PPWR traceability does not require serialising every packaging unit. Article 15(5) of Regulation (EU) 2025/40 accepts a type, batch or serial number or other element allowing identification. The European Commission confirms identification may refer to types or production batches rather than to each individual item.
Article 15(5) requires manufacturers to ensure that packaging bears a type, batch or serial number or other element allowing its identification, or, where the size or nature of the packaging does not allow this, that the information is provided in a document accompanying the packaged product. The stated purpose is to link the packaging to its technical documentation and declaration of conformity for compliance verification and market surveillance.
What the provision does and does not demand
| Reading | Position under Article 15(5) |
|---|---|
| A unique code on every individual unit | Not required; a type or batch identifier is expressly accepted |
| A separate marking on every component of a unit | Not required; one component of the sales packaging suffices |
| Identification at the level of a production batch | Accepted, and normal for standardised bought-in items |
| Information in an accompanying document | Permitted where size or nature does not allow marking on the packaging |
The Commission FAQ, in material added in August 2026, gives a yoghurt cup consisting of a plastic cup, lid and sleeve or label, and states that displaying the required information on only one component of the sales packaging should be sufficient. It adds that commonly used standardised items such as adhesive tapes, generic plastic bags and desiccant bags bought from suppliers are normally traceable at production-batch level rather than per unit.
The contact details are a separate obligation
Article 15(6) requires the manufacturer name, registered trade name or registered trademark and postal address to appear on the packaging, on a QR code or another data carrier, or where that is not possible through the Article 12 data carrier or an accompanying document. The postal address must indicate a single point at which the manufacturer can be contacted. Article 15(7) requires the information under both paragraphs to be clear, understandable and legible, and not to obscure or be confused with labelling required by other Union legal acts.
Sources: Regulation (EU) 2025/40, PPWR Frequently Asked Questions, second edition
Setting the identification level at batch rather than unit is a design decision taken early in EU PPWR solutions, and the surrounding Article 15 duties are set out in the PPWR compliance guide.