If you sell products in the EU, the new Packaging and Packaging Waste Regulation (PPWR) shouldn’t slip by without you noticing it might apply to you. Understanding if and whether you are a PPWR manufacturer vs. producer is the first step in your PPWR compliance journey. Because once you know your role, you know which obligations apply to you. Understanding your role starts with taking a look at your packaging and sales structure.
PPWR manufacturer vs. producer: Who has which responsibilities?
PPWR creates distinct roles with distinct responsibilities:
- Manufacturer: Responsible for physical sustainability (recyclability, PFAS bans, labelling). There is only one manufacturer per packaging unit in the entire EU.
- Producer: Responsible for financing waste management, including EPR fees and registering with national authorities.
- Importer: Responsible for checking the manufacturer has performed a conformity assessment and correctly labelled the packaging, as well as for keeping techical documentation on file. The importer may also have the role of producer with all corresponding obligations. See more information below.
Want an in depth look at the roles and their PPWR responsibilities? Watch Tibor’s Video!
The Golden Rule: What determines if you are a PPWR manufacturer vs. producer?
The role of the manufacturer
Forget who physically molds the plastic or corrugates the cardboard. The PPWR determines who the manufacturer is based on who has their name or trademark on the packaging and/or who controls the design specifications. There is only one EU-wide manufacturer per packaging item.
If the packaging or packaged product carries your name or trademark, you are usually the manufacturer. That is because you are seen as the company that controls the packaging specifications and the final product placed on the market.
For sales packaging and grouped packaging, the manufacturer is normally the company that fills the packaging and places the packaged product on the market. In most cases, this is also the brand owner.
For transport packaging, service packaging, and primary production packaging, the manufacturer is usually the company that physically makes the packaging. But if the packaging carries the user’s name or trademark, the user becomes the manufacturer instead.
For example, if you are a brand owner (say, a cosmetics company) and you order a custom bottle from a supplier, then you are the manufacturer. You are responsible for ensuring the packaging meets all the substantive requirements in articles 5-12 (substances in packaging, recyclability, minimisation, labelling), for issuing the EU Declaration of Conformity and for ensuring the supporting technical documentation is complete (containing the necessary tests and evidence).
As an exception, if a micro-enterprise has packaging or a packaged product made under its own name or trademark and the supplier is in the same Member State, the supplier is considered the manufacturer instead.
The role of the producer
You are the producer if you are the first company to make packaging or packaged product available in the EU Member State where it later becomes waste. The producer is responsible for fulfilling EPR obligations, including registration, reporting, and financing packaging waste recovery. Depending on the supply chain, the producer may be the manufacturer, importer, or distributor. But the packaging type and state play a role in determining responsibilities too.
For sales and grouped packaging, the producer is usually the company that fills the packaging and first places the packaged product on the market in a Member State. If the product is sold directly to end users online, the distance seller is generally the producer.
For transport, service and primary production packaging, the producer is usually the company that first makes the empty packaging available in the Member State where it will become waste. In practice, this is often the manufacturer of the packaging itself.
Take sales packaging, such as bread bags for a bakery. An Italian bakery buys empty bread bags, fills them with bread, and sells the packaged bread in Italy. The bakery is the producer for the bread bags, because it first places the packaged product on the Italian market (which is also where they become waste).
The bakery also buys empty cardboard boxes to transport trays of bread to supermarkets. Those boxes are first supplied in Italy by a packaging wholesaler. The wholesaler is generally the producer for the transport boxes, because in this case the wholesales is the entity that first makes the empty transport packaging available in Italy.
Conclusion
PPWR readiness is urgent with key deadlines for many requirements, such as the Declarations of Conformity, coming up in August 2026. Understanding the differences between the PPWR manufacturer vs. producer is key to determining your companies’ roles and obligations.
We recommend you audit your supply chain and packaging today. Determine which packaging types you place on the market, who truly “decides the design specifications”, and how packaging flows across borders and between entities to customers.
If you are the manufacturer start preparing your Declaration of Conformity technical documentation. If you are the producer, check your EPR status across all relevant EU markets and start preparing any outstanding registrations where you are not yet compliant.
How ecosistant can support you
Whether you are a producer or a manufacturer, ecosistant helps you prepare for PPWR efficiently.
For producers, we manage your EPR compliance across EU markets: our EPR service supports you from registration to reporting and with ongoing obligations.
For manufacturers, our PPWR Readiness Service identifies compliance gaps, clarifies responsibilities and provides a clear roadmap to compliance. Additionally, we offer dedicated support for supplier outreach (to gather the necessary tests and data), as well as drafting of Declarations of Conformity and technical documentation. This service is ideal for you if your packaging is already PPWR compliant and you need help with your documentation.
Not sure which role applies to you? We’ll help you determine this and guide you toward the right compliance approach.
Contact us for individual support
About the author
Matija Kajić, PhD in law, is specialized in circular economy legislation, including extended producer responsibility. At ecosistant, she supports brands and online retailers across Europe in translating complex PPWR requirements into clear, practical compliance steps. She is the founder of her own company, KayHive, helping organizations across Europe anticipate change and make informed decisions.
Q&A: PPWR manufacturer vs. producer
What is the difference between a PPWR manufacturer vs. producer?
The difference between the PPWR manufacturer vs. producer are the definitions and responsibilities of each.
Producers are generally companies who make packaging available for the first time in the EU country where it becomes waste.
Manufacturers are often the companies whose name or trademark appears on the packaging and/or who controls the design specifications.
The manufacturer is responsible for packaging conformity, while the producer is responsible for EPR obligations such as registration, reporting and financing waste management.
Who is the PPWR manufacturer?
The PPWR manufacturer is usually the company that places packaging on the market under its own name or trademark, or the company that controls the design specifications. In many cases, this is the brand owner or filler of the packaging.
Who is the PPWR producer?
The PPWR producer is the company that first makes packaging or packaged products available in the relevant EU Member State where the packaging becomes waste. This can be the manufacturer, importer, distributor or distance seller, depending on the supply chain.
Can one company be both PPWR the manufacturer and the producer?
Yes. In many cases, one company will act as both the PPWR manufacturer and producer. This is especially common when a brand owner fills and sells its own packaged products under its own name.
Does packaging type matter for determining PPWR manufacturer vs. producer?
Yes, packaging type matters. Sales packaging and transport packaging can lead to different role outcomes, depending on who fills the packaging, if it is empty, and who places the packaging on national European markets.
Why does the PPWR manufacturer vs. producer distinction matter?
Because the two roles trigger different legal obligations. If you identify your role correctly, you can focus on the right compliance tasks.
What if I am not sure whether I am a PPWR manufacturer vs. producer?
If your supply chain is complex, it is best to review the packaging type, branding, design control, and the first market placement in each of the Member States relevant for you. A compliance review can help you determine the correct role. Contact us if you need help determining your role or fulfilling your obligations.
Share article:
Other interesting articles for you:
EU packaging regulation 2025/40 PPWR: what does it mean for e-commerce?
The first provisions of the EU Packaging Regulation (PPWR) started applying from August 12, 2026. These include the obligation to use compliant packaging, follow rules on producer responsibility and appoint Authorized Representatives. We have summarized the most important points for online retailers here.
How to Get an EPR Registration Number for Amazon & Co.
Amazon and other marketplaces are required by law to check the EPR registration number of their sellers in some European countries. Further EU member states will follow. Find out all you need to know on your EPR obligations.
