Practical reflections on identification and traceability where EU guidance remains limited

The EU Packaging and Packaging Waste Regulation (PPWR) is a very topical subject, and at this stage there is still considerable uncertainty around several requirements. While EU‑level guidance on the PPWR has been published, this guidance does not provide clarity with respect to the identification requirement under Article 15(5). In particular, it does not address how the identification element must look, how it should be structured, or the level of traceability granularity expected in practice. As a result, the required level of granularity remains unclear.

Discussions in the market indicate that the intended risk level of the packaging may be relevant when determining an appropriate identification approach. For example, batch‑level identification is often considered suitable for food packaging, whereas other packaging formats may justify a higher‑level identifier. However, this approach has not been confirmed by EU authorities.

In addition, batch‑level identification may not be technically feasible for all packaging items, depending on the printing technique used. Many packaging solutions rely on fixed templates, and updating these for each production run or batch can be costly or impractical.

While Article 15(5) itself does not prescribe a specific level of granularity, it should be read together with the traceability obligations for economic operators set out in Article 22 of the PPWR. These obligations require operators to be able to identify from whom the packaging was received and to whom it was supplied. As a result, the packaging identifier under Article 15(5) must be sufficiently granular to allow the physical packaging placed on the market to be reliably linked to the corresponding compliance documentation, including the technical documentation and the Declaration of Conformity, as well as to relevant supply‑chain records. As a result, this may indirectly influence the level at which identification is implemented, even though no specific format or batch level is formally mandated.

At this stage, it is largely up to the brand to determine a suitable packaging identifier. Among our clients, we see different approaches. Some rely on internal item numbers or packaging type identifiers, while others use batch or purchase‑order references, although this can be challenging where variable data printing is not technically feasible.

Article 15(5) applies to packaging as such and does not explicitly require every individual packaging component to be identified. Generally, identification at packaging type or configuration level is considered sufficient, provided the packaging can be clearly identified and traced in the technical documentation. Applying separate identifiers to each individual component is not explicitly required under the Regulation. The definition of the relevant “packaging unit” may ultimately depend on the sales channel and the packaging set‑up. At present, we follow the interpretations suggested by Ohana.

Regarding timing, the decisive criterion under the PPWR is when the packaging is placed on the EU market, not when it is manufactured. In theory, packaging placed on the market from 12 August 2026 onwards must comply, which could imply re‑labelling of non‑compliant stock placed on the market after that date. At the same time, one of the stated objectives of the PPWR is to prevent and reduce packaging waste. For this reason, it is questionable whether authorities will expect systematic re‑labelling of existing stock. Based on experience from previous labelling obligations, such as Triman (France), it will likely be important to demonstrate to authorities that the company is actively working towards compliance, particularly during the initial enforcement phase.

Finally, responsibilities must be clearly understood, as confusion frequently arises around the definitions of manufacturer, importer, and producer under the PPWR. In general, the packaging supplier provides the technical documentation to the brand. The brand uses this information to carry out the conformity assessment, draw up the Declaration of Conformity and acts as the producer for EPR purposes. Shipment or transport packaging used to ship unfilled brand packaging remains the responsibility of the supplier, including the technical documentation, the Declaration of Conformity and the associated EPR obligations.

In this sense, the PPWR should not be viewed solely through the lens of immediate compliance challenges. It marks a broader transition towards more intelligent, connected, and circular packaging systems, where identification and traceability are enablers rather than administrative burdens. The current phase, while uncertain, offers the industry a rare window to rethink how packaging information is structured, shared, and validated across the value chain. Companies that use this period to align internal data, strengthen supplier collaboration, and test proportionate identification models will be well positioned not only to comply with the PPWR, but to leverage it as a foundation for future transparency, efficiency, and innovation in packaging compliance.