Position as of 13 October 2026, for packaging placed on the EU market.

For a brand selling products in the EU, PPWR already requires information that identifies the packaging and its responsible manufacturer, plus importer details where applicable. These obligations generally apply from 12 August 2026. The harmonized consumer sorting and reuse labels follow later timetables. For a paper carton or rigid gift box, including one manufactured in China, the immediate artwork decisions concern the packaging identifier, the correct company details, their permitted placement and any applicable destination-market markings.

Information required now

Articles 15 and 18 of Regulation (EU) 2025/40 set out the identification and contact requirements. Their placement rules differ, particularly when digital information is used.

A QR code can carry the manufacturer’s contact information under Article 15(6). That permission does not automatically extend to every field in the table. Article 18(3) makes the importer’s digital or document alternative conditional on being unable to put the information on the packaging. The packaging identifier has its own size-or-nature exception for accompanying documents.

The identification and contact information must be clear, understandable and legible. It must not replace, obscure or be confused with information required under other EU legislation for the packaged product. This makes placement part of the design decision: the contact panel needs enough space to remain readable alongside any required product information.

The identifier connects the physical packaging to its technical documentation and EU declaration of conformity. The Commission’s FAQ confirms that identification can work at packaging-type or production-batch level; individual serialization of every box is not generally required. For illustration, BX-042-R2 / B2610 could identify a box model, specification revision and production batch. An existing product code can serve this purpose if the records behind it also identify the relevant packaging. If the insert or wrapping material changes, that connection needs to remain reliable.

Whose details belong on packaging made in China?

Under Article 3, a business that has packaging or a packaged product designed or manufactured under its own name or trademark is generally the PPWR manufacturer, subject to the specific exceptions below. The physical factory and the legal manufacturer can therefore be different companies. For an own-brand box that CMIC makes in China, the commissioning brand may be the manufacturer whose information belongs on the packaging, while we supply the packaging and supporting material and production information.

The importer test requires both EU establishment and placing packaging from a third country on the EU market. It covers packaging imported empty or with products inside. Article 21 also gives manufacturer duties to an importer or distributor that places packaging on the market under its own name or trademark, or modifies it in a way that could affect compliance.

When one company performs both roles, the same contact information can serve both purposes. A single physical panel containing its name and registered trade name or trademark, postal contact address and electronic contact where available can cover the fields in Articles 15(6) and 18(3). The address does not need to be printed twice. Keeping those details only behind a QR code would leave the importer-placement requirement unmet where the packaging can accommodate them. If physical placement is impossible, the importer alternatives in Article 18(3) become relevant.

Microenterprises have specific supplier rules. Article 3(1)(13)(b) makes the supplier the manufacturer where the own-brand business qualifies as a microenterprise and its supplier is in the same Member State. Separately, Article 15(12) assigns Article 15 manufacturer duties to an EU-based supplier of own-brand packaging to a microenterprise; that provision does not contain the same-Member-State restriction. Article 21 contains a corresponding rule. Direct sourcing from a China-based supplier does not meet these EU-supplier conditions. Microenterprise status is assessed under EU enterprise-size rules, including fewer than 10 persons employed and annual turnover or annual balance-sheet total not exceeding €2 million.

Current national marks and existing stock

For artwork being approved now, check the destination’s applicable national sorting and marking rules alongside PPWR, including any relevant deposit-return marking. One country’s sorting mark is not an EU-wide requirement. Required information for the packaged product also remains part of the layout: where the product’s legislation calls for ingredients, warnings or other particulars, the PPWR contact panel must leave that information clear and readable.

The Commission’s August 2026 FAQ explains that packaging produced and held in stock before 12 August 2026, but not yet placed on the market, need not be destroyed, remanufactured or relabeled to meet Article 15(5)–(6): the identifier and manufacturer details may be supplied in an accompanying document. This accommodation concerns those manufacturer-information requirements; importer information still follows its applicable placement rules. Packaging already placed on the market before that date can also remain available under the FAQ’s transitional guidance. For newly manufactured packaging, use the ordinary placement rules rather than extending the stock accommodation to new production.

Putting the information on a rigid gift box

Consider the first supply route: a two-piece jewelry box made in China for an EU brand that also acts as the importer. The box has a dark textured wrap, a foil logo on the lid and a removable insert. A discreet printed panel on the base can carry the company’s combined manufacturer and importer contact details, with a separate field for the packaging reference or batch code. The lid retains its presentation space, while the base provides the physical contact information required for the import role.

For a lid-and-base box treated as one packaging unit, an identifier on the base can identify the unit when its records cover the complete construction; the Commission’s FAQ does not require every component to be individually marked for traceability. Material information still needs to account for the actual components. A removable plastic insert, for example, changes the information needed to explain sorting even when the outside of the box looks entirely paper-based.

At CMIC, we can translate confirmed operator details, destination requirements and the selected construction into an annotated artwork layout and a marked sample for review. Keeping the identifier away from a wrapping joint makes it easier to apply and read. Fine contact lettering needs checking on the actual paper and finish, where texture or reflection can reduce clarity. If the design includes a QR code, we can check scanning at its intended printed size. These checks help your team approve the information as it will appear on the finished box.

Sorting and reuse labels: the later timetable

At this October 2026 update, the Commission’s implementation page describes the implementing act covering sorting, reuse and content labels as still in preparation. The Regulation’s 12 August 2026 deadline for adopting specifications does not establish that a final format has been adopted. The application dates below therefore retain their implementing-act conditions.

A sturdy gift box that a customer keeps for jewelry storage is not automatically reusable packaging within the PPWR framework. Reuse status needs to be assessed against Article 11 and the relevant reuse arrangements. Board thickness, a magnetic closure or an attractive storage function alone does not establish that status, which determines whether the later reuse label and digital information belong in the specification.

Other markings depend on the packaging

• Compostability: for formats covered by Article 9(1) and, where applicable, Article 9(2), Article 12(1) specifies information that the material is compostable, is not suitable for home composting and must not be discarded in nature. Paper-based construction alone does not establish compostability.
• Deposit-return systems: scheme-covered packaging needs its applicable return-system marking. National DRS labels retain separate treatment; Article 12 also provides for a harmonized color label that Member States may require.
• Recycled or biobased content: PPWR does not require a recycled-content percentage on every paper box. Article 12(4) governs voluntary recycled-content labels for packaging within Article 7’s plastic-packaging scope, and biobased-plastic-content labels. The relevant harmonized specifications govern their use once applicable.
• Substances of concern: Article 12 provides for specific digital marking following an implementing methodology, which the Commission is to adopt by 1 January 2030.

Placement, digital information and the transition

When the Article 12 labels apply, they must be visible, legible and firmly affixed, printed or engraved so they cannot easily be erased. Where the packaging’s nature and size make direct placement impossible or unwarranted, Article 12(5) provides a grouped-packaging alternative, followed by an electronic-code route where that alternative is also unsuitable or accessibility needs warrant it. The information must also be available before an online purchase. The label and digital information must use languages easily understood by end users, as determined by the destination Member State; English alone is not automatically sufficient throughout the EU.

PPWR does not impose a universal QR code or Digital Product Passport on every gift box. Additional digital sorting guidance is optional, while particular uses, such as covered reusable packaging, carry specific digital duties. Where other EU law requires product information through a data carrier, Article 12(5) requires a single carrier for the relevant product and packaging information, with the two easily distinguishable. Article 12 digital compliance information must also be presented separately from sales or marketing information.

The Commission’s guidance says national sorting labels cannot remain alongside the harmonized EU labels once the corresponding regime applies; deposit-return labels are a separate case. The older material-identification system under Decision 97/129/EC is scheduled for repeal on 12 August 2028. Existing material codes should therefore not be treated as the final future PPWR pictograms.

A separate transition under Article 12(12) covers packaging manufactured in the EU or imported before the relevant Article 12 labeling deadlines. Qualifying stock may remain available for up to three years from the entry into force of those labeling requirements. For boxes manufactured in China, the import condition matters: an early factory production date alone does not establish eligibility for this later transition.

The records behind the information panel

Technical documentation, the EU declaration of conformity and EPR registration and reporting are separate obligations from the printed information panel. PPWR does not turn the full technical file, test reports or an EPR registration number into universal text for every consumer box. The packaging identifier provides the connection to the supporting records. Our guide to PPWR labels, technical documentation and EPR explains how those responsibilities fit together.

If you are preparing an EU packaging order, share the box structure, destination markets and confirmed operator information with us. We can help turn those details into a readable layout and check them on a physical sample before production artwork is approved.