One of the first challenges businesses face when preparing for the EU Packaging and Packaging Waste Regulation (PPWR) is understanding which obligations apply to them.
PPWR introduces different responsibilities for businesses throughout the packaging supply chain. These depend on their activities, the packaging involved and how that packaging or packaged products reach the market.
The Regulation assigns responsibilities through different economic operator roles, including manufacturers, suppliers, importers and distributors. Businesses may also be classified as producers for Extended Producer Responsibility (EPR) purposes.
A business can hold more than one role under PPWR, meaning it may need to comply with several different sets of obligations.
PPWR began to apply generally on 12 August 2026, although individual requirements apply from different dates.
The Regulation is also relevant to many businesses supplying packaging or packaged products to Northern Ireland, even where those products do not enter an EU Member State. The position is different for some waste management and EPR provisions, so businesses should consider which requirements apply to their activities and markets.
Understanding your role is an important first step towards compliance. This article explains the main differences between manufacturers, producers and suppliers, as well as when businesses may be classified as importers or distributors.
PPWR Roles at a Glance
The role that applies will depend on the circumstances. A business may hold different roles for different packaging or in different supply chains.
How Do I Know if I Am a Manufacturer Under PPWR?
Under PPWR, a manufacturer is a business that manufactures packaging or a packaged product, or has packaging or a packaged product designed or manufactured under its own name or trademark.
This means the manufacturer is not necessarily the business that physically makes the packaging. For example, a brand owner that commissions another company to produce a packaged product under its own brand will generally be considered the manufacturer, even where it does not physically produce the packaging itself.
This can also apply where a business selects standard packaging for its branded product without requesting changes to the packaging’s design.
For unbranded or custom-made packaging, identifying the manufacturer will depend on the circumstances, including which business orders the packaging and determines its design and characteristics.
You may be classified as a manufacturer if:
- You manufacture packaging or a packaged product under your own name or trademark.
- You are a brand owner that has packaging or packaged products designed or manufactured under your name or trademark.
- You commission custom-made packaging and are responsible for determining its design and characteristics. The correct classification will depend on the circumstances.
- You are an importer or distributor that places packaging on the market under your own name or trademark, or modifies packaging already on the market in a way that could affect its compliance.
Manufacturers are responsible for ensuring that their packaging meets the applicable requirements before it is placed on the EU market. This includes carrying out, or having someone carry out on their behalf, the relevant conformity assessment and drawing up the required technical documentation and EU Declaration of Conformity.
What if My Business Is a Micro-Enterprise?
PPWR contains specific provisions for qualifying micro-enterprises. In certain circumstances, a packaging supplier may be treated as the manufacturer instead of the micro-enterprise that commissions or places the packaging on the market.
The position depends on the provision that applies and where the supplier is located. Businesses should therefore check the relevant circumstances carefully before deciding who is responsible for the manufacturer’s obligations, including the Declaration of Conformity.
As a general guide, a micro-enterprise employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2 million. The full EU definition also considers factors such as links to other businesses.
How Do I Know if I Am a Producer Under PPWR?
Under PPWR, the term producer has a different meaning from manufacturer.
While manufacturers are primarily responsible for ensuring packaging meets the applicable regulatory requirements, producers are responsible for packaging EPR obligations in the relevant Member State.
Producer status is determined at Member State level, meaning a business may have producer obligations in several EU countries.
Under Article 3(1)(15), producer status depends on specific conditions, including where a business is established, the type of packaging involved and how it is supplied.
Depending on the circumstances, you may be classified as a producer if:
- You are established in an EU Member State and are the first business to make certain packaging or packaged products available in that Member State.
- You are established in an EU Member State and are the first to make certain service packaging or primary production packaging available there.
- You sell packaging or packaged products directly to end users in an EU Member State from another Member State or from a country outside the EU, such as the UK.
- You unpack packaged products in a Member State without being the end user, where no producer can be identified under the relevant preceding provisions.
For example, a UK retailer selling packaged products directly to consumers in France may be classified as a producer in France, even though the retailer is established outside the EU.
Similarly, an EU business may have producer responsibilities in its domestic market and additional responsibilities when supplying end users directly in other Member States.
Where products are supplied through an EU distributor, the UK business is not automatically the producer in that country. The position will depend on the supply chain and the circumstances.
It is important to note that being classified as a producer does not automatically make a business the manufacturer. However, a business may hold both roles where its activities meet both definitions.
How Do I Know if I Am a Supplier Under PPWR?
Under PPWR, a supplier is a business or individual that provides packaging or packaging materials to a manufacturer.
Suppliers play an important role in helping manufacturers demonstrate that packaging meets the applicable requirements.
For example, a company supplying packaging materials or components to a brand owner may be classified as a supplier, even if the brand owner is ultimately responsible for the packaging’s Declaration of Conformity.
You may be classified as a supplier if:
- You supply packaging materials to a manufacturer.
- You manufacture packaging components for a customer responsible for the finished packaging.
- You supply packaging to a brand owner that commissions packaging under its own name or trademark.
Suppliers do not generally have to draw up the EU Declaration of Conformity solely because they supply packaging or packaging materials. However, a supplier may also have manufacturer obligations where its activities make it the manufacturer under PPWR.
Under Article 16, suppliers must provide the manufacturer with the information and documentation needed to demonstrate that the packaging and packaging materials comply with the relevant requirements. This includes information needed for the technical documentation and, where applicable, information relating to contact-sensitive packaging.
What About Importers and Distributors?
Businesses may also have responsibilities as importers or distributors under PPWR.
An importer is a business established in the EU that places packaging from outside the EU on the EU market.
Importers must carry out relevant checks to ensure packaging complies with applicable requirements, including verifying that the manufacturer has completed the required conformity assessment and documentation.
A distributor is a business in the supply chain, other than the manufacturer or importer, that makes packaging available on the market.
Distributors must also carry out appropriate compliance checks before making packaging available.
An importer or distributor can take on manufacturer obligations if it places packaging on the market under its own name or trademark, or modifies packaging already on the market in a way that could affect compliance. Specific provisions may apply where the importer or distributor is a qualifying micro-enterprise.
Can My Business Hold More Than One Role Under PPWR?
Yes. Depending on your activities, your business may hold more than one role under PPWR.
For example, a company could be the manufacturer of packaging used for its own branded products and also be a producer in one or more Member States, depending on how it supplies those products.
The same company could also act as a distributor when it supplies packaging or packaged products from another manufacturer.
Similarly, a company that supplies packaging materials to another manufacturer may also be classified as a manufacturer for packaging it places on the market under its own name.
The roles that apply will depend on the packaging involved, your business’s activities and the markets in which it operates.
For this reason, businesses should assess their responsibilities for each relevant packaging supply chain and market, rather than assuming that one classification applies across all their operations.
How Can Clarity Help?
Understanding your role is an important first step towards PPWR compliance, but interpreting the definitions and requirements can be challenging, particularly for businesses with complex supply chains or operations across multiple markets.
Clarity’s PPWR Compliance Assessment can help you identify your responsibilities, understand which obligations apply and assess your current compliance position.
Our PPWR specialists can support you in reviewing your supply chain activities, identifying potential compliance gaps and developing a practical action plan to prepare for current and future requirements.
Not sure which PPWR roles apply to your business?
Find out more about our PPWR Compliance Assessment and how we can help you navigate your obligations.
To find out more about the obligations attached to each role, read our article: Who Is Responsible for Packaging Compliance Under PPWR?
