Whose Name and Address Go on the Packaging? The PPWR Identity Block That Gets Approved With the Artwork
Naming the manufacturer, naming the importer and verifying both are three separate duties under Regulation (EU) 2025/40. All three have applied since 12 August 2026, and none of them is a claim, a label or a declaration of conformity.
On the EU side, buyers have asked for the words “PFAS-free” or “compostable” to be printed on the carton, and for a document stating that the product is 100% naturally biodegradable. Those requests arrive as artwork instructions, and most of the discussion they generate is about the wording itself.
The same artwork also carries a different kind of text, which is not a claim and is not optional: the name and postal address of the operator that the regulation requires to be identifiable on the packaging. A carton can repeat the approved claim line perfectly and still fail a distributor’s check on that block. The two are approved in the same file, often by different people, and they are governed by different articles.
The regulation is Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation. It has applied since 12 August 2026. https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
The Commission’s implementation page records the same two dates: in force since 11 February 2025, applicable from 12 August 2026. https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
What Article 15(6) puts on the packaging
The manufacturer’s duty is in Article 15(6). In its own words, manufacturers “shall indicate on the packaging or on a QR code or another data carrier their name, registered trade name or registered trademark as well as the postal address at which and, where available, the electronic means of communication by which they can be contacted.” The same paragraph adds: “The postal address shall indicate a single point at which the manufacturer can be contacted.”
Three details matter at artwork stage.
First, the carrier is not limited to print on the item. The text allows the packaging itself or a QR code or another data carrier. That is a broader choice than the importer gets in Article 18(3).
Second, the fallback is conditional. “Where that is not possible”, the required information must be provided through the QR or other standardised, open, digital data carrier referred to in Article 12(1), (2), (4) or (5), or in a document accompanying the packaged product. “Where that is not possible” is a condition to be established, not a preference to be selected because the print area is tight.
Third, the address is not a general switchboard. It must indicate a single point at which the manufacturer can be contacted.
The identity requirement sits in Article 15(6). The batch identification sits in Article 15(5). They are separate duties. A carton with a batch code is not thereby compliant on the name block.
The importer’s line is separate, and narrower
Article 18(3) addresses the importer: “Importers shall indicate on the packaging their name and their registered trade name or registered trademark as well as the postal address at which and, where available, the electronic means of communication by which they can be contacted. Where it is not possible to indicate that information on the packaging, it shall be provided via standardised, open, digital data carrier as referred to in Article 12 or in a document accompanying the packaged product.”
The order is different from Article 15(6). The importer’s information goes on the packaging first. The digital carrier and the accompanying document are fallbacks, not parallel options.
The importer also has a duty that points back at the manufacturer. Before placing the packaging on the market, Article 18(2)(d) requires the importer to ensure that “the manufacturer has complied with the requirements set out in Article 15(5) and (6)”. So the importer checks the manufacturer’s block before adding its own. Two names on one carton is not a design choice; it is one duty verifying another.
The distributor’s check at the point of supply
Article 19(2)© requires distributors, before making packaging available on the market, to verify that “the manufacturer and the importer have complied with the requirements set out in Article 15(5) and (6) and Article 18(3), respectively.”
“Making available” is defined in Article 3(9) as any supply of packaging, “whether empty or with a product”, for distribution, consumption or use on the Union market in the course of a commercial activity. Empty packaging counts. A wholesaler or a foodservice distributor that supplies empty cartons is inside the wording.
Article 19(3) then says what happens when the check fails: the distributor shall not make the packaging available until it has been brought into conformity or until the manufacturer or importer complies. This is not a paperwork preference. It is a stop condition at the point of supply.
Who is “the manufacturer” when the carton carries a private label?
This is the part that changes the artwork most often.
Article 3(13)(a) defines the manufacturer to include a natural or legal person that has packaging or a packaged product designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible. Article 21 repeats the consequence for an importer or distributor that places packaging on the market under its own name or trademark, or that modifies packaging already placed on the market in a way that could affect compliance: it “shall be considered to be a manufacturer for the purposes of this Regulation and shall be subject to the obligations of the manufacturer under Article 15.”
So on a private-label carton, the name the regulation wants in the manufacturer block may be the brand owner’s, not the factory’s. The factory still manufactures the item. But the duty attaches to the operator that put its name or trademark on the packaging.
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There is a narrow micro-enterprise carve-out, and it does not read the same way in the two places it appears. Under Article 3(13)(b), where the own-brand operator is a micro-enterprise and the supplier is located in the same Member State, “manufacturer” means the supplier. Under the second paragraph of Article 21, for an importer or distributor in that position, the supplier must be located in the Union, and the supplier is then considered to be the manufacturer for the purposes of Article 15. Neither is a general small-order exemption.
Four duties that share one surface
Manufacturer identity — the manufacturer’s name, registered trade name or registered trademark, postal address and electronic contact where available — on the packaging or a QR code or another data carrier, with a conditional document fallback — Article 15(6).
Importer identity — the importer’s name and its registered trade name or registered trademark, with postal address and electronic contact where available — on the packaging, with a digital carrier or accompanying document only where not possible — Article 18(3).
Distributor check — verification that the manufacturer met Article 15(5) and (6) and the importer met Article 18(3), before making the packaging available — not a field on the carton; a check performed against the two blocks — Article 19(2)©.
Environmental claim — a statement about packaging properties — wherever the claim is made, on its own legal conditions — Article 14.
Two more items sit beside them, and neither is the identity block.
The declaration of conformity is a document rather than a field. Article 18(2)(a) requires the importer to check that the manufacturer carried out the conformity assessment and drew up the technical documentation. Article 18(7) requires the importer to keep a copy of the EU declaration of conformity. A carton that carries a DoC reference is not automatically carrying the identity block, and a DoC does not replace it.
The material label under Article 12 has its own dates: from 12 August 2028 or 24 months from the entry into force of the implementing acts adopted under Article 12(6) or (7), whichever is the latest. Article 12(1) expressly exempts transport packaging from that label, except e-commerce packaging, and also exempts packaging subject to a deposit and return system. Article 15(6) and Article 18(3) contain no corresponding exemption.
The part the text leaves conditional
It is tempting to treat the transport carton as the place where every name and address can live. Sometimes it will be the only printed surface. But the regulation attaches the identity duties to “the packaging”, and the routes away from the packaging itself are limited to the ones each article lists. The document fallback is conditional.
Two questions should therefore be answered in writing before the artwork is released, not after the first shipment.
Which physical item is the packaging unit that is being placed on the EU market?
Which carrier route is being used for each identity duty on that unit, and if it is a fallback, what makes the primary route “not possible”?
The answers differ by SKU and by supply arrangement. A clamshell sold empty to a foodservice operator, a clamshell filled at the point of sale, and a clamshell packed in a shipping carton for an importer are not the same packaging configuration. This article does not resolve that scope question for a specific order, and a supplier should not resolve it silently either.
This article covers packaging placed on the EU market from 12 August 2026. It takes no position on stock that was placed on the market before that date. That question needs a separate analysis, and this article does not settle it.
What to check at artwork approval
1. Write down each party’s role: who manufactures the item, who imports it into the Union, who distributes it, and whose name or trademark appears on the packaging.
2. Identify the packaging unit being placed on the EU market, and therefore the surface whose artwork is being approved.
3. Settle the manufacturer under Article 3(13) before the brand goes into the file, not after.
4. Place the Article 15(6) block on the packaging or on the permitted QR or data carrier; if the document fallback is used, record why the primary route is not possible.
5. Place the Article 18(3) block on the packaging; if the fallback is used, record the carrier and keep it with the batch.
6. Check the block is clear, legible and not obscured by, or confusable with, other mandatory labelling, as required by Article 15(7) and Article 18(4).
7. Keep the approved artwork, the role map and the declaration of conformity together, so the distributor’s Article 19(2)© check can actually be performed.
8. Tie the approved version to the batch, type or serial identification required by Article 15(5).
The manufacturer I work with, Zhongxin Packaging, makes molded fiber food packaging and supports OEM, custom and private-label projects. The artwork file is where these lines are fixed. The custom and private-label page is here: https://www.zhongxinpacking.com/oem-odm/
A claim line can sell a box. An identity line is what makes it placeable. The cheap moment to fix both is the artwork approval, while the file is still open.
