Although the marking obligations of RD 1055/2022 came into force on January 1, 2025, the sector had doubts about its technical application and its coexistence with the new European Regulation (PPWR).

The specific clarifications and changes that this note adds to resolve that uncertainty are:

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Technical definition of “Small Size Packaging”.

Prior to this note, there was ambiguity about what was considered too small a package to be marked. The note establishes precise metric criteria based on EU technical guidelines:

• Physical threshold: Containers with a width equal to or less than 10 cm or insufficient front surface for minimum labels.
• Minimum label dimensions: It is defined that a label with text must be at least 15 mm wide, and if it only contains symbols, 6 mm. If the package does not allow these sizes, the use of digital alternatives is justified.

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Flexibility in the use of QR Codes

The note introduces a “pro-trade” interpretation to prevent physical marking from being a barrier in the single market:

• Avoiding obstacles to trade: QR is allowed specifically for packaging destined for several Member States (multi-language labeling), preventing each country from requiring a different physical marking that saturates the packaging.
• Cut-off date for previous QRs: Clarifies that the exception for containers that were already using QRs should be understood as referring to January 1, 2025, in order to provide legal certainty to those who had already digitized their information prior to that deadline.

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“Impossibility” criteria for physical marking

The note adds a list of technical assumptions that were not detailed before, legally allowing the use of digital media when there is:

• Material limitations: Such as screen-printed glass or die-cut metal where printing of recycling instructions is technically unfeasible.
• Risk of functional deterioration: Cases where printing or marking the package (as in certain heat-sealed products) may compromise its integrity.

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Stock Management and Extraordinary Deadlines

To avoid the destruction of products (prohibited by the Ecodesign Regulation), the note establishes an “out-of-stock” rule with an important temporal nuance:

• 6-month deadline: It is allowed to market stocks manufactured or imported before January 1, 2025 until stocks are exhausted, but it sets a 6-month horizon for this transition.
• Protection against recalls: Specifies that the coexistence on the shelf of products with and without marking should not be a reason for withdrawal from the market, especially protecting low rotation products.

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Multiple Sales Units

It clarifies a critical logistical point: if a sales unit contains several individual containers and it is not possible to mark them all, the information on the destination container can appear only on the outer sales unit.

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Details on Compostables and Reusables

• Compostables: Confirms that the marking of compliance with the UNE EN 13432:2001 standard and the legend “do not abandon in the environment” is strictly compliant as of January 2025.
• Reusable and DRS: Clarifies that the deposit symbol and reusable status only affect containers purchased on or after January 1, 2025, not those already circulating in the market prior to that date.