The Micro-Enterprise Rule
For micro-enterprises, stating several packaging manufacturers via a QR code is particularly relevant. The reason lies in a specific PPWR rule on how the manufacturer role is attributed.
The three conditions
For the packaging supplier to count as the manufacturer, all three points must be met at the same time:
- The company has packaging or packed products designed or manufactured under its own name or brand.
- The company is itself a micro-enterprise within the meaning of the EU definition.
- The packaging supplier is established in the same member state.
If one of these conditions is missing, the assessment turns out differently. Because the criteria depend on your specific company and supply chain structure, we cannot answer the question for your case.
In Brief
What does the rule say?
In certain constellations the packaging supplier may count as the packaging manufacturer – rather than the company selling the product under its own brand.
This requires three conditions to coincide: your own brand, the company is itself a micro-enterprise, and the packaging supplier is established in the same member state.
Why does that lead to several manufacturer entries?
Because packaging usually consists of several components sourced from different manufacturers – and attribution happens per component.
Bottle, closure, label and carton can have four different manufacturers. Fitting every name and address onto the label is barely feasible. That is exactly what the QR code is for.
Which criteria apply to a micro-enterprise?
EU Recommendation 2003/361/EC states fewer than 10 employed persons and an annual turnover or balance sheet total not exceeding €2 million.
Criteria on autonomy from linked enterprises apply in addition. Whether your company meets the definition should be assessed by qualified advisers.
Does the rule affect my company?
We cannot assess that – it depends on your company and supply chain structure.
We do not provide legal advice. If you are unsure, talk to us: we will refer you to our competent partners for swift legal advice.
This page describes the rule in general terms. It does not constitute an individual legal assessment and does not replace legal advice.
What the entry in the QR code looks like
You record the corresponding packaging manufacturer for each packaging component.
Product
Packaging component A
Packaging component
Manufacturer A
Packaging manufacturer
Packaging component B
Packaging component
Manufacturer B
Packaging manufacturer
Packaging component C
Packaging component
Manufacturer C
Packaging manufacturer
The QR code for your packaging is generated from these entries.
Create a QR code for your packaging manufacturers
State the packaging type and its manufacturer, receive your QR code.
Unsure whether the rule applies to you?
Get in touch. We will talk it through with you and refer you to our competent partners for swift legal advice.
We do not provide legal advice ourselves and do not make a legal assessment of your individual case.
Request a QR code
Tell us briefly which components your packaging consists of and which manufacturers are behind them. We will get back to you with the next steps.
Prefer a personal conversation or have an urgent question?