Sectors and timing
Does your packaging need a digital product passport?
Packaging has its own EU rule, Regulation (EU) 2025/40. The food exclusion does not reach it, and no packaging passport duty is confirmed.
A pallet of sauvignon blanc lands in Hamburg. EU law sees five products on it, and only one of them is the wine.
The other four are the bottle, the label, the carton and the shrink wrap. No confirmed passport duty covers any of them today.
Packaging is a separate physical good in European Union (EU) law, and it has its own regulation.
The food exclusion is real, and it stops at the food. The bottle, the label and the carton are not food, so the exclusion never covered them.
Those duties fall on your importer. The pack still has to comply, and you are the one who chooses it.
One pallet of wine is five products
Those five are:
- the wine
- the glass bottle
- the paper label
- the cardboard carton
- the shrink wrap around the pallet
The wine is food, and the ecodesign regulation excludes it. The other four are packaging, and a different regulation covers them.
The exclusion is in the ecodesign regulation, and it covers food
The Ecodesign for Sustainable Products Regulation (ESPR) creates a digital product passport for the products it covers. Its Article 1(2) excludes food and feed.
Food includes drink. So wine, beer and bottled water sit outside that regulation. See food and feed are excluded and wine, beer and spirits.
The exclusion attaches to the product. It does not attach to the company, and it does not attach to the box. ESPR exclusions gives the full list.
The packaging regulation is in force, and it is phased
| Item | Detail |
|---|---|
| Instrument | Packaging and Packaging Waste Regulation |
| Number | Regulation (EU) 2025/40 |
| Status | In force since 11 February 2025 |
| Application | From August 2026, with phased implementation |
The two dates have different meanings. The regulation entered into force first. It starts to apply later, and it applies in stages.
The official text is on EUR-Lex, at Regulation (EU) 2025/40.
No packaging passport is confirmed, but four other duties apply
The sources behind this site do not confirm a digital product passport duty for packaging. They confirm a label, a data carrier rule, a registration duty and a material limit.
Warning: this site publishes no start date for the Article 12 label. The sources behind this site do not confirm that date. Read the regulation text before you commit to a print run.
| Provision | What it requires |
|---|---|
| Article 12(1) | A harmonised label that gives the material composition |
| Article 12(5) | One data carrier, where Union law already requires information through a data carrier |
| Articles 44 and 45(3) | Registration in the producer register of each member state of first supply |
| Article 5(4) and 5(6), with Annex VII | Lead, cadmium, mercury and hexavalent chromium capped at 100 mg/kg combined |
France adds a national requirement. Its environment code, article L. 541-10-13, requires a unique identification number.
Article 12(5) asks for one data carrier
Article 12(5) asks for one data carrier where Union law already requires information through a carrier. It asks for one code on the box, not two.
The Ministry of Foreign Affairs and Trade (MFAT) made the same point about the passport. MFAT published a report on the EU packaging rules in March 2025. It states that where a product also falls under ESPR, the passport should carry the packaging information too.
Treat the MFAT statement as a planning assumption, not as a duty. No delegated act covers any product group today, so no passport carries anything yet. See which products need a passport, and when and how to read the timeline.
The practical consequence is a design choice, and you make it early. Plan for one identifier and one data source that can serve both the packaging label and a later passport. See data carriers.
The exclusion covers the wine, and not the bottle
Work through the pallet again, item by item.
The wine needs no ecodesign passport. No EU law was found that requires a digital product passport for food.
The bottle, the label, the carton and the shrink wrap fall under the packaging regulation. That regulation covers their material composition, their heavy metal content and their producer registration, whatever is inside them.
The same split reaches a honey exporter, a dairy exporter and a pet food exporter. See does my New Zealand food product need one.
A New Zealand regulator wrote about this rule, and left the passport out
The Ministry for Primary Industries (MPI) issued circular F16/26 in April 2026. Its subject is the EU Packaging and Packaging Waste Regulation.
That circular never mentions a digital product passport or ecodesign.
Two things follow. The packaging rule is real enough for a New Zealand regulator to issue a circular about it. This site searched 104 New Zealand pages on 16 August 2026, and MFAT joins packaging to the passport in one sentence of one report. See what New Zealand agencies have said.
Record every packaging component, and buy no passport system
- Do not buy a passport system for your packaging. No such duty is confirmed.
- List every packaging component: bottle, closure, label, carton, wrap.
- Record the material of each component, because Article 12(1) asks for it.
- Check each component against the heavy metal limit of 100 mg/kg.
- Find out who registers you in each member state of first supply.
- Ask your EU importer to confirm that duty in writing.
The last two items are both about registration. A registration duty needs a name against it, and your importer may assume that name is yours.
See first steps for a New Zealand exporter for the wider list. What this means for New Zealand exporters gives the position across all sectors.
Do not treat the food exclusion as the end of the answer. The wine is excluded, and the bottle, the label and the carton are not.