regulation
Wait — Does Our Packaging Need Its Own QR Code Too? PPWR vs. the Battery Passport
The Packaging and Packaging Waste Regulation (EU) 2025/40 adds packaging-level QR obligations on its own timeline. Here's how they relate to the battery passport carrier, and the one-code principle.
The short answer
Probably not two codes — but the honest answer is that the technical recipe isn't published yet. The Packaging and Packaging Waste Regulation (EU) 2025/40, in force since 11 February 2025 and applying generally from 12 August 2026, creates packaging-level digital marking obligations that are separate from the battery passport. The regulation itself states the unifying principle: where information for both the packaged product and the packaging is legally required via a data carrier, a single data carrier shall be used, with the two information sets easily distinguishable. So a PPWR layer can share the battery passport's QR code. What's missing is the how — implementing acts due by 12 August 2026 define the actual format, and until they land, "use one QR code" is a principle without a recipe.
What PPWR actually requires, and when
| Obligation | Status | Date |
|---|---|---|
| Reusability label + QR on reusable packaging | Mandatory | 12 Feb 2029 |
| Digital marking for substances of concern above thresholds | Mandatory | By 1 Jan 2030 at the latest |
| Digital EPR identification | Member-state opt-in | From 12 Feb 2027 |
| Harmonized material-composition pictogram | Mandatory (QR supplement optional) | 12 Aug 2028 |
| Implementing acts defining formats | Awaited | Due 12 Aug 2026 |
Two details worth knowing: opt-in EPR marking, where a member state activates it, must be a QR code or comparable open, standardized technology — proprietary national logos no longer qualify. And for reusable packaging, the Commission's FAQ confirms one shared code per packaging type (with average rotation data) is acceptable — no per-unit serialization of crates and boxes.
What a battery manufacturer should actually do
- Classify your packaging — reusable transport packaging (returnable crates, battery transport containers) triggers the 2029 reusability obligations; single-use shipping boxes mostly trigger the 2028 pictogram.
- Check for substances of concern above thresholds in packaging materials — that's the other mandatory digital-marking path.
- Don't print packaging QR codes yet. With format specs due from the 12 August 2026 implementing acts, anything printed to a guessed spec risks a re-run.
- Design your battery passport carrier assuming a future co-tenant. The passport QR you deploy for February 2027 may later need to serve PPWR information through the same carrier. Resolver-based architectures (identifier resolves to a page you control) absorb this cheaply; hardcoded single-purpose links don't.
What this means for your team
PPWR is a watch-and-prepare item, not a panic item — its battery-relevant deadlines trail the passport's by two years or more. The one decision worth making now is architectural: one resolvable identifier per product, able to serve multiple regulatory layers, so packaging rules become a routing question later instead of a relabeling project.