PPWR vs ESPR vs Digital Product Passport: Which Regulation Applies to Your Packaging

Three regimes get conflated, and the packaging one is the narrowest of the three on digital marking. This page draws the boundary.

The short version

What PPWR actually says about digital marking

The phrase "digital product passport" appears twice in the Official Journal text of Regulation (EU) 2025/40, both inside recital 70, and zero times in the enacting terms or the annexes. Recital 70 says only that where a packaged product is already covered by a digital product passport under other Union law, that passport should also carry the PPWR information. It creates no packaging passport and no packaging passport deadline.

The provision that does concern digital marking is Article 12(9), which is permissive rather than mandatory and concerns carrying an EPR symbol inside a QR code or other digital data carrier. It is not a passport requirement, and reading it as one is the most common error in circulation.

What this means in practice

• If you sell packaged goods in the EU, PPWR applies to the packaging from 12 August 2026 regardless of ESPR.
• Whether a Digital Product Passport applies to you depends on whether an ESPR delegated act covers your product group, not on PPWR.
• If a DPP does apply to your product, recital 70 points toward carrying the PPWR packaging information in it rather than building a second system.
• The PPWR harmonized sorting label under Article 12 is a separate obligation from either, applying from 12 August 2028 or 24 months after the Article 12(6) or 12(7) acts, whichever is the latest.

Read Article 12 in detail  |  ESPR Atlas, the ESPR and DPP side