First published: September 2026
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, does not place a single obligation on one single party. It creates a framework of responsibilities across the packaging value chain, covering packaging design, manufacture, import, distribution, market placement and waste-related financing. It applies to all packaging and all packaging waste, regardless of the material used or the sector in which the packaging is supplied.
This article discusses the different roles and their responsibilities under PPWR.
If you’re looking for PPWR services, contact us directly.
Roles defined under PPWR
PPWR places obligations on economic operators, not only on the packaging itself. The defined operator categories include the manufacturer, supplier, importer, distributor, authorised representative, producer, final distributor and fulfilment service provider.
A solid PPWR compliance model starts with one practical question: who is the legally responsible operator for this packaging in this market? Once that is clear, the rest becomes more manageable. The relevant operator can then organise conformity assessment, technical documentation, declarations, labelling checks, EPR registration and internal controls in the right place.
Overview of different roles and responsibilities under PPWR
| Role | Official definition under PPWR | Main responsibilities | Key practical point |
|---|---|---|---|
| Manufacturer | The natural or legal person that manufactures packaging or a packaged product; this can also include the person that has packaging or a packaged product designed or manufactured under its own name or trade mark, subject to a limited micro-enterprise exception in certain cases. | Ensure packaging complies before it is placed on the market; carry out or arrange conformity assessment; ensure that procedures are in place for series production of packaging to remain in conformity; ensure proper identification (packaging and manufacturer info); draw up technical documentation; issue the EU Declaration of Conformity; cooperate with authorities. | The legal manufacturer is not always the factory. A brand owner may be the manufacturer if it controls the packaging under its own name or trade mark (as it has decisive power in the contractual relationship with its suppliers and can therefore also determine the packaging characteristics). |
| Importer | Any natural or legal person established within the Union that places packaging from a third country on the market. | Verify that packaging from outside the EU complies; check that required documentation exists; ensure packaging is properly labelled and includes importer info; ensure upstream obligations have been met before placing packaging on the market; ensure storage or transport do not jeopardise compliance; document retention and cooperation with authorities. | Import is not a passive role. The importer needs enough visibility of compliance evidence to support market placement. |
| Importer or distributor becoming manufacturer | Under Article 21, an importer or distributor that places packaging on the market under its own name or trade mark, or modifies packaging in a way that could affect compliance, is considered the manufacturer for PPWR purposes. | Takes on the manufacturer’s obligations under Article 15. | This is one of the biggest practical compliance traps for brands and private-label businesses. |
| Distributor | Any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market. | Verify that packaging complies and that manufacturer/importer obligations have been fulfilled; verify that the relevant producer is registered in the EPR register; verify packaging is properly labelled; do not continue supplying packaging they know, or have reason to believe, is non-compliant. | Distributors still carry due diligence duties, especially in retail, wholesale and marketplace models. |
| Producer | Any manufacturer, importer or distributor to whom one of the situations in Article 3(1)(15) applies; in practice, the operator responsible for EPR in the Member State where packaging or a packaged product is first made available and is expected to become waste. | Register under national EPR schemes where required; report quantities; pay fees; fulfil other Member State EPR obligations. | Producer is not the same as manufacturer. Producer status is market-specific and linked to EPR, not product conformity alone. |
| Authorised representative | Any natural or legal person established in the Union that has received a written mandate from the manufacturer to act on that manufacturer’s behalf in relation to specified tasks under the Regulation. | Act on behalf of the manufacturer for the tasks covered by the written mandate. | This is a product compliance role linked to the manufacturer. The manufacturer’s core duty to ensure packaging conformity and the obligation to originally draw up technical files cannot be delegated. |
| Authorised representative for EPR | A natural or legal person established in the relevant Member State and appointed by the producer to fulfil that producer’s EPR obligations under the Regulation. | Fulfil EPR-related obligations in the Member State where the producer is not established, where required. | This is different from the manufacturer’s authorised representative and is especially relevant for cross-border and distance-selling models. |
The manufacturer role
Under Article 3(1)(13) of Regulation (EU) 2025/40 (PPWR), a manufacturer is, in essence, any natural or legal person that manufactures packaging or a packaged product. The definition also makes clear that, where a business has packaging or a packaged product designed or manufactured under its own name or trade mark, that business is treated as the manufacturer, subject to a limited micro-enterprise exception in certain cases.
A manufacturer must also keep technical documentation available and cooperate with authorities where required, within other obligations.
The important point is that a manufacturer does not always mean the factory physically producing the packaging. In many cases, the legal manufacturer will be the brand owner or the business placing the packaging on the market under its own name or trade mark. For brand-led businesses, that means commercial control can create compliance responsibility.
If your name is on the packaging, or if you determine the packaging specification, you may well be the legal manufacturer for PPWR purposes. That means you cannot rely on a supplier statement alone. You need a technical file, a robust evidence trail, and governance around who signs off packaging claims. At the end, the manufacturer is the sole economic operator bearing legal responsibility for the packaging’s compliance.
The importer role and when they become a manufacturer
Article 3(1)(17) defines an importer as any natural or legal person established within the Union that places packaging from a third country on the market.
Importers have their own obligations under PPWR, such as verifying that the packaging they place on the market complies, that the required documentation exists, and that the manufacturer has met the applicable obligations.
However, importers can become manufacturers in legal terms. Article 21 provides that, where an importer places packaging on the market under its own name or trade mark, or modifies packaging already placed on the market in a way that could affect compliance with PPWR, that importer is considered a manufacturer and becomes subject to the manufacturer obligations under Article 15.
That is an important practical warning for businesses importing packaging or packaged goods from outside the EU. An importer may assume that the original supplier remains fully responsible, but once the importer rebrands the packaging or makes a conformity-relevant change, the compliance burden may shift.
The distributor role
Article 3(1)(18) defines a distributor as any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market.
Distributors are sometimes treated as low-risk operators, but that is too simplistic. Under PPWR, distributors are expected to verify that packaging complies with the applicable rules and that manufacturer and importer obligations have been met before making it available on the market. If they know, or have reason to believe, that packaging is non-compliant, they should not continue supplying it.
That makes distributor due diligence much more important, particularly in wholesale, retail, marketplace and multi-brand environments. A distributor handling hundreds or thousands of SKUs cannot assume that packaging compliance sits entirely upstream. It needs a process to check documentation status, supplier readiness, and escalation routes when evidence is missing or inconsistent.
Producer role under EPR
Article 3(1)(15) defines a producer as any manufacturer, importer or distributor to whom, irrespective of the selling technique used, including distance contracts, one of the situations listed in the Regulation applies.
In practical terms, producer is the operator responsible for extended producer responsibility in the Member State where the packaging or packaged product is made available for the first time and is expected to become waste.
This is a crucial distinction because producer does not mean the same thing as manufacturer:
- The manufacturer is the operator responsible for packaging conformity under the product rules.
- The producer is the operator responsible for EPR obligations such as registration, reporting and fee payment in the relevant Member State.
Under the PPWR, the concepts of producer and manufacturer serve different regulatory purposes. The producer is responsible for financing the collection and treatment of packaging waste in the relevant Member State. To fulfil these obligations, the producer must register with the competent national authorities, submit the required reporting and pay the applicable Extended Producer Responsibility (EPR) fees in the Member State where the packaging is expected to become waste. By contrast, the manufacturer is responsible for ensuring that the packaging complies with the sustainability and labelling requirements set out in Articles 5 to 12 of PPWR before the packaging is first placed on the Union market. Unlike the producer, only one manufacturer can be responsible for a given packaging throughout the EU.
These roles can overlap, but they are not the same thing. In practice, the producer may be a manufacturer, importer or distributor, depending on how the goods enter a particular national market.
That means a company may be the manufacturer for one packaging activity and the producer for EPR purposes in a particular country at the same time. It also means that producer status can change from one market to another depending on how goods are supplied. A company selling directly to end users across borders through e-commerce may be the producer in several Member States, even if another group entity is the legal manufacturer for the packaging specification itself.
Producer status is therefore geographically sensitive. A company may be the producer in France but not in Spain, or vice versa, depending on its route to market. That is why PPWR compliance cannot be managed solely through a packaging specification sheet. It depends on the legal and commercial flow of goods.
For businesses operating across Europe, product compliance tasks such as technical documentation and declarations differ from EPR tasks such as national registration, quantity reporting, and fee payment. Both matter, but they should not be confused.
The authorised representative role
Article 3(1)(19) defines an authorised representative as any natural or legal person established in the Union that has received a written mandate from the manufacturer to act on that manufacturer’s behalf in relation to specified tasks with regard to the manufacturer’s obligations under this Regulation.
PPWR also defines an authorised representative for the extended producer responsibility as a natural or legal person established in the relevant Member State and appointed by the producer to fulfil that producer’s obligations under the EPR chapter of the Regulation.
In day-to-day discussion, businesses often refer to “the authorised representative” as though it were a single concept. Under PPWR, there are two related but different ideas. One concerns the manufacturer’s representation for specified product-compliance tasks. The other concerns representation of the producer for national EPR obligations where the producer is not established in the relevant Member State.
For global brands supplying into Europe, this adds another layer to PPWR planning. Understanding the packaging alone is not enough. Businesses also need clarity on who the selling entity is, where it is established, how products enter each market, and whether an authorised representative for EPR is required. This is especially important for distance selling, marketplace models and cross-border supply chains, where the commercial route to market can determine who is the producer in each country.
Why may the same company hold several roles?
A single company can hold more than one role at the same time. A business might import packaged goods from outside the EU, become the manufacturer because it sells under its own brand, act as a distributor within certain channels, and be the producer for EPR purposes in the Member States where it first makes the goods available.
This is especially common in softlines and hardlines businesses operating globally. One team sources packaging, another approves artwork, another appoints fulfilment partners, and another registers waste obligations in-market. Without a clear role map, accountability becomes blurred. The result is usually inconsistent evidence, duplicate requests to suppliers, and a poor ability to respond to authority queries.
Documentation, declarations and evidence control
PPWR turns packaging compliance into a documentation discipline. Businesses that are manufacturers for PPWR purposes need a complete and credible technical file and a signed EU Declaration of Conformity. Importers and distributors need systems to verify that those documents exist and that the upstream obligations have been met.
In practical terms, companies should be able to answer a short set of questions quickly. What packaging type is this? Which PPWR requirements apply to it? What evidence supports compliance with applicable requirements? Who reviewed and approved the evidence? Where is the documentation stored? Which entity is responsible in each Member State? If those answers cannot be produced reliably, the business is probably not yet operationally ready.
What should businesses do now for PPWR compliance?
The first step is to map all packaging-related roles across the organisation and supply chain. Identify which legal entity acts as manufacturer, importer, distributor or producer for each packaging format and for each market. Do not assume the answer is the same across all product lines or all sales channels.
The second step is to assign documentation ownership. Someone must own conformity assessment, supplier evidence, declarations, EPR registration inputs, claim substantiation and response processes if authorities ask questions.
The third step is to close data gaps, especially where packaging specifications have evolved over time, where multiple suppliers are involved, or where sustainability claims are already being used externally.
How can Eurofins Sustainability Services help you ensure PPWR compliance?
Because PPWR responsibilities differ by operator, the evidence needed to support compliance also differs. Manufacturers need credible evidence for conformity assessment and technical files. Importers need stronger due diligence on third-country supply. Distributors need confidence that upstream obligations have been met. Producers need a clearer link between packaging data and national EPR reporting.
