Digital Product Passport: a new feature in PPWR

A „digital packaging passport” is a practical term for a system in which information about the packaging is available digitally — most commonly via a QR code or another open data carrier affixed to the packaging. However, it is worth clarifying straight away that the PPWR does not introduce a single universal document called a ‘Digital Product Passport for every piece of packaging’ in the same sense as the ESPR Regulation. Instead, the PPWR introduces obligations regarding labelling, digital data carriers, QR codes, information on reuse, EPR, substances of concern and the traceability of packaging.

The Digital Product Passport, as a broader EU tool, stems primarily from the ESPR Regulation. The European Commission describes the DPP as a digital „identity card” for a product, designed to store data on sustainability, recyclability and environmental impact throughout the product’s life cycle. The DPP is to be made available electronically to consumers, businesses and public authorities. (single-market-economy.ec.europa.eu)

In the PPWR, a similar principle applies through the digital labelling of packaging. For businesses, this means one thing: simply printing a QR code is not enough. A database must be set up to provide the code with reliable, up-to-date and legally compliant information.

What is a digital packaging passport?

A digital packaging passport is a structured set of data about the packaging, accessible via a QR code, link, data carrier, NFC, GS1 Digital Link or another digital solution. Its purpose is to provide the relevant information to the relevant users: consumers, businesses, recyclers, reuse system operators, regulatory bodies, importers, distributors and B2B partners.

In practice, such a passport may contain details of:

– packaging material,
– the composition of the components,
– sorting instructions,
– recyclability,
– recycled content,
– substances of concern,
– the manufacturer or importer,
– batch number or type of packaging,
– a reuse system,
– collection points,
– the number of times the reusable packaging is reused,
– the obligations of the EPR,
– declarations of conformity,
– related technical documents.

A digital packaging passport is not a graphic element on the label. It is a data system that must be accurate, up to date and consistent with the company’s documentation.

PPWR versus the Digital Product Passport — what’s the difference?

The Digital Product Passport, or DPP, is a broader instrument of EU product policy. Its main provisions are set out in the ESPR, or the Ecodesign Regulation for Sustainable Products. The Commission states that the DPP is intended to store and make available data on a product’s sustainability, durability and other environmental aspects. (single-market-economy.ec.europa.eu)

The PPWR, on the other hand, applies to packaging and packaging waste. It introduces its own requirements regarding labels, pictograms, QR codes and digital data carriers. These terms should therefore not be used interchangeably without distinction.

The simplest comparison:

Area	ESPR / DPP	PPWR / digital packaging labelling
Main subject	product	packaging
Objective	information on the sustainability, durability, repair and recycling of the product	information on materials, sorting, reuse, EPR, substances, and packaging labelling
Media	data carrier, e.g. a QR code	A QR code or other standard, open digital data carrier
Recipients	consumers, businesses, authorities, service providers, recyclers	consumers, waste operators, authorities, EPR, B2B partners
Character	a comprehensive product passport for the specified product groups	digital layer of packaging information

Therefore, whilst the term „digital packaging passport” may be used in business communications, it is advisable to be precise when referring to it in compliance documents QR code, digital data carrier and the data required by the PPWR.

Will QR codes on packaging be compulsory?

The PPWR provides for situations in which a QR code or another standard, open digital data carrier will be required. Reusable packaging is particularly important. According to the guidance on Article 12 of the PPWR, packaging intended for reuse is to be labelled to indicate its reusability, and additional information on the reuse system and collection points is to be made available via a QR code or other open data carrier. Such a data carrier is also intended to facilitate the tracking of packaging and the calculation of its journey and turnover. (fieldfisher.com)

European Commission documents on packaging labels also indicate that, for reusable packaging, a QR code or other digital data carrier is intended to provide information on collection points, tracking and the calculation of turnover. The Commission also emphasises the need to distinguish between reusable and single-use packaging at the point of sale. (environment.ec.europa.eu)

At the same time, a QR code cannot replace all physical markings. Certain information and pictograms will still need to be displayed directly on the packaging in a visible and durable manner. Analyses of Article 12 of the PPWR indicate that a QR code may supplement the label, but should not be regarded as a complete substitute for mandatory printed or engraved markings. (compliancegate.com)

When should companies start preparing for digital labelling?

The PPWR came into force on 11 February 2025 and, in principle, will apply from 12 August 2026. The European Commission states that the new regulations cover all packaging and packaging waste, regardless of material or origin. (environment.ec.europa.eu)

For labelling and digital data carriers, the deadlines set out in the implementing acts will be important. Legal analyses indicate that from 12 August 2028 or 24 months after the adoption of the relevant implementing acts, whichever is later, packaging on the EU market is to bear harmonised labels regarding material composition and sorting. From 12 February 2029 or 30 months after the implementing acts, reusable packaging is to bear a harmonised ‘reuse’ label, and additional information is to be made available digitally. (fieldfisher.com)

In practice, companies should start earlier, as the implementation of digital labelling requires:

– organising data on packaging,
– updates to ERP, PIM, WMS or materials databases,
– selection of the QR standard / data carrier,
– the preparation of multilingual content,
– integration with suppliers’ documentation,
– procedures for updating data following a change in material,
– marketing and legal compliance checks.

What information can a digital packaging passport contain?

The scope of the data will depend on the type of packaging, its function and the obligations under the PPWR. Different data will be required for single-use packaging, for reusable packaging, for packaging containing problematic substances, and for packaging bearing a recycled content declaration.

Basic information

This group contains the following identifying information:

– name of the packaging,
– type of packaging,
– batch number, type, batch or serial number,
– packaging manufacturer,
– the importer, if applicable,
– contact details,
– sales market,
– the language of information.

The PPWR also sets out information obligations for manufacturers and importers, including identification and contact details, which in certain cases may be linked to a digital data carrier. (compliancegate.com)

Material data

This is the core of the digital packaging passport:

– the predominant material,
– composition of the components,
– the mass of the packaging unit,
– the mass of the component parts,
– type of plastic, paper, glass, metal or composite,
– the presence of coatings, laminates, adhesives, barriers and labels,
– information on multi-material packaging.

This data is required for sorting, recyclability, BDO, EPR and B2B client audits.

Data on sorting and recycling

A digital medium can provide detailed instructions that cannot be included on a label:

– which waste stream the packaging should be disposed of in,
– should the components be separated,
– is the packaging compostable,
– is it covered by the deposit scheme,
– how to handle multi-material packaging,
– Are there any local differences in the collection system?.

The PPWR requires harmonised labels regarding material and sorting, and the digital layer can supplement the data with additional instructions. (fieldfisher.com)

Data on reusable packaging

For reuse, a digital packaging passport makes the most operational sense. It may include:

– a statement that the packaging is reusable,
– a description of the reuse system,
– collection points,
– return instructions,
– the owner of the packaging,
– the number of rotations,
– repair and cleaning history,
– the status of the package in the pool,
– B2B settlement rules.

The Commission’s guidance on the PPWR explicitly states that a QR code or other data carrier for reusable packaging is intended to facilitate tracking and the calculation of turnover. (environment.ec.europa.eu)

Data on substances of concern

If packaging contains problematic substances or substances of concern, digital labelling could become an important tool for providing information to authorities and recyclers. Studies relating to Article 12 of the PPWR indicate that packaging containing substances of concern is to be labelled using standard, open digital labelling technologies. (compliancegate.com)

This is particularly important in industries that use specialised coatings, varnishes, barriers, processing additives, dyes or contact materials.

How will QR codes change packaging reporting?

A QR code is not just an extra for consumers. A well-implemented system can serve as a gateway to data that a company also uses for environmental reporting.

The biggest change is that packaging data must be organised and up to date. If a QR code links to information about the composition, recyclability or reuse scheme, the company must ensure that this data matches the actual packaging.

This involves linking several areas:

– ERP — product and material data,
– PIM — data published on product pages and product detail pages,
– WMS — information on warehouse and dispatch packaging,
– quality system — supplier declarations and material versions,
– BDO/EPR — volumes, materials and sales markets,
– labelling system — graphics, QR codes, pictograms, languages,
– the reuse system — rotations, returns, losses and repairs.

A digital packaging passport will ensure data consistency. If the packaging is described as PET in the ERP system, the supplier declares it to be a laminate, the label says „paper”, and the QR code links to different sorting instructions, the company faces a compliance issue.

Traceability of packaging waste — what will change?

The traceability of packaging waste refers to the ability to link packaging to its material, manufacturer, market, management method and potential recycling stream. Until now, many companies have treated packaging as a purchase cost and a logistical consideration. PPWR redefines packaging as a data object.

For recyclers and waste management operators, digital data can help with:

– identification of the material,
– identifying problematic substances,
– determining the correct stream,
– assessing the quality of secondary raw materials,
– the analysis of multi-material packaging,
– separating the packaging components,
– documenting the circulation of reusable packaging.

For companies launching products onto the market, digital data can help them to:

– packaging audit,
– BDO and EPR reporting,
– meeting the requirements of B2B customers,
– handling international sales,
– verifying environmental declarations,
– managing changes to suppliers.

A QR code on the packaging — what does a company need to consider?

Implementing a QR code on packaging seems straightforward: generate the code, add it to the label, publish the webpage. In reality, it involves technical, legal and operational considerations.

The company should answer the following questions:

– Will there be a single QR code for the entire type of packaging, or will each batch have its own unique code?
– Is the code intended to link to a public website, a database, DPP, GS1 Digital Link or an internal system?
– Who updates the details after a change of supplier?
– How long must the data remain available after the product has been sold?
– Will the information be available in the languages of the countries where the product is sold?
– Does the code conflict with any other codes required by product regulations?
– Will the link remain valid for the entire life cycle of the packaging?
– Who is responsible for cybersecurity and data integrity?
– Do the data for consumers differ from those for public authorities or B2B clients?
– Will the QR code remain legible after transport, cold storage, exposure to moisture or abrasion?

Studies on PPWR indicate that labels and QR codes should be visible, durable and difficult to remove, and that the information should also be available for online purchases. (compliancegate.com)

One code or several codes?

This poses a practical problem for companies that sell products subject to several sets of regulations. A product may require a QR code for instructions, for marketing, for a loyalty scheme, for traceability, for a product passport and for the packaging.

Too many codes on a label is a problem. Consumers do not know which code to scan. The waste management operator may be unable to find the correct information. The marketing department may change the link without consulting the compliance team.

Best practice is usually to have a single, well-organised entry point that categorises information according to the user’s role:

– consumer: sorting, returns, instructions, safety,
– recycler: material, components, substances, stream,
– authority: documentation, declarations, manufacturer, importer,
– B2B customer: certificates, EPR, material data, recycled material,
– reuse operator: rotations, status, waypoints, cleaning.

This requires a data architecture, not just a QR code generator.

Digital packaging passports and multi-material packaging

Multi-material packaging will be one of the biggest beneficiaries of the digital data layer. It is difficult to explain on a small label how to handle packaging consisting of paper, plastic, aluminium, adhesive, a barrier layer and a label. A QR code can provide more detailed instructions.

Examples of data useful for multi-material packaging:

– the predominant material,
– list of layers,
– instructions for separating the components,
– information about the barrier,
– the correct waste stream,
– restrictions on recycling,
– information for recyclers,
– the supplier’s documentation.

This does not exempt the company from the need for physical labelling, but it does help to reduce information overload. In the case of such packaging, it is worth combining the implementation of QR codes with analysis multi-material packaging and PPWR audit.

The digital packaging passport and e-commerce

E-commerce will be particularly affected by the digitisation of packaging information. An online shop uses product packaging, shipping boxes, void-fill material, tape, courier labels and, sometimes, return packaging. Each of these items may have different material specifications and different regulatory requirements.

Digital signage can help shops to:

– instructions on how to sort parcels,
– instructions on what to do with the cardboard box, plastic wrap, packing material and label,
– reducing errors in environmental declarations,
– handling returns,
– according to BDO data,
– exports,
– EPR reporting,
– inspection of empty space and packaging materials.

An online shop should combine digital signage with e-commerce audit and analysis Packaging in e-commerce: BDO and LUCID.

Digital labelling and reuse systems

The greatest value of the digital packaging passport lies in reusable packaging. In this case, the QR code is not merely for information purposes; it can support the operational system for reuse.

Using a QR code or another data carrier, a company can:

– identify the packaging,
– count rotations,
– check the location,
– record cleaning,
– supervise repairs,
– detect losses,
– settle deposits,
– plan the packaging allocation,
– to document the level of reuse.

The European Commission states that a QR code or other data carrier on reusable packaging is intended to facilitate tracking and the calculation of turnover. (environment.ec.europa.eu)

In B2B logistics, this could be a game-changer. A pallet, crate, container or canister becomes an asset with a digital history, rather than an anonymous piece of packaging.

How can you prepare your IT system for PPWR?

Companies should start by organising their packaging data. The QR code is merely an interface. What matters most is what lies behind it.

1. Create a database of packaging

Each package should include a data sheet: material, weight, supplier, components, sales market, recyclability, recycled content, labelling, documentation.

2. Identify the source of truth

The company must decide where the packaging master data is stored. This could be in an ERP, PIM or PLM system, a dedicated compliance database or an environmental management system. Without a single source of truth, the data will quickly become fragmented.

3. Link the packaging to the product and the market

The same packaging may have different language versions, different EPR requirements and different labelling depending on the country. The system should know where the product is going.

4. Make sure you keep your software up to date

Any change to the supplier, film, label, adhesive or recycled content should automatically trigger a review of the QR data.

5. Set access levels

Not all data needs to be made public. A consumer may need sorting instructions, a regulatory body may need documentation, and a B2B client may need material data and certificates.

6. Archive versions

If the packaging changes over time, the company needs to know which version of the QR code and which version of the data applied to a specific batch of the product.

7. Test the code for readability and robustness

The QR code must work in the real world: after transport, in cold storage, and despite moisture, dirt, abrasion or the label being creased.

Checklist for the implementation of the digital packaging passport

1. Does the company have a complete list of packaging types?
2. Is the material composition of every package known?
3. Is the weight information up to date?
4. Do suppliers provide specifications and declarations?
5. Is it clear which packaging is single-use and which is reusable?
6. Do reusable packaging systems have a return and rotation tracking system?
7. Is the packaging data consistent with the BDO and EPR?
8. Does the company know what information must appear on the physical label?
9. Is it clear which information can be made available digitally?
10. Will the QR code work in all sales channels?
11. Is the content available in the languages of the relevant EU countries?
12. Does the system keep a record of changes to the data?
13. Can’t the marketing department change the QR code content on its own without compliance approval?
14. Is there a procedure for updating your details after changing your provider?
15. Is the system ready for future PPWR implementing acts?

If many of the answers are „no”, the company should start by conducting an audit of its packaging data, rather than by designing a QR code.

The most common mistakes when implementing QR codes on packaging

The first mistake is to treat a QR code as a marketing sticker. In PPWR, the code can carry compliance information, so it must be managed as regulatory data.

The second mistake is the lack of a data owner. If the marketing, IT, compliance and quality teams edit the information independently, the risk of inconsistencies increases.

The third mistake is linking to a standard product page. A product page does not always contain information on materials, sorting, reuse, EPR and documentation.

The fourth mistake is a lack of versioning. Once the packaging has changed, the old QR code may lead to out-of-date information.

The fifth mistake is publishing information in only one language. The information should be understandable in the market where the packaging is made available.

The sixth mistake is replacing a physical label with a QR code. Some of the labelling must remain visible without the need to scan it. (compliancegate.com)

The digital packaging passport and BDO, EPR and LUCID

The digital data on the packaging should be consistent with the data reported in environmental systems. If a company declares in QR that the packaging is made of PET, but reports a different material category in BDO or EPR, this creates a risk.

In practice, the digital passport database should be linked to:

– BDO in Poland,
– EPR in EU countries,
– LUCID in Germany,
– suppliers’ declarations,
– the weight of the packaging,
– SKU numbers,
– sales markets,
– audit documentation.

Companies selling outside Poland should combine digital labelling with compliance with packaging obligations in EU markets and, for sales to Germany, with LUCID audit.

How do you get started with the implementation?

The best sequence of steps is as follows:

1. Packaging audit

First, you need to know what type of packaging the company uses, what it is made of and what information it contains. It will be helpful to PPWR audit.

2. Data audit

Next, you need to check where the data is stored: ERP, Excel, PIM, the warehouse, supplier files, the quality department, BDO, EPR.

3. Information architecture design

The company should determine which data is public, which is for B2B customers, which is for regulatory bodies, and which is for internal use.

4. Choice of technology

Possible solutions include QR codes, GS1 Digital Link, NFC, serialisation, the DPP system, a compliance platform or integration with an existing PIM/ERP system.

5. Pilot scheme

It’s best to start with one category of packaging: reusable, export, e-commerce or high-volume.

6. Update procedure

Any change to the packaging should automatically update the digital data, the label, the BDO/EPR and the documentation.

7. Team training

Marketing, quality, procurement, production, IT, logistics and compliance must know who is responsible for the data in the QR code.

If a company does not have the resources to integrate PPWR, data and labelling in-house, it is worth using comprehensive environmental advice i ongoing environmental management.

FAQ - Frequently asked questions

Is PPWR introducing a digital packaging passport?

The PPWR does not introduce a single document called a „digital packaging passport” for each item of packaging, but instead introduces QR codes and standard, open digital data carriers for selected information, particularly in the areas of reuse, EPR, labelling and substances of concern. (fieldfisher.com)

How does the Digital Product Passport differ from PPWR digital labelling?

The Digital Product Passport stems primarily from the ESPR and applies to products in the broadest sense. The PPWR applies to packaging and requires specific information about packaging to be provided digitally, for example via a QR code or another data carrier. (single-market-economy.ec.europa.eu)

Can a QR code replace the label on the packaging?

Not entirely. A QR code may provide additional information, but some of the pictograms and markings must be physically displayed on the packaging in a visible and permanent manner. (compliancegate.com)

What information should a digital packaging passport contain?

It may include information on materials, the composition of components, sorting instructions, recyclability, recycled content, manufacturer or importer details, information on EPR, reuse, collection points, product life cycles and substances of concern. The scope depends on the type of packaging and the obligations under the Packaging and Waste Management Act.

Will reusable packaging require a QR code?

Yes, reusable packaging is one of the most important areas of digital labelling. A QR code or other data carrier is intended to provide information about the reuse system and collection points, and to facilitate tracking and the counting of cycles. (environment.ec.europa.eu)

How can you prepare your business for QR codes on packaging?

First, you need to organise the data on packaging: materials, weights, components, suppliers, sales markets, BDO, EPR and documentation. Only then should you consider choosing between QR, GS1 Digital Link, NFC or the DPP platform.

Implement modern labelling systems with Eko-Pro

The digital packaging passport will be more than just a QR code on a label. It is a data system that must integrate material, recyclability, labelling, BDO, EPR, reuse, documentation and B2B customer requirements. Companies that set up a database in advance will find it easier to implement future PPWR implementing acts and avoid chaos when updating labels.

Implement modern labelling systems with Eko-Pro. Find out more PPWR audit, e-commerce audit, compliance with packaging obligations in EU markets and comprehensive environmental consultancy. You can also go directly to the tab Contact Eko-Pro and describe what packaging, QR codes and data systems you wish to implement.