Yes, for the packaging manufacturer’s contact details under PPWR. A QR code on the packaging can provide that information. Importer details follow a narrower rule: the digital alternative is available where indicating the information on the packaging is not possible. Separate product-labeling requirements may also mean that some company details must remain physical, even when PPWR allows them digitally.

The distinction comes from Articles 15 and 18 of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation. These operator obligations have applied since 12 August 2026. For an EU-bound box we develop at CMIC, the starting point is to establish which company and legal duty each information block represents. That determines how much space a QR code can actually free.

Manufacturer and importer details follow different rules

The manufacturer does not have to establish that the box is too small before choosing the ordinary QR route. Moving the contact block online changes its location; the postal address still has to be supplied, together with electronic contact details where available. For the importer, the inability to indicate the information on the packaging is a condition of using the fallback. A preference for a cleaner-looking panel does not, by itself, establish that printing is impossible.

Whose contact information belongs there?

Under Article 3(1)(13), a business that commissions packaging or a packaged product under its own name or trademark is generally the PPWR manufacturer, even when another company physically makes the box. A brand ordering its own custom packaging from China may therefore hold that role. The Chinese packaging factory’s address is not automatically the address required by Article 15(6). Where different companies’ names and trademarks appear, the August 2026 FAQ explains that contractual control over the packaging design and specifications can determine the manufacturer.

The PPWR importer is an EU-established person that places packaging from a third country on the EU market. Article 21 also makes an importer or distributor subject to manufacturer obligations when it places packaging on the market under its own name or trademark, or modifies it in a way that could affect compliance. Manufacturing origin alone therefore cannot settle whose information belongs on the box: the branding and actual supply arrangement matter.

Special case: qualifying micro-enterprises. Article 3(1)(13)(b) identifies the supplier as manufacturer where the own-brand customer is a qualifying micro-enterprise and the supplier is in the same Member State. Article 15(12) separately treats an EU-based packaging supplier as the manufacturer for Article 15 when its own-brand customer meets the specified micro-enterprise definition. These provisions have different geographical wording; neither supplier-location condition is met by a supplier located in China.

Check the other information on the box before removing anything

A company address may serve more than one legal duty. Where the General Product Safety Regulation’s physical-labeling obligations apply, digital information supplements the required physical information. As UL Solutions’ GPSR guidance explains, digital labeling cannot substitute for those physical requirements. If the box is the permitted location carrying the product manufacturer’s required contact details, PPWR’s QR option alone does not authorize their removal. Products covered by specific legislation need their own labeling assessment. A shared contact block must satisfy each applicable rule.

The packaging identifier has its own placement rule. Article 15(5) requires the packaging to bear a type, batch or serial number, or another identifying element. Where its size or nature prevents this, the fallback is a document accompanying the packaged product. The FAQ explains that a packaging type or production batch can be sufficient; every individual box does not need its own serial number. The identifier connects the packaging to its documentation and declaration of conformity. A QR code opening a general company contact page does not establish that connection.

Environmental labels follow a separate timetable. Article 12(1)’s harmonized material-composition label for consumer sorting applies from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. The optional QR information about sorting separate packaging components is additional to that label. Moving company contacts online does not replace the harmonized label, and its later timetable does not postpone manufacturer and importer information duties.

Match the QR setup to the route you use

Manufacturer contacts through a QR code on the box

This is the ordinary option in the first sentence of Article 15(6). Article 15(7) requires the information to be clear, understandable and legible, without replacing, obscuring or being confused with information required by other EU product-labeling laws. The first-sentence QR option does not expressly cross-refer to Article 12. A code used only for manufacturer contacts therefore should not be treated as though every Article 12 environmental-label condition automatically governs it. If the same code also supplies Article 12 information, the conditions for that information apply.

Importer contacts when printing them is not possible

Article 18(3) explicitly points to the standardized, open digital carrier referred to in Article 12. This fallback needs to be planned against Article 12’s applicable carrier and end-user language provisions, alongside Article 18(4)’s requirement for clear, understandable and legible information that does not interfere with other legally required product information. The privacy and marketing provisions have a more specific content trigger, explained below.

Manufacturer contacts when the packaging cannot carry the text or code

The August 2026 FAQ published by the European Commission describes a fallback through a QR code on grouped packaging, where grouped packaging is used and already bears a carrier for the relevant Article 12 information, or through an accompanying document. This grouped-packaging route uses an Article 12 carrier, so its Article 12 content brings the corresponding presentation conditions with it. For the document fallback, the FAQ calls for a case-by-case assessment of the packaging’s physical dimensions, shape and functional characteristics. A small decorative lid alone does not describe all the usable space on a box.

The relevant Article 12(5) conditions have distinct scopes and triggers:

• Language: information in the Article 12 labels and digital carriers must be available in one or more languages easily understood by end users, as determined by the Member State where the packaging is made available.
• Placement and accessibility: Article 12(5) sets visible, legible and durable marking requirements for the labels and reuse carrier it specifies. Its fallback provisions allow grouped-packaging placement when on-pack marking is impossible or unwarranted because of packaging nature and size, and further electronic provision in specified circumstances, including where needed for nondiscriminatory access for vulnerable groups, particularly visually impaired people.
• Personal data and marketing: for information supplied electronically under Article 12(1), (2) or (4), personal-data collection is limited to the purpose of providing access to the relevant compliance information, and that information must be displayed separately from sales or marketing content. These express restrictions concern that Article 12 information, including when it shares a destination with company contacts.
• A shared product-and-packaging carrier: where EU law requires information about the packaged product through a data carrier, Article 12(5) requires a single carrier for the required product and packaging information, with the two easily distinguishable. The trigger is the legal requirement for digital product information.

For any of these routes, a useful destination opens directly to a clearly labeled contact block identifying the operator’s role and required details. We recommend readable text, access without a sign-in and a layout that works with assistive technology. Assign responsibility for keeping the destination available, too: a website redesign can break a printed link while boxes are still reaching customers. The URL belongs in the approval discussion alongside the artwork.

Existing stock: a specific Article 15 document route. The August 2026 FAQ says packaging produced before 12 August 2026 but not yet placed on the market can use an accompanying document for the Article 15(5) identifier and Article 15(6) manufacturer information. Packaging already placed on the market before that date may remain on the market. For newly manufactured boxes, the ordinary conditions on accompanying documents apply.

A compact gift box: what stays on the base?

Consider a non-EU jewelry brand ordering a compact rigid gift box from us in China for sales through a separate EU importer. For this example, the parties have confirmed that the brand is the PPWR manufacturer and the EU company is the importer. The base panel has usable printing space. The PPWR part of the layout could work as follows:

• Manufacturer contacts: a QR code on the box opens the brand’s required manufacturer identity, postal contact address and available electronic contact details.
• Importer contacts: the required importer identity and contact information remain printed on the base, because indicating them on the packaging is possible.
• Packaging identification: a printed code such as BX-J01-R2 identifies the relevant packaging type or version and connects it to its documentation. This illustrative code only works if the records establish that connection.

Now suppose the brand’s address is also required physically as product-manufacturer information under GPSR, and the box is its permitted location. That address must remain physical as well. The QR route satisfies the PPWR contact-information option, but it does not free that particular area of artwork. The amount of space saved depends on what each printed block currently does.

At CMIC, we can help turn the confirmed information requirements into a workable box layout: position the contact block and identifier, allocate a clear area for the QR code, and coordinate checks on the finished sample. A code that scans from a screen can behave differently on textured wrapping paper, reflective foil or a surface interrupted by a fold. Testing at the intended printed size, on the actual material and finish, helps reveal those problems before production. Reviewing the artwork, packaging identifier and digital destination together also helps ensure that they refer to the intended packaging.

Our guide to PPWR labels, technical documentation and EPR explains the wider relationship between these requirements. To discuss a specific layout, send us your current box artwork, destination markets and confirmed operator details. We can help work through where the information belongs and how the printed code will function on the packaging you want to make.