Harmonisation of product labelling across the EU – an end to national disparities and new obligations for businesses

The new approach marks a shift away from regulatory fragmentation towards uniform rules that apply directly across the European Union.

Fragmented rules – a real barrier to the free movement of goods

The European Council explicitly identifies differences in product labelling and packaging requirements as a significant barrier to the free movement of goods.

Businesses operating in several Member States often have to adapt products to different local requirements, resulting in:

• the need to create multiple versions of packaging;
• higher production and logistics costs;
• the risk of regulatory non-compliance;
• limited ability to scale operations across the EU.

From the perspective of EU institutions, this situation undermines the foundations of the Single Market.

Harmonisation of requirements – what is the European Commission planning?

As part of the measures referred to in point 32 of the European Council conclusions, the European Commission is expected to present proposals aimed at reducing the fragmentation of rules on labelling and packaging.

The planned measures include:

• harmonising product labelling rules at EU level;
• limiting the ability of Member States to introduce additional national requirements;
• using digital solutions as an alternative to physical labelling;
• eliminating barriers arising from territorial delivery restrictions.

As a result, businesses will be able to place the same product on the market in multiple Member States without having to modify it.

Regulations instead of directives – direct obligations, without a transitional buffer

A fundamental element of this change is the clear preference for EU regulations over directives.

The new rules on packaging and labelling:

• will apply directly in all EU Member States;
• will not require transposition into national law;
• will limit the ability of Member States to apply additional requirements.

For businesses, this means more consistent rules, but also the absence of a “transitional buffer” associated with the implementation of directives. Compliance in this area must be managed centrally at the product-planning stage—not retrospectively.

The best example of this regulatory model is Regulation (EU) 2025/40 of the European Parliament and of the Council of 22 January 2025, commonly known as the PPWR (Packaging and Packaging Waste Regulation). It entered into force on 11 February 2025 and applies directly in all Member States. Its principal provisions will apply from 12 August 2026.

PPWR – a regulation already reshaping the packaging market

PPWR – packaging compliance. From 12 August 2026, all packaging placed on the EU market must meet uniform requirements concerning recyclability, material composition, the content of hazardous substances—including PFAS and heavy metals—and harmonised sorting labels.

• Incorrect classification of packaging means that documentation obligations may not be fulfilled and creates a genuine risk of penalties.

PPWR – manufacturer obligations. These are extensive. Under Article 15 of the Regulation, manufacturers must carry out a packaging conformity-assessment procedure, prepare technical documentation for each type of packaging and issue an EU declaration of conformity.

• From 12 August 2026, the burden of proof rests with the manufacturer: compliance must be demonstrated with robust evidence, including laboratory test results.

PPWR – importer obligations are becoming more specific. An entity importing products in packaging from third countries is responsible for PPWR packaging compliance, even where the packaging itself was designed and manufactured outside Europe.

Importer obligations include:

• verifying whether the manufacturer has carried out the conformity assessment;
• retaining the declaration of conformity and technical documentation;
• under Article 22 of the PPWR, identifying every entity that supplied the packaging or packaged product and making this information available to market-surveillance authorities upon request.

In practice, this requires a systematic approach to supply-chain monitoring.

Alongside the harmonisation of requirements, the European Council calls for stronger controls of products placed on the EU market, particularly those originating from third countries. This may be expected to result in:

• stricter documentation requirements;
• a greater role for market-surveillance authorities;
• greater responsibility for importers and distributors;
• wider use of digital tools to monitor compliance.

Harmonising the rules does not therefore mean that they will become simpler—it may lead to a genuine increase in regulatory standards.

Digitalisation of labelling – a new dimension of compliance

One of the most significant elements of the changes is the development of digital ways of providing product information.

Solutions that may in future partially replace traditional physical labelling include:

• digital labels;
• QR codes;
• digital product passports.

The PPWR already provides for the use of QR codes on reusable packaging (Article 12 of the PPWR) and for the introduction of digital product passports for selected categories, currently planned from 2030.

Businesses must prepare for the parallel operation of:

• physical labelling obligations;
• digital product-information systems.

Managing compliance in this area requires product-data systems to be integrated with packaging-design processes. This is not a task for the legal department alone.

What this means for businesses – implications for companies

Changes relating to labelling and packaging will have a direct impact on businesses operating in the EU market.

1. The costs of adapting products to different national markets may be reduced.
2. Centralised EU-level compliance management will become more important.
3. The time available to adapt to new rules will be shorter because regulations apply directly.
4. Importers and distributors will bear greater responsibility for product compliance.
5. Digital solutions for product labelling and documentation will need to be integrated.

It should be stressed that PPWR manufacturer obligations and importer obligations are not rules designed for a distant future. The specific date after which a lack of preparation becomes both a regulatory and business risk is 12 August 2026.

Trading partners may start requiring packaging certification compliant with the PPWR before market-surveillance authorities do so.

Summary

The European Council conclusions make it clear that labelling and packaging will become central elements of the Single Market reform. The shift to regulations and the harmonisation of requirements mark the end of a model based on national disparities and the beginning of genuinely uniform operating rules across the EU. For businesses, this means both operational simplification and a need to adapt quickly to new EU regulations that apply directly.