PPWR Readiness: Plan now 2027-2028

Phase 2 of PPWR runs from 2027 to 2028 and shifts the focus from foundational data to how packaging communicates to consumers and recyclers: labelling, QR codes, and the first signals of the Design for Recycling (DfR) grading system that will determine market access from 2030 onward. Unlike Phase 1, most of these requirements aren't fully defined yet, the methodology for DfR grades and harmonised labelling is still being published. But the companies that start collecting the underlying data now, before the rules land, will be ready to act the moment they do.

2.1 Current labelling evidence

PPWR prohibits misleading claims on packaging about specific sustainability characteristics, recyclability, recycled content, reusability, compostability, bio-based content, and hazardous substances. Harmonised labelling requirements covering pictograms and sorting guidance come into force in 2028, but the restriction on misleading claims applies from August 2026.

Ask yourself:

• Have you reviewed your current packaging labels for claims about recyclability, recycled content, reusability, or compostability that are not backed by verified evidence? Yes / No / Partially

• If you use compostable packaging, is it clearly labelled as industrially compostable only? Yes / No / Not applicable

2.2 QR code & labelling readiness

Two distinct labelling changes are coming. First, by February 2027 the Green Dot symbol will no longer be valid as a standalone EPR mark, it transitions into a harmonised QR code system. Second, broader harmonised labelling requirements covering material composition pictograms and sorting guidance are subject to implementing acts expected in 2028.

Ask yourself:

• If you currently use the Green Dot symbol on any of your packaging, have you identified which packaging will need to be updated by February 2027? Yes / No / Partially

• Are you monitoring the development of the 2028 harmonised labelling implementing acts so you can plan label updates in time? Yes / No

2.3 Design for Recycling (DfR) grade awareness

The EU will publish the methodology for calculating DfR grades A through E in January 2028. Grades will be based on recyclability performance by weight. From 2030, all packaging must achieve a minimum Grade C. From 2038, only Grades A and B will be permitted on the market. The methodology isn't finalised yet, but companies can already identify which packaging formats are likely to be at risk based on material type, multi-material construction, and known recycling infrastructure gaps.

Ask yourself:

• Have you identified which of your packaging formats are likely to be at risk of a low DfR grade, for example multi-layer plastics, mixed material units or formats not currently collected at scale? Yes / No / Partially

• Are you collecting the underlying material and component data now that will be needed once the grading methodology is published? Yes / No / Partially

2.4 Supplier declarations for recyclability

Once DfR grades are introduced, companies will need verified evidence from suppliers to substantiate recyclability claims in their technical documentation. This means material composition declarations, layer-level data for composite components, and evidence of compatibility with existing recycling infrastructure. Starting to collect this now, before the methodology is published, puts companies significantly ahead.

Ask yourself:

• Do you collect material composition information from your packaging suppliers? Yes / No / Partially

• For composite or multi-layer components, do suppliers provide data on each individual layer? Yes / No

• Is this documentation stored and linked to the specific packaging units it relates to, rather than held generically? Yes / No

2.5 Reporting

If you already report packaging volumes annually under existing national EPR schemes, you have the foundation in place. However, PPWR raises the bar, reporting will need to be at material type level per packaging component, not just total weight by broad category. The first mandatory report under the new harmonised rules is due June 2029, covering the 2028 calendar year.

Ask yourself:

• Do you currently report packaging volumes and material types annually to your registered PRO(s)? Yes / No

• Is your packaging data structured at a level of detail that will support the more granular PPWR reporting requirements, material type per component, across all packaging units? Yes / No / Partially

Phase 2 is largely about positioning, not just compliance. The Green Dot symbol's shift to a QR code system (February 2027) is a concrete, near-term deadline, while DfR grading and harmonised labelling are still being finalised for 2028. The common thread across all five sections is supplier data: material composition, layer-level breakdowns, and recyclability evidence collected and linked at packaging-unit level now will directly determine how easily a business clears Phase 2 once the methodologies are published.

Getting ahead of Phase 2 means building on the same data foundation Phase 1 asks for, structured, supplier-verified, and linked to individual packaging units. Download the full PDF checklist to work through Phases 1, 3, 4 and 5, and calculate your overall PPWR readiness score. Or book a 15 minute PPWR consult to go through your specific use case.