{"id":11341,"date":"2026-06-25T21:39:59","date_gmt":"2026-06-25T19:39:59","guid":{"rendered":"https:\/\/empact.nu\/are-you-a-producer-covered-by-the-ppwr-your-role-and-obligations-explained\/"},"modified":"2026-06-26T16:20:33","modified_gmt":"2026-06-26T14:20:33","slug":"are-you-a-producer-covered-by-the-ppwr-your-role-and-obligations-explained","status":"publish","type":"post","link":"https:\/\/empact.nu\/en\/insights\/are-you-a-producer-covered-by-the-ppwr-your-role-and-obligations-explained\/","title":{"rendered":"Are you a producer covered by the PPWR? Your role and obligations explained"},"content":{"rendered":"\n

The same packaging can mean a mountain of obligations for one company and almost nothing for another. The difference isn\u2019t in the packaging, but in your role. And it\u2019s precisely that role that many companies misjudge. The importer who assumes that his foreign supplier will take care of it. The online store that thinks, \u201cWe\u2019re just reselling.\u201d <\/p>\n\n

In this article, we explain the different roles defined by the PPWR, when you are considered a manufacturer, when you are considered a producer, and what obligations are associated with each. We base our explanation on the definitions in the regulation itself, Regulation (EU) 2025\/40, specifically Article 3. This article provides further detail on our overview of the new European Packaging Regulation<\/a>. <\/p>\n\n

\"\"<\/figure>\n\n

An Overview of Economic Roles<\/h2>\n\n

The PPWR identifies a number of economic roles<\/strong>\u2014the market participants in the supply chain. These roles primarily determine the product side: does the packaging meet the requirements, and who verifies this? <\/p>\n\n

Role<\/strong><\/td>When did you do this?<\/strong><\/td>Primary duty<\/strong><\/td><\/tr><\/thead>
Manufacturer<\/td>You manufacture packaging or a packaged product\u2014or have it manufactured\u2014and market it under your own name or brand<\/td>Product Conformity: Recyclability, Recycled Content, Technical Documentation, Declaration of Conformity, Labeling<\/td><\/tr>
Importer<\/td>You import packaging or packaged products from outside the EU and place them on the European market<\/td>Verify that the manufacturer meets the requirements; often, you also act as the manufacturer for the UPV<\/td><\/tr>
Distributor<\/td>You make packaging available on the market without being a manufacturer or importer<\/td>Duty of Care: Verifying Proper Labeling and Documentation<\/td><\/tr>
Fulfillment Service Provider<\/td>You handle storage or shipping without being the owner of the goods<\/td>Facilitation duties: verifying that your client is in compliance<\/td><\/tr>
Online platform or marketplace<\/td>You facilitate distance sales to consumers in the EU<\/td>Personal Responsibility Under the PPWR (Art. 45)<\/td><\/tr>
Authorized Representative<\/td>You fulfill certain obligations in the EU on behalf of a foreign manufacturer (Art. 17)<\/td>Function, not a separate outcome: you assume the manufacturer’s obligations<\/td><\/tr><\/tbody><\/table><\/figure>\n\n

“Producer”<\/strong> is intentionally not listed as a separate row in this table. It is not an economic role in this list, but a separate status for the waste phase. Therefore, a single company can be both a manufacturer as listed in this table and a producer for the UPV, or it can be one but not the other. <\/p>\n\n

When are you considered a manufacturer?<\/h2>\n\n

A manufacturer is a natural or legal person who manufactures packaging or a packaged product, or has it designed or manufactured, and places it on the market under their own name or brand. The emphasis is not on physical production, but on control over the design, specifications, and brand name. <\/p>\n\n

Example.<\/strong> Company A designs packaging for its own brand of coffee. An external packaging supplier physically manufactures the packaging. Company A is therefore the manufacturer, while the supplier is merely a contract manufacturer. <\/p>\n\n

When are you considered a producer?<\/h2>\n\n

The definition of \u201cproducer\u201d is linked to the UPV rules and is assessed on a Member State-by-Member State basis<\/strong>. A producer is generally the party that first makes packaging or a packaged product available in a Member State, imports it from outside the EU, or sells it directly to end users in a Member State via distance selling. So, you can be a producer in one country but not in another. Three common scenarios: <\/p>\n\n

Example 1: Dutch manufacturer.<\/strong> A Dutch company manufactures and sells packaged products in the Netherlands. It is both a manufacturer and a producer in the Netherlands. <\/p>\n\n

Example 2: Export to Germany.<\/strong> The same company also sells directly to German consumers through an online store. It remains the manufacturer and also becomes a producer in Germany. This means it is required to register with the German Packaging Register. <\/p>\n\n

Example 3: importer.<\/strong> A Dutch distributor imports packaged products from China. The Chinese company may be the manufacturer, but the Dutch importer is considered the producer for the purposes of Dutch UPV obligations. <\/p>\n\n

What do those roles actually mean?<\/h2>\n\n

If you are a manufacturer<\/strong>, you must demonstrate that your packaging meets the product requirements: it must be recyclable, contain the required percentage of recycled material, and use as little material as possible. You must document this in technical documentation and an EU declaration of conformity, and ensure proper labeling. You can read about exactly what these requirements entail in our article on the PPWR requirements<\/a>. <\/p>\n\n

If you are a manufacturer<\/strong>, you must register before placing packaging on the market, periodically report the quantity and type of packaging you have placed on the market, and pay a waste management fee that covers the costs of collection and processing.<\/p>\n\n

If you fall into both categories, your responsibilities pile up. That\u2019s the case for many brand owners. <\/p>\n\n

Foreign Companies and Their Authorized Representatives<\/h2>\n\n

Is your company based outside the EU, but do you place packaging or packaged products on the market here? If so, you may need an authorized representative: a party based in the EU that fulfills the obligations on your behalf. This is not a separate role with its own outcome, but a function. The obligations do not disappear; they are fulfilled by someone based here. <\/p>\n\n

Three Misconceptions We Often Encounter<\/h2>\n\n

\u201cI only import, so my supplier is responsible.\u201d<\/strong> If you place a product from outside the EU on the European market, you are generally the one placing it on the market. The obligations fall on you, not on your foreign supplier. <\/p>\n\n

\u201cWe\u2019re just reselling this, so it\u2019s not ours.\u201d<\/strong> Distance selling and online platforms are explicitly covered by the PPWR. A marketplace that facilitates sales to consumers in the EU has its own responsibilities. <\/p>\n\n

\u201cWe\u2019re too small; I\u2019m sure this doesn\u2019t apply to us.\u201d<\/strong> There are a few exceptions, but the leeway is limited and is getting smaller rather than larger. Don’t count on getting out of it too easily. Check your situation. <\/p>\n\n

Where do you start?<\/h2>\n\n

Start with the question this article opened with: What exactly is my role? Without that clarity, you\u2019re basing your entire preparation on an assumption. <\/p>\n\n

Are you unsure about your role? The free PPWR tool<\/a> walks you through the roles outlined in the regulation, determines separately whether you are a producer in the Netherlands, and shows you the tasks associated with that role. And, of course, you can also contact us for PPWR advice<\/a>. <\/p>\n\n

Frequently Asked Questions<\/h2>\n\n

What is the difference between a manufacturer and a producer under the PPWR?<\/h3>\n\n

The manufacturer is responsible for ensuring the packaging complies with product requirements: recyclability, technical documentation, and the EU Declaration of Conformity. The producer is responsible for extended producer responsibility (EPR): registration with the national registry, reporting, and financing the management of packaging waste. You can have one without the other, or both at the same time. <\/p>\n\n

I only import\u2014am I still responsible?<\/h3>\n\n

Generally speaking, yes. You\u2019re placing the product on the European market, so the obligations fall on you. In practice, when it comes to the end-of-life phase, you\u2019re often considered the producer in the country where you import the product. <\/p>\n\n

Does this also apply to my online store?<\/h3>\n\n

Yes. Online sales and marketplaces are explicitly covered by the PPWR. Even if you\u2019re just reselling, you may still have a responsibility. <\/p>\n\n

What if I’m based outside the EU?<\/h3>\n\n

In that case, you may need an authorized representative in the EU: a party that fulfills the obligations here on your behalf.<\/p>\n\n

<\/p>\n","protected":false},"excerpt":{"rendered":"

The same packaging can mean a mountain of obligations for one company and almost nothing for another. The difference isn\u2019t in the packaging, but in your role. And it\u2019s precisely that role that many companies misjudge. The importer who assumes that his foreign supplier will take care of it. The online store that thinks, \u201cWe\u2019re […]<\/p>\n","protected":false},"author":17,"featured_media":11388,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[257],"tags":[],"class_list":["post-11341","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-insights"],"_links":{"self":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11341","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/users\/17"}],"replies":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/comments?post=11341"}],"version-history":[{"count":10,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11341\/revisions"}],"predecessor-version":[{"id":11391,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11341\/revisions\/11391"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/media\/11388"}],"wp:attachment":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/media?parent=11341"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/categories?post=11341"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/tags?post=11341"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}