The PPWR requires packaging to carry a digital product passport (DPP) from 2028, providing consumers and waste management operators with information about the packaging's material composition, recycled content, recyclability, and disposal instructions. The DPP is accessed via a QR code or other data carrier on the packaging.
DPP Data Requirements
The packaging DPP must contain: material composition (percentage by weight of each material); recycled content (percentage of recycled material by weight); recyclability information (whether the packaging is recyclable and in which recycling stream); disposal instructions for consumers; and information about the producer's EPR registration.
Data Carrier Requirements
The DPP must be accessible via a data carrier that is: readable by consumers using a standard smartphone; durable and legible throughout the packaging lifecycle; and compliant with the EU's Digital Product Passport technical specifications (to be established by the Commission through delegated acts). QR codes are the most likely data carrier for most packaging formats.
Platform Options
Several platform options are emerging for packaging DPP implementation: the EU's planned Digital Product Passport infrastructure (under development by the Commission); industry-developed platforms such as GS1's Digital Link standard; and proprietary brand platforms. Companies should monitor Commission delegated acts for technical specifications before committing to a specific platform.
Implementation Timeline
The DPP requirement applies from 2028. Companies should begin preparing in 2025–2026 by: inventorying packaging material composition data; establishing data collection processes from packaging suppliers; evaluating DPP platform options; and piloting DPP implementation on selected packaging formats.