http://forums.catholic.com/showthread.php?p=1922412
quote
I am not aware of any permission for lay people to distribute ashes outside of the USA. In the USA there is no permission for lay people to distribute ashes in Mass.
The Roman Missal has "The priest then places ashes on those who come forward, saying to each: ..." (page 77)
The Ceremonial of Bishops has:
"257 After the blessing, the appointed minister, a concelebrant or a deacon, places ashes on the bishop, as the bishop bows before him, and says, Turn away from sin and be faithful to the Gospel or Remember, man, you are dust and to dust you will return.
258 Then the bishop again puts on the mitre and, seated at the chair or standing, places ashes on the concelebrants, the ministers, and the faithful. The bishop may be assisted if necessary by some of the concelebrants or deacons."
endquote
Me here. The alternate wording is valid. The use of EMHC to distribute ashes seems to be an abuse, but a widespread one. Seems like an oversight in the law.