Does every single pack need its own unique number?

No. PPWR allows identification by type, model, batch, serial number or another equivalent element. The marking must make it possible to link the packaging to its documentation and declaration of conformity.

Does AS-INTER-BOX always issue the PPWR declaration of conformity?

No. The declaration is drawn up by the entity that is the manufacturer within the meaning of PPWR. Where that is the customer, AS-INTER-BOX provides the required information and supplier documentation under Article 16 PPWR.

Does a food-contact declaration replace the PPWR DoC?

No. These are separate bases of conformity assessment. The documents may be combined in one dossier, but the assessment against each legal act must remain clearly separated.

Does the 50% empty space limit apply to a cake box?

Not as a single sales packaging item. Such a box must fit the product as closely as reasonably possible, but may keep the space needed to protect decoration, close the pack and transport it safely. The 50% limit applies to grouped, transport and e-commerce packaging.

Does filling a carton with paper reduce empty space?

No. Under PPWR, space taken up by filling materials still counts as empty space.

Can existing packaging stock still be used?

Packaging placed on the market before 12 August 2026 may remain on the market. For stock produced before that date but not yet placed on the market, the Commission FAQ allows the required data to be provided in an accompanying document.

PPWR in practice: traceability, documentation and packaging choice

Updated: 9 August 2026, based on the PPWR FAQ, second edition. Prepared by the AS-INTER-BOX documentation and quality team.

From 12 August 2026 the PPWR reorganises responsibility for packaging conformity, identification and documentation. It does not mean that every QR code has to point to the printing house, or that every customer receives the same document.

The PPWR entered into force on 11 February 2025 and generally starts to apply from 12 August 2026. Individual obligations also have later dates of application.

The first step is to establish who the manufacturer of the packaging is within the meaning of PPWR. Only that role determines who draws up the EU declaration of conformity, whose details belong on the packaging and what information package the supplier provides. AS-INTER-BOX identifies its packaging by type, model and batch, and prepares documentation matching the construction of the pack and the roles of the parties in the supply chain.

Check the documentation for your packaging See the packaging catalogue

Key points at a glance

Identification does not mean numbering every single unit

PPWR allows packaging to be identified by type, model, batch, serial number or another equivalent element. The marking must connect the pack with the right technical documentation and declaration of conformity.

A QR code does not decide who the manufacturer is

The manufacturer is established first, based on how the packaging is designed, marked and placed on the market. A QR code is only one of the permitted ways of communicating those details.

AS-INTER-BOX does not always issue the PPWR DoC

Where we are the manufacturer under PPWR, we draw up the EU declaration of conformity and maintain the technical documentation. Where the customer is the manufacturer, we supply the information and documents required by Article 16 PPWR.

The 50% limit does not apply to a single cake box

The limit covers grouped, transport and e-commerce packaging. For sales packaging the rule is to limit volume and empty space to the minimum necessary for product protection and functionality.

Who draws up the PPWR declaration of conformity

PPWR uses the concept of the manufacturer. That is not always the company which physically prints, die-cuts or glues the box. The manufacturer must be established for the specific way the packaging is sold and marked.

Who draws up the PPWR declaration of conformity
Situation	Who is usually the PPWR manufacturer	Who draws up the PPWR DoC
Standard, unbranded box from the AS-INTER-BOX range, intended to be filled at the counter	AS-INTER-BOX as manufacturer of the finished service packaging	AS-INTER-BOX
Box carrying the name or brand of a bakery or pastry shop that is not a micro-enterprise	The owner of the name or brand	Customer (bakery / pastry shop)
Box carrying the brand of a customer that is a micro-enterprise, supplied by AS-INTER-BOX within the same Member State	AS-INTER-BOX as the supplier of the packaging	AS-INTER-BOX
Unbranded box made to an individual construction and specification defined by the customer	The customer who orders the packaging and decides on its specification	Customer (bakery / pastry shop)
Sales packaging filled before the finished product is offered	Usually the pastry shop, bakery or another filler, or the owner of the product brand	Customer (the filler or the owner of the product brand)

Standard, unbranded box from the AS-INTER-BOX range, intended to be filled at the counter

Who is usually the PPWR manufacturer: AS-INTER-BOX as manufacturer of the finished service packaging
Who draws up the PPWR DoC: AS-INTER-BOX

Box carrying the name or brand of a bakery or pastry shop that is not a micro-enterprise

Who is usually the PPWR manufacturer: The owner of the name or brand
Who draws up the PPWR DoC: Customer (bakery / pastry shop)

Box carrying the brand of a customer that is a micro-enterprise, supplied by AS-INTER-BOX within the same Member State

Who is usually the PPWR manufacturer: AS-INTER-BOX as the supplier of the packaging
Who draws up the PPWR DoC: AS-INTER-BOX

Unbranded box made to an individual construction and specification defined by the customer

Who is usually the PPWR manufacturer: The customer who orders the packaging and decides on its specification
Who draws up the PPWR DoC: Customer (bakery / pastry shop)

Sales packaging filled before the finished product is offered

Who is usually the PPWR manufacturer: Usually the pastry shop, bakery or another filler, or the owner of the product brand
Who draws up the PPWR DoC: Customer (the filler or the owner of the product brand)

The final classification depends on the specific product, its marking and the design arrangements. It cannot be changed by contract alone, nor freely “assigned” by a QR code. In every case the PPWR declaration of conformity is drawn up by the party identified as the manufacturer. Where that is the customer, AS-INTER-BOX does not declare on their behalf but provides the supplier information and documentation required by Article 16 PPWR.

Important: the “manufacturer” responsible for packaging conformity is not the same concept as the “producer” fulfilling extended producer responsibility obligations.

PPWR manufacturer vs. EPR producer

PPWR uses the terms manufacturer and producer for two different kinds of responsibility. The same company may hold both roles, but they must not be treated as automatically identical.

PPWR manufacturer

Responsible for: Conformity of the packaging with PPWR, conformity assessment, technical documentation, the EU declaration of conformity, packaging identification and manufacturer contact details
How it is determined: Determined for the packaging across the EU. What matters includes how it is made, who orders and specifies it, brand marking and the micro-enterprise exception.

EPR producer

Responsible for: Registration, reporting of packaging volumes and financing the collection and treatment of packaging waste
How it is determined: Determined separately for each member state. What matters is who first makes that packaging type, or the packed product, available there.

The manufacturer answers the question: who is legally responsible for this packaging’s conformity and its declaration of conformity? The EPR producer answers a different one: who registers, reports and finances the waste from this packaging in a given country?

For example, if AS-INTER-BOX is the first to make a standard unbranded service box for counter filling available in Poland, it is usually both the PPWR manufacturer and the EPR producer. If, however, a patisserie fills sales packaging before offering the finished product, it usually holds both roles.

BDO is not a name for either of these roles. It is the Polish registration and reporting system in which different categories of businesses fulfil obligations under national law. A BDO entry alone does not determine who is the manufacturer or producer within the meaning of PPWR.

Check the documentation for your packaging Ask about custom-printed packaging

How packaging traceability works

The identifier must lead from a specific pack to the right type, batch and documentation. It does not require a unique number on every single box. In practice the system can have three levels:

1
Packaging type
defines the basic construction, e.g. folded or glued packaging.
2
Model or index
identifies the dimensional variant and the commercial product.
3
Production batch
links the item to a specific production run, materials and quality control.

The identification may sit on one element of the packaging unit. Where the size or nature of the packaging genuinely prevents direct marking, PPWR allows the required information to be provided in an accompanying document.

Information used for food traceability may also serve PPWR only where it unambiguously identifies the packaging and links it to the correct PPWR declaration of conformity.

Manufacturer details and the QR code

The manufacturer should provide:

its name, registered trade name or trade mark,
a postal address allowing contact,
an electronic means of communication, where available.

The details may be given directly on the packaging, in a QR code or in another data carrier. Where that is not possible because of the size or nature of the packaging, they may be placed in a carrier on the grouped packaging or in an accompanying document, as provided for by PPWR.

A QR code is not mandatory for every packaging item. It is a tool that can organise access to information, but it does not replace correctly establishing the manufacturer, the type or batch identifier, or the technical documentation.

Where AS-INTER-BOX acts solely as a supplier, the rules do not require our details on the packaging. We can, however, technically apply the identifier and the details of the relevant manufacturer during production.

What documents the customer receives

When AS-INTER-BOX is the PPWR manufacturer

We prepare the EU declaration of conformity for the relevant packaging type and maintain the technical documentation behind it. The product identifier links the delivered packaging to the right declaration.

When the customer is the PPWR manufacturer

We provide the supplier information and documentation required by Article 16 PPWR, which the customer needs to carry out the conformity assessment and issue its own declaration. A general statement that something is “PPWR compliant” does not replace the technical data needed to demonstrate conformity.

Food-contact documentation vs. PPWR

Food-contact material documentation and the PPWR declaration of conformity cover two different areas of law. They may be presented in one structured dossier, but the assessment against each legal act must remain clearly separated. A food-contact document alone does not replace the PPWR declaration of conformity.

Packaging minimisation and empty space

PPWR requires packaging to be no larger or heavier than necessary to retain its function. Product protection, hygiene, closability, efficient packing and safe transport remain legitimate design requirements.

A single box for cake, gateau or bread

No 50% limit is set for sales packaging. Empty space should be reduced to the minimum needed for functionality and product protection. For confectionery, the following can be justified:

clearance protecting decoration from contact with walls and lid,
space allowing the product to be inserted and removed safely,
tolerance for the usual dimensional variation of hand-made products,
a construction that keeps the pack stable while carried,
space needed for hygienic closing of the pack.

Marketing, or simply increasing the perceived volume of the product, does not justify extra space. That is why each model should have a defined range of dimensions and intended uses.

Grouped, transport or e-commerce packaging

For these, the maximum empty space ratio will be 50%. Responsibility lies with whoever fills such packaging — a warehouse, a pastry shop or a fulfilment operator.

The ratio is calculated as follows:

empty space = volume of the outer packaging − total volume of the sales packaging insideempty space ratio = empty space / volume of the outer packaging × 100%

Filling materials such as paper shreds, air pillows, bubble wrap, foam or wood wool still count as empty space.

The Commission is to adopt a detailed calculation method by 12 February 2028, covering fragile, liquid, irregular and specially protected products. Until it is published, current calculations should not be presented as the final harmonised EU method.

What AS-INTER-BOX does

We are building a system in which packaging can be unambiguously linked to the right construction and documentation. It covers:

identification of type, model or index and production batch,
linking the batch to the materials used and quality control records,
documentation on suitability for food contact,
documents and information required for PPWR conformity assessment,
analysis of the intended use and any necessary limitations of use,
matching dimensions to the protective function of the product,
updating documentation after a change of construction, material or legal requirement.

The scope of documents provided depends on who the manufacturer of the given packaging is under PPWR. This keeps responsibilities properly divided — without shifting obligations onto the customer that are not theirs, and without declaring on behalf of an entity that should declare for itself.

Deadlines and packaging already in stock

The PPWR entered into force on 11 February 2025 and generally starts to apply from 12 August 2026. Individual requirements, however, start to apply on different dates.

Packaging placed on the market before 12 August 2026 may remain on the market.
For packaging produced before that date but not yet placed on the market, the information required by Article 15(5) and (6) may be provided in an accompanying document.
For packaging produced after 12 August 2026, an accompanying document may replace marking only where placing the information directly on the pack is genuinely impossible.
The obligation to reduce empty space in sales packaging to the necessary minimum applies from 12 February 2028.
The 50% limit for grouped, transport and e-commerce packaging applies from the later of 1 January 2030 or three years after the relevant implementing act enters into force.

Frequently asked questions

Related PPWR resources

PPWR from 12 August 2026: what applies now and what comes laterTimeline of obligations, existing stock and a checklist before the date of application.Who is the packaging manufacturer under PPWRSupplier, brand owner or micro-enterprise — who draws up the EU declaration of conformity.

Not sure who should draw up the PPWR DoC for your packaging?

Check the table above, “Who draws up the PPWR declaration of conformity”. If in doubt, contact us.

Sources and legal basis

This content is informational. Determining the manufacturer role and the scope of documentation requires assessing the specific construction, marking, intended use and the relationship between the parties.