Supply-Chain Traceability: The Article 22 Identification Duty

Article 22 requires every economic operator to be able to identify, on request by an authority, the operator that supplied it with packaging or packaged products and the operator - or, at the chain's end, the final distributor - to which it supplied them. The information must be kept for five years for single-use packaging and ten years for reusable packaging, matching the documentation retention periods elsewhere in the regulation.

It is the shortest duty in the chapter and the one that makes the rest enforceable. Conformity failures are traced, recalls are bounded and responsibility is apportioned by walking Article 22 records from operator to operator. A chain whose traceability fails does not have several small problems; it has one large one with several names.

The duty is intentionally shallow: you must know your immediate supplier and your immediate customer for packaging flows, not the whole chain. Depth emerges from the sequence - an authority assembles the full path by asking each operator its one step. The design keeps the burden proportionate for small operators (your records are your invoices) while making the chain as a whole transparent to anyone with the patience to walk it. Two consequences follow. Records must identify operators unambiguously - legal name and address, not a trading nickname or a sales rep's first name. And gaps cannot be compensated by neighbours: your supplier's excellent records do not discharge your duty to hold your own step.

For most businesses the duty is already discharged by ordinary systems - ERP supplier and customer masters, invoice archives, marketplace and fulfilment records - provided three conditions hold: the records are retained to the regulation's periods (many default retention settings are shorter than ten years, and reusable packaging now sets the longer clock); they can be produced as a set, filtered to packaging flows, within a reasonable request window; and they survive system migrations, which is where ten-year records most often quietly die. A one-time archive audit - can we produce, today, the supplier set for a packaging line from three years ago - tests all three conditions in an afternoon.

Reusable packaging strains the simple picture, because the same physical units circulate: supplied, returned, washed, resupplied. The ten-year retention exists precisely for this loop, and pool operators' rotation records double as traceability evidence. Operators running their own reusable fleets should treat the fleet register - units, movements, counterparties, losses - as the Article 22 record for those flows, kept to the same standard. When a reusable unit is implicated in an incident years into its life, the register is either the answer or the finding.

The duty is reactive in form - identify on request - and preparatory in substance: a request typically arrives with a deadline measured in days, attached to a live enforcement or safety matter. Businesses that assemble records after the request discover the difference between having data and having evidence: scattered invoices, departed staff, a fulfilment provider whose contract never promised production. The cheap preparation is a named owner, a known query and a tested export for each system that holds identity data. Test it once a year, on a random line, and file the test itself - it is the record that your records work.

Nothing in Article 22 requires software. A two-person business discharging it with a disciplined invoice archive - supplier invoices filed by date, sales records likewise, retained for the full period - is compliant in substance. The risks for small operators are retention and retrieval, not format: default accounting-package purge cycles, the bookkeeper's housekeeping, the laptop that held the only copies. One conversation with whoever keeps the books - do not purge packaging-relevant records inside ten years, and here is the folder structure - discharges most of the duty's real risk for a small chain. Cheap, unglamorous, decisive: the regulation in miniature.