. Recycling arrows from a past supplier, vague “eco” icons, or a recycling claim that doesn’t match the actual build are all worth questioning.
A common one we see: a box wrapped in film-laminated paper with a big “100% recyclable” icon. Whether that claim holds depends on the material and where the box ends up. If you can’t back it up, take it off.
Certification marks are a separate topic, with their own rules. Our guide to FSC label requirements covers when you can and can’t print the FSC logo.
From 12 February 2027: EPR Marks Move into a QR Code
Article 12(9) deals with marks that show a producer has met its extended producer responsibility duties. The green dot is the best-known example.
From 12 February 2027, if you identify packaging as covered by an EPR scheme, you can only do it through a QR code or another standardised, open digital marking. The symbol can no longer sit on the box as a printed logo on its own.
Using the mark is optional. Printing it the old way after that date is not. Producer responsibility organisations read the rule as covering packaging placed on the market after 12 February 2027.
Germany built this into its national rules too. If you sell there, our article on VerpackDG explains what else changed in August 2026.
From 12 August 2028 at the Earliest: The Harmonised Sorting Label
Article 12(1) brings in the label most people picture when they hear “PPWR labelling requirements”. It is a pictogram showing what the packaging is made of, so consumers know which bin to use. It has to be readable by people with disabilities.
The date is 12 August 2028, or 24 months after the Commission’s implementing act enters into force, whichever is later. With adoption now pushed to Q2 2027, the real date is likely to fall after August 2028.
Transport packaging and packaging in a deposit return system are excluded. E-commerce packaging is not excluded, so a shipper box sent straight to a customer is in scope.
Two related rules run on the same clock. Compostable packaging will need a label saying so, and packaging containing substances of concern will need digital marking. Neither applies to a standard paper gift box, but check if you use specialty coatings.
From 12 February 2029 at the Earliest: Reusable Packaging
Articles 12(2) and 12(3) cover packaging that is part of a re-use system. It must carry a label saying it is reusable, plus a mandatory QR code with information on the re-use system, collection points and tracking.
The date is 12 February 2029, or 30 months after the relevant implementing act, whichever is later.
Be careful with the word “reusable”. A rigid box that customers keep for storage is not automatically reusable packaging under the PPWR, which is about organised re-use systems. Calling a keepsake box “reusable packaging” on the box could cross into the misleading-marks rule. Say “keep it” or “store your jewellery in it” instead.
PPWR Labelling Requirements at a Glance
| Requirement | Article | Applies From | Relevant to Rigid Gift Boxes? |
|---|---|---|---|
| No misleading marks or symbols | 12(8) | 12 August 2026 | Yes, check all existing artwork |
| EPR marks only via QR code or digital marking | 12(9) | 12 February 2027 | Yes, if you use a mark like the green dot |
| Harmonised material sorting label | 12(1) | 12 August 2028 or 24 months after the implementing act | Yes, including e-commerce shipper boxes |
| Compostable and substances of concern labels | 12(1), 12(7) | Same as the sorting label | Only for special materials or coatings |
| Reusable packaging label and QR code | 12(2), 12(3) | 12 February 2029 or 30 months after the implementing act | Only if the box is part of a re-use system |
How to Design a Gift Box Now So It Still Works in 2028
Nobody has seen the final sorting pictogram yet. That’s the awkward part. You can’t print it, but you can plan for it.
Reserve a QR code area on the base or an inner flap. From 2027 the code can carry your EPR mark. Later, it can link to recycling details and the sorting label data. When the rules change, you update what the code points to, not the printing plates.
Leave a clear panel near the QR code, roughly the size of a small pictogram row. Then the sorting label can go in without redesigning the whole box.
One quick test before you approve any proof. List every mark on the box and ask what each one claims. If a mark has no clear basis, or will clash with PPWR labelling requirements by 2027, take it off now rather than at the next reprint.
We can print one fixed QR code per design, or inkjet variable codes and serial numbers so each box has its own. Before sampling, our team checks your artwork and flags printed EPR marks, missing QR space, or recycling claims that don’t match the build. That check is a production step. It isn’t legal advice.
The build matters as much as the print. A label only tells the truth if the box behind it is simple to sort. On many structures we can replace BOPP film lamination with water-based varnish, keeping the box closer to all-paper. Some structures still need film, and we’ll say which.
Paper card inserts can replace EVA foam in a lot of designs. Our glue is water-based as standard. If you want magnet-free, a ribbon tie, a tuck flap or a drawer box works. Our magnets are not designed to be removed.
With each order we can also send a breakdown of every component by material and weight. You’ll need that data for EPR reporting anyway, and it makes a future sorting label easier to get right.
What Your Packaging Supplier Should Be Doing
Labelling is the brand’s legal responsibility, not the factory’s. Your supplier still has a part to play.
A good one will tell you when your artwork carries a mark that may no longer be allowed, give you honest material data, and suggest builds that make a recycling claim true rather than hopeful. If yours can’t do that, ask why.
For a wider list of things to check, our PPWR packaging guide sets out four questions to put to any supplier. For how EPR and the PPWR fit together, see EPR vs PPWR.
This article is a planning summary, not legal advice. Check your own position with your compliance adviser or authorised representative.
FAQ on PPWR Labelling Requirements
What are the PPWR labelling requirements?
They are the packaging label rules in Article 12 of Regulation (EU) 2025/40. They ban misleading marks from August 2026, limit EPR marks to QR codes from February 2027, and add a harmonised sorting label from August 2028 at the earliest.
Do I need to print the new sorting label on my boxes now?
No. The final design isn’t adopted yet, and the rule applies from 12 August 2028 at the earliest. Reserve space for it and a QR code instead.
Can I still print the green dot on my gift boxes?
Not as a standalone printed logo on packaging placed on the market from 12 February 2027. After that date, an EPR mark can only appear through a QR code or another standard digital marking.
Can your factory check my artwork for PPWR labelling issues?
Yes. Before sampling, Topvisio Packaging checks artwork for printed EPR marks, missing QR space and claims that don’t match the box build. It’s a production check, not legal advice. Samples take 7 working days.
What can you produce, and with which certifications?
Our production base in Dongguan, Guangdong, China runs 14+ automated lines making 800,000 drawer and book-style boxes and 1,500,000 two-piece lid and base boxes a month. MOQ is 1,000 units per design.
We offer FSC on request, with the certificate number provided with your order, production at ISO 9001 / ISO 14001 / SEDEX audited facilities, and PPWR compliant packaging. See our factory, our rigid boxes, or FSC certified packaging.
