Effects on print data
The labelling requirements associated with the manufacturer’s role have a direct impact on print output. Under Article 15(5) of the PPWR, every package must bear a marking for identification, such as a type, batch or serial number, which corresponds to the number of the associated EU Declaration of Conformity. This marking must be affixed once to each sales, repackaging and transport package.
Furthermore, under Article 15(6) of the PPWR, the name, trade name or brand and the postal address of the manufacturer must be provided. For imports from non-EU countries, the importer is responsible for providing this information and must include their own contact details within the EU (Article 18 of the PPWR).
The type, batch or serial number must, as a general rule, be affixed to the packaging. Only if this is not possible due to size or nature may the information be provided in the accompanying documents (e.g. delivery notes, etc.) (Article 15(5) of the PPWR). The only aspect that is freely selectable is the structure of the company-specific numbering system (EU Commission FAQ, Chapter XV, No. 7).
The contact details (see above), on the other hand, may also be displayed on the packaging via a QR code (Art. 15(6)). This may be particularly useful if the additional information on recyclability and similar details, which will become mandatory from 2030, is included in the linked data sets of dynamic QR codes.
The requirements for labelling under Article 15 of the PPWR apply to all packaging categories, i.e. including outer and transport packaging. Print data should therefore be checked accordingly and supplemented with identification and address details as soon as possible.
The role of the producer in relation to private-label products
Unlike under the German Packaging Act (Verpackungsgesetz), the PPWR stipulates that responsibility lies not with the party placing the product on the market (e.g. the manufacturer or co-packer), but with the producer.
The German “Central Packaging Register” (ZSVR) has already drawn attention to this in a press release dated 16 April 2026 and further confirmed this in a notice dated 19 June 2026, referring to the consistent legal interpretation within the European Register Network (EUNR). Accordingly, with the PPWR coming into force on 12 August 2026, the role of producer for own-brand products and for imported third-party brands without a domestic intermediary lies with the retailer. This is based on Article 3(1)(13) of the PPWR and the supplementary guidelines issued by the European Commission.
An example from the Commission dated 16 June 2026, cited by the ZSVR, reads as follows: When distributing a ‘third-party branded product’, the brand owner is regarded as the producer; in the case of a private label, this is the retail company, even if another company fills the packaging.
Different viewpoints within the retail sector
Currently, different viewpoints on this matter can be observed within the retail sector. Some retailers continue to regard themselves primarily as traders in the case of own-brand products and identify the supplier as the responsible producer or manufacturer on the product. Others specify in their style guides exactly how manufacturer and distributor details are to be placed on primary and secondary packaging. It is therefore advisable for suppliers, packagers and printers to coordinate these requirements at an early stage, as the entire supply chain relies on the same compliance data.
