Packaging Manufacturer

Who is the Packaging Manufacturer?

• In most cases, the Packaging Manufacturer is you, as you are the brand owner.
• For bulk or white label wine, it may be the retailer.
• Micro-enterprises in the EU, fewer than 10 staff and turnover or balance sheet of €2 million or less, have different rules (Article 15(12)) that the EU has yet to clarify.

From Section 3 of the EU Guidance*

Note: This is still being clarified. The EU has a number of open questions about this definition. Consult the EU guidance and your own legal advisor if your case isn't clear-cut.

What information is required?

Name
Your name, registered trade name, or registered trademark

Postal address
A single point at which you can be contacted

Email
Your electronic means of communication

How to Add

For all your e-labels at once (recommended)
This applies the same details to every e-label, including older vintages.

Go to your e-labels. You may already see a prompt to add a Packaging Manufacturer.

If you do not see this screen, click on Account in the bottom of the left hand menu. On the screen you will see Packaging Manufacturer, Click on the button Set Packaging Manufacturer.

For a single e-label

Open the e-label form and find the Packaging Manufacturer section under Packaging.

What if it is on my printed labels?

Look at your printed label first.

1. It already shows your name and postal address, then the requirement is met. The only presentation rule is that the information must be "clear, understandable and legible" (Article 15(7)). No heading or particular wording is prescribed, so it does not have to say "Packaging Manufacturer" to count. A QR code is not mandatory for this — though we'd still recommend setting it on your e-labels.
2. It shows a name and address, but not yours — a bottler or distributor, say - that doesn't identify you as the Packaging Manufacturer. Add your own details to your e-labels.
3. It shows nothing, then add the details to your e-labels.

12 August 2026

A 2024 vintage first placed on the EU market after 12 August 2026 needs a Packaging Manufacturer, even though it was grown and bottled long before the deadline. The vintage year is irrelevant. What counts is the date the packaging reaches the market — so library releases, late releases and older stock entering the EU for the first time are all in scope.

The legislation

Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) applies from 12 August 2026. Manufacturer identification is Article 15(6); Article 15(7) governs how it must be presented.

Article 15(6)

"Manufacturers shall indicate on the packaging or on a QR code or another data carrier their name, registered trade name or registered trademark as well as the postal address at which and, where available, the electronic means of communication by which they can be contacted. Where that is not possible, the required information shall be provided as part of the information through the QR code or other type of standardised, open, digital data carrier as referred to in Article 12(1), (2), (4) or (5) or in a document accompanying the packaged product. The postal address shall indicate a single point at which the manufacturer can be contacted."

Article 15(7)

"Manufacturers shall ensure that information provided in accordance with paragraphs 5 and 6 is clear, understandable and legible, and that it does not replace, or obscure nor can be confused with information required by other Union legal acts on the labelling of the packaged product."

Article 15(5)

"Manufacturers shall ensure that the 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 so allow, that the required information is provided in a document accompanying the packaged product."

Updated on: 17/08/2026