Food packaging already carries a considerable amount of mandatory information, from the name and address of the responsible food business operator to batch codes and product traceability details. It may therefore seem reasonable to assume that the same information will also satisfy the identification requirements introduced by the Packaging and Packaging Waste Regulation.
According to the European Commission’s updated PPWR FAQs, however, that assumption may be wrong.
Food legislation and the PPWR are separate regulatory frameworks with different objectives. Information provided to comply with food law may also support PPWR compliance, but only when it meets the specific requirements established for the packaging itself. Compliance with food labelling rules alone is therefore not automatically sufficient.
The PPWR requires the packaging to be identifiable
Article 15(5) of the PPWR requires packaging to carry a type, batch or serial number, or another element that allows it to be identified. Where the size or nature of the packaging makes this impossible, the information may be included in a document accompanying the packaged product.
The purpose is not simply to trace the food inside the pack. The identifier must allow the relevant authorities to connect the packaging to its technical documentation and EU Declaration of Conformity.
A batch code already printed on a food product may therefore be sufficient only if it also identifies the packaging in a way that enables this regulatory link. A code that traces the production of the food but provides no connection to the packaging type, series or conformity documentation may not meet the PPWR requirement.
The distinction becomes clearer with a simple example. A yoghurt cup may already display the food business operator’s name and a batch code for the yoghurt. But that code may trace the dairy product rather than the packaging unit made up of the cup, lid and label. The information may consequently satisfy food traceability rules without providing the packaging traceability required under the PPWR.
The food business operator may not be the packaging manufacturer
The second issue concerns the identity of the responsible economic operator.
Food legislation requires the identification of the food business operator responsible for the information provided to consumers. The PPWR, by contrast, requires the identification of the packaging manufacturer, determined according to the regulation’s own definition of manufacturer.
These two entities may be the same, but they do not have to be.
A retailer, food producer, co-packer, brand owner or another operator may be identified under food law, while responsibility for the packaging under the PPWR depends on factors such as who manufactures or commissions the packaging and under whose name or trademark it is placed on the market.
The Commission therefore makes clear that the identification of an operator under food law does not, by itself, determine who the packaging manufacturer is for PPWR purposes.
This is particularly relevant for private-label products and outsourced manufacturing arrangements, where several companies may be involved in the food product, the packaging design, filling and market placement.
What information must be checked?
Under Article 15(6), packaging must provide the manufacturer’s name, registered trade name or registered trademark, together with a postal address and, where available, an electronic means of communication.
The information may be provided physically on the packaging or, in certain circumstances, through a QR code or an accompanying document. The method used must comply with the specific presentation rules set out by the PPWR.
Brands should therefore verify whether the information already present on their food packaging:
- identifies the packaging rather than only the food product;
- can be linked to the correct technical documentation and Declaration of Conformity;
- names the economic operator that qualifies as the manufacturer under the PPWR;
- includes the contact information and presentation format required by the regulation.
This does not necessarily mean that every food pack will need an additional set of names, addresses and codes. One set of information can satisfy both food law and the PPWR where the responsible operator is the same and all the requirements of both frameworks are met.
But the Commission’s message is clear: existing food labelling cannot simply be assumed to cover the new packaging obligations.
For brands, the challenge is therefore not merely to add more information to the pack: it is to determine whether the information already printed identifies the right operator, traces the packaging itself and connects it to the documentation required to demonstrate PPWR compliance.
