PPWR Copilot

Packaging Compliance Guide

France, Italy & Spain Packaging Labelling in 2025

What exporters must do now — and what PPWR changes next

Last reviewed: 13 December 2025

If you ship products into the EU, three markets consistently cause the most last-minute artwork changes:

  • France – Triman + Info-Tri (Sorting Info) for household packaging
  • Italy – mandatory environmental labelling (material ID + disposal instructions)
  • Spain – from 1 January 2025, household packaging must indicate the correct waste fraction/container

At the same time, the new EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) applies from 12 August 2026, with EU-harmonised packaging labels coming later (details below). That means most brands must manage today's national labels while preparing for tomorrow's EU label.

PPWR Copilot is built for that "in-between" reality: create country-ready documentation for current rules (e.g., FR/IT/ES) and keep an upgrade path for the PPWR harmonised label as soon as the EU implementing acts are in force.

1) PPWR timeline: the exact labelling dates

PPWR (Regulation (EU) 2025/40) applies from 12 August 2026.

EU harmonised packaging label (material composition for consumer sorting):

  • By 12 August 2026, the Commission must adopt implementing acts setting the harmonised label specifications (including formats and where digital means are used).
  • The obligation for packaging placed on the market to be marked with a harmonised label applies from 12 August 2028 or 24 months from the entry into force of the relevant implementing acts (whichever is later).

Decision 97/129/EC (material identification system): PPWR provides that Decision 97/129/EC is repealed with effect from 12 August 2028 and its content incorporated into the new implementing act framework.

Practical takeaway: in 2025–2027 you generally cannot "skip ahead" to a final EU label design because the exact formats are legally defined via implementing acts, and the obligation date is explicitly linked to those acts.

2) France: Triman + Info-Tri (Sorting Info)

What's required (in plain English)

France's consumer-facing system for household packaging uses:

  • Triman (to indicate the product/packaging is subject to sorting rules); and
  • Info-Tri / Sorting Info (pictograms and instructions showing how to sort each packaging component).

Citeo's Sorting Info guidance explains how to build the label (components, layout, sizing and use cases) to comply with the AGEC framework and Decree 2021-835.

Future-proofing note

National labelling rules can evolve as EU harmonisation arrives. In July 2025, the European Commission referred France to the Court of Justice of the EU regarding aspects of its waste-sorting labelling requirements (Triman/Info-Tri) in the absence of EU-harmonised rules.

Operational takeaway: treat your final France artwork as something you re-check against the latest official guidance before each major print run.

3) Italy: environmental labelling + digital options

What's required

Italy's mandatory environmental labelling requirements apply broadly to packaging placed on the Italian market, including primary, secondary and tertiary packaging.

In practice, businesses commonly provide:

  • Material identification (often aligned to the 97/129 code system); and
  • Consumer disposal instructions (e.g. "Raccolta Plastica / Carta / Vetro" depending on the component).

Are digital channels allowed?

Italian guidance allows the use of digital channels (e.g. QR codes, websites, apps) to provide environmental labelling information, as long as access is clearly signposted so users can reach the information easily. CONAI has published practical guidance on how to implement digital labelling (including what to print on-pack to point to the QR/app/website).

4) Spain: sorting/container indication from 1 January 2025

Spain's Royal Decree 1055/2022 establishes (among other things) marking and consumer information rules for packaging.

Key points you should reflect in your artwork briefs

  • Material marking via 97/129 codes is voluntary unless EU rules establish otherwise.
  • Household packaging must indicate the fraction/container where packaging waste should be deposited; for multi-material packs, the instruction depends on whether components can be easily separated and which material predominates.
  • Where applicable, reusable packaging should indicate it is reusable and show the symbol associated with a deposit–return system (where such a system applies).

Important nuance: Spain's decree also notes that packaging may be identified with symbols indicating membership of an EPR scheme — it is not framed as a single universal "Spain EPR logo" requirement for all packaging.

5) How PPWR interacts with FR/IT/ES

A common misconception is that "PPWR arrives and France/Italy/Spain labels disappear immediately." That isn't how the legal mechanics read in practice.

  • PPWR applies from 12 August 2026, but the harmonised packaging label obligation is linked to implementing acts and applies from 12 August 2028 or later (depending on those acts).
  • Until EU harmonised formats are fully defined and applicable, national labelling systems continue to be the day-to-day compliance reality for exporters selling into those markets.

What to do now: keep national rules (FR/IT/ES) accurate in your artwork briefs today, and plan a controlled transition once the PPWR harmonised label specifications are final and in force.

This article is general information, not legal advice. Packaging rules can change and may be interpreted differently depending on product category, packaging type, and the specific route to market. Always validate final artwork against the latest official guidance and, where needed, qualified local advice.

Sources

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