The Central Horticultural Association (ZVG), the North Rhine-Westphalia Horticultural Association, the Association of the German Flower Wholesale and Import Trade (BGI) and Landgard are recommending that horticultural businesses implement the labelling requirements of the European Packaging and Packaging Waste Regulation (PPWR) using a QR code. The industry organisations see this as the most pragmatic solution for providing the required producer information on sales packaging such as flower pots, sleeves and labels.
The PPWR has been applicable in all EU Member States since 12 August 2026. According to associations and Landgard, the responsibility for labelling sales packaging lies with those who ultimately fill or pack the products or pots. In horticulture, these are generally the producing businesses.
The sales packaging must therefore be marked with a type, batch or serial number and display at least the name and postal address of the manufacturing business. According to industry organisations, it is sufficient for one of the packaging components of a product within a packaging unit to be labelled accordingly.
Combine serial number and QR code
The type, series or batch number must be clearly visible directly on the sales packaging and must not be encrypted. As a simple option, the associations and Landgard mention the serial number found on the underside of many standard plant pots. The prerequisite is that this number enables the producer to trace which packaging materials were used. This is intended to ensure that the relevant declarations of conformity can be provided in the event of an official enquiry.
The situation is different when it comes to the details regarding the producer. According to the industry associations, the name and postal address may be provided via a digital medium such as a QR code. ZVG, the NRW Horticultural Association, BGI, and Landgard therefore recommend a combination of the pot's serial number and a QR code on a component of the sales packaging, for example on the pot, bag, or label.
The QR code should lead directly to the required producer details. It can either contain the name and address itself or link to a website where this information is displayed directly. In the estimation of the associations and Landgard, horticultural businesses can thus implement the PPWR labelling in a comparatively simple and practical manner.
Transport packaging does not fall under the recommendation
The organisations distinguish transport packaging, such as trays and cardboard boxes, from sales packaging. This also has to be labelled. However, the corresponding labelling obligation lies with the packaging manufacturers and not with the horticultural production businesses, as the saying goes.
According to the associations, an exception could be achieved for plants that were already in stock in pots before 12 August 2026. This goods do not have to be retrospectively labelled and can be identified via an accompanying note.
Furthermore, the organisations point to a transitional period provided for in the Packaging Law Implementation Act until 12 February 2027. Within this period, no administrative fine proceedings would be initiated for regulatory offences concerning the PPWR compliance of packaging. However, the transitional arrangement does not exempt companies from implementing the PPWR requirements, including the labelling of sales packaging, as early as 12 August 2026.
Associations criticise legal basis
Notwithstanding their QR code recommendation, the horticultural associations and Landgard view the legal situation critically. Not all provisions of the PPWR have yet been interpreted in a legally secure manner, leading to widespread uncertainty across the sector. The organisations therefore intend to continue advocating for clarifications and practical adjustments.
In the political dialogue, the aims include achieving longer transitional periods and a shift in the labelling obligation from producer farms to packaging manufacturers, among other things. Since no corresponding changes are to be expected in the short term, the associations and Landgard recommend labelling the sales packaging using a QR code for the time being.
Source: Landgard
