A packaging identification code under PPWR is a practical name for the reference used to identify the packaging: a type, batch or serial number, or another identifying element. The legal duty belongs to the PPWR manufacturer. In practice, the brand and packaging supplier can agree who creates and applies the reference.

For a brand sourcing custom gift boxes, that reference should connect the box in someone’s hand to the correct specification and conformity records. Its value becomes especially clear when an insert changes, another supplier joins the project or a repeat order enters production: everyone needs to know exactly which packaging the documents describe.

What PPWR actually requires

Article 15(5) of Regulation (EU) 2025/40 requires manufacturers to ensure that packaging bears a type, batch or serial number or other element allowing its identification. The provision gives businesses flexibility in how they identify packaging. It does not prescribe a universal character pattern or establish a central application process for an EU-issued packaging number.

An existing brand packaging reference or supplier item number can therefore be a starting point, provided it identifies the packaging clearly. This identification duty forms part of the manufacturer obligations applying from 12 August 2026. It is separate from the harmonised consumer-sorting labels under Article 12, which follow their own later timetable.

Who creates the reference, and who is responsible?

PPWR assigns responsibility by legal role. Under Article 3(1)(13)(a), a business that has packaging or a packaged product designed or manufactured under its own name or trademark is generally the manufacturer. Outsourcing physical production does not, by itself, move that responsibility to the factory.

For example, a France-based skincare brand commissions rigid gift boxes under its own trademark from a packaging supplier in China. Under the own-brand rule, the brand will generally be the PPWR manufacturer for those boxes. The supplier can propose a reference, incorporate it into the artwork and apply a production-batch marking. The brand remains responsible for ensuring that the identification requirement is met.

That responsibility comes with a supporting supply-chain obligation: Article 16 requires suppliers to provide the information and documentation the manufacturer needs to demonstrate conformity. For a CMIC project, we can help align the customer’s packaging reference with our production reference, approved specifications and supporting supplier documents. Agreeing that relationship early gives both sides a usable reference before the artwork is released.

Two micro-enterprise provisions have different scopes. Both depend on meeting the EU micro-enterprise definition.

• Article 3(1)(13)(b): where the qualifying business has packaging or a packaged product made under its own name or trademark and its packaging supplier is in the same Member State, the supplier becomes the manufacturer under the definition.
• Article 15(12): where the qualifying business has packaging made under its own name or trademark and the packaging supplier is located in the EU, the supplier is considered the manufacturer for the purposes of Article 15.

Direct sourcing from a China-based supplier does not meet either supplier-location condition. These provisions allocate the duties to another business; they do not remove the identification requirement.

An EU importer also has its own checks. Article 18 requires it to verify, among other things, that the manufacturer has met Article 15(5) and (6), covering packaging identification and manufacturer contact information. One business can occupy more than one role, so the allocation should follow the actual commercial arrangement.

Type, batch or serial number: what does each identify?

• A type reference points to a defined packaging design or specification, such as a particular rigid box with specified dimensions and components.
• A batch reference identifies a production lot, helping connect supplied boxes to the records for that run.
• A serial number identifies an individual packaging unit, allowing that particular unit to be distinguished from others.

Article 15(5) presents alternatives; it does not require every gift box to receive an individual serial number. For repeat custom-box orders, combining a stable design reference with a changing batch reference can make both specification checks and production investigations easier. That combination is a practical choice, rather than a prescribed PPWR numbering formula.

A rigid-box example: connecting type, revision and batch

Consider a lid-and-base rigid box with a fitted paperboard insert for a two-bottle skincare set. One practical marking could read RB014-R02 / L017. These illustrative references divide the information into three useful parts:

The technical documentation would connect the identified packaging to the evidence supporting its conformity. The EU declaration of conformity would identify and describe the packaging it covers. Annex VIII expressly calls for identification of the packaging allowing traceability. A declaration’s own document number serves a separate purpose: it identifies the declaration. The connection to RB014-R02 must still be clear.

The brand and supplier can keep their existing internal references if the relationship is recorded clearly. For example, the brand’s RB014-R02 may correspond to a different supplier job number. At CMIC, we can help put those references alongside the approved specification and relevant documents, so a buyer does not have to reconstruct the connection from old emails.

A repeat order made to the same approved specification could retain RB014-R02 and receive batch reference L018. If a gluing problem is later reported, the batch reference helps locate the production records for the affected run while the type and revision establish what should have been made.

Now suppose the paperboard insert is replaced with a moulded plastic insert. The closed box may look identical, but its composition and relevant conformity evidence have changed. A controlled revision such as R03, or another distinct reference, can preserve that difference. Review the affected evidence and documents before carrying them forward, and retain the earlier reference for boxes already supplied. Article 39(2) requires the declaration of conformity to be kept continuously updated; a revision system helps make those updates traceable.

Where should the identifier appear?

The starting rule in Article 15(5) is that the packaging bears the identifier. Where its size or nature does not allow this, the required information must be provided in a document accompanying the packaged product. Keeping a reference only in an internal spreadsheet does not fulfil that placement requirement.

For a typical rigid gift box, a legible marking on the base is a practical option to assess during artwork approval. Check it on the intended paper and finish: fine characters that look clear on screen can become difficult to read against a dark or textured wrap. Article 15(7) requires the information to be clear, understandable and legible, and to avoid replacing, obscuring or being confused with information required under other EU product-labelling laws.

Plan the packaging reference alongside the manufacturer name and contact information required by Article 15(6). That paragraph expressly provides options involving QR codes and other data carriers for contact information. Those options are separate from the packaging-identification wording in Article 15(5). Where a QR code also links to packaging information, keeping the packaging reference readable in text makes it usable without a scan.

How it differs from other codes on packaging

The manufacturer and the EPR producer are determined for different purposes and may be different businesses. Our guide to PPWR labels, technical documentation and EPR explains how these responsibilities fit together.

Agree the connection before approving the artwork

A useful result before production is a marked artwork proof accompanied by a short reference record: which packaging the identifier covers, which revision is approved, how supplier references correspond and how batches will be recorded. Starting with that proof, the brand and supplier should be able to locate the same specification and supporting documents. This makes an identification decision reviewable while the marking can still be adjusted.

If you are developing custom paper packaging for EU sales, share your specification, sample or existing packaging reference with us. CMIC can help agree a workable marking, connect brand and production references, and coordinate the supporting packaging information. The aim is for the finished box and its records to tell the same precise story about what was approved and what was supplied.