Master Data & Marking

Overview

Master data & marking (Art. 5, 15, 22) is the second step of a packaging item's journey. It drives the Article 5 requirements, the marking obligations, and the evidence needed downstream, and changes here apply immediately. This is where you record how the item is sourced and how it is marked on the pack, and where you file the artwork that proves it.

Before you start

• Complete the item's Classification first: this step reads Single-use / Reusable and Food contact from there and shows them read-only under "Set in classification", with a link back if they need changing.
• Have the pack artwork or label file at hand, plus the manufacturer name and address exactly as displayed on the pack.

Step by step

1. Check the classification values. The "Set in classification" box mirrors Single-use / Reusable and Food contact. If they are wrong, follow from Classification and fix them there; they are maintained in classification only.
2. Set the sourcing of empty packaging. Select where the empty packaging comes from, for example Bought in EU. Sourcing shapes which supplier evidence matters and who carries which duties for the empty packaging.
3. Record the marking on pack (Art. 15(5)/(6)). The marking block carries a Declared manually badge, because you declare what the pack shows:
   • Identifier scheme on pack. How the item is identified on the packaging itself, for example a moulded-in cavity number and date wheel on the base plus a pool asset label on the short side.
   • Manufacturer name & address as displayed. The name and address exactly as shown on the pack. Importers additionally carry their own address duty (Art. 18(3)).
4. Upload the artwork / label. Evidence of the marking as displayed on the pack: identifier scheme, address block, symbols. Upload the PDF (max 10 MB); its text is extracted automatically into the Content of this input field, which you can edit or write yourself. The slot shows Complete once evidence is in place.

Retention

The step reminds you how long this evidence is kept after placing on the market, per Art. 15(3): 5 years for single-use packaging, 10 years for reusable packaging. The applicable period follows the item's classification, for example "Keep 10 years (Reusable)".

After this step

• The step shows Complete, and the marking evidence is on file for the item.
• Substances and Technical documentation build on these values and the supplier evidence you file next.

Tips

• Enter the address exactly as printed, not the official registered address, if they differ; the point is to evidence what the pack actually shows.
• Re-upload the artwork when the pack design changes; the marking record should always match the pack in the market.

ℹ️ Regulatory context. Marking and identification duties come from Article 15(5)/(6), with importer-specific additions in Article 18(3), harmonised labelling in Article 22 as it phases in, and the retention periods in Article 15(3). See Regulation (EU) 2025/40.

Common Questions