PPWR Roles & Obligations: Manufacturer, Producer, Importer, Distributor
The EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) assigns different obligations depending on your position in the supply chain. Before you do anything else, you need to determine which role(s) your company occupies — because this determines the evidence you are legally required to provide. Particularly tricky: in everyday German usage the terms "Erzeuger" and "Hersteller" seem synonymous, but in the Regulation they mean different things. This article explains the four roles, their concrete obligations, and the notorious Article 21 trap.
The four roles at a glance
Most companies combine several of these roles. Each carries its own documentation duties – so check for every packaging type individually which ones apply.
Manufacturer
You manufacture the packaging or have it manufactured under your name or brand. As the manufacturer, you carry the main burden of PPWR documentation: you carry out the conformity assessment and issue the legally binding documents.
- Carry out a conformity assessment for each packaging type.
- Prepare and maintain technical documentation in accordance with Annex VII.
- Draw up and sign a Declaration of Conformity (DoC) with all 9 mandatory elements.
Importer
You place packaging from a third country on the EU market. You do not produce the documentation yourself, but you must ensure that the manufacturer has produced it properly and keep copies available for the authorities.
- Obtain the manufacturer's Declaration of Conformity (DoC) and check it for completeness.
- Retain copies of the DoC for 5 to 10 years.
- Respond to authority requests within 10 days.
Distributor
You make packaging available on the EU market without being a manufacturer or importer. You do not produce documentation, but you must not pass on non-compliant packaging and must verify that upstream obligations have been met.
- Verify that labelling, the DoC and manufacturer/importer details are in place before you pass it on.
- Do not sell or make available non-compliant packaging.
- Ensure traceability back to your manufacturer or importer.
Producer (subject to EPR)
You place the packaged product on a Member State's national market for the first time. This triggers extended producer responsibility (EPR): registration, volume reporting and financial contributions in every affected Member State.
- Register in every Member State where you first place packaged products on the market.
- Report packaging volumes by material category and market.
- Make financial contributions to the national Producer Responsibility Organisation (PRO).
The PPWR evidence pyramid
Packaging compliance is built from the bottom up: without solid supply-chain data at the base, no declaration of conformity holds at the top. Each layer rests on the one below it.
Market surveillance and end customers must be able to verify conformity – on request within 10 days.
The signed document per packaging type that legally declares conformity.
The evidence file that backs every statement in the declaration of conformity with data and test reports.
The four conformity pillars
Complete material list – every coating, printing ink and adhesive. A supplier's self-declaration alone does not count as sufficient evidence.
Why your role decides everything
The PPWR applies to economic operators — all natural or legal persons who place packaging or packaged products on the EU market. The evidence you must provide does not depend on how large your company is or which industry you operate in, but rather on which role you occupy in the supply chain. Most companies occupy more than one role — each one brings additional obligations.
Our interactive PPWR role check guides you in six questions to your likely role, complete with a personalised list of obligations.
The two terms that are constantly confused
In German the distinction is especially delicate:
- Erzeuger (English manufacturer) refers to the packaging itself — whoever produces it or has it produced under their own name.
- Hersteller (English producer) refers to the packaged product — whoever first places it on the market of a Member State, thereby triggering extended producer responsibility (EPR).
A company can be both at the same time. Keep the original English terms in mind whenever the German words cause confusion.
The four roles in detail
1. Manufacturer
Produces packaging or has it produced under their own name or brand. The manufacturer bears the main burden of PPWR evidence:
- Carry out a conformity assessment for each packaging type
- Draw up and maintain technical documentation in accordance with Annex VII
- Prepare and sign a Declaration of Conformity (DoC) in accordance with Annex VIII, including all 9 mandatory elements
- Comply with and document substance limit values (sum of lead, cadmium, mercury and hexavalent chromium ≤ 100 mg/kg; for food contact, additional PFAS testing)
- Justify packaging minimisation (Art. 9)
- Retain documentation for 5 years (single-use) or 10 years (reusable) and make it available to authorities within 10 days
2. Importer
Places packaging from a third country (non-EU) on the EU market. The importer does not draw up the documentation themselves but is legally responsible for ensuring it exists and is correct:
- Obtain the manufacturer's Declaration of Conformity (DoC) and technical documentation and check them for completeness
- Retain copies of the DoC for 5 to 10 years
- Respond to authority requests within 10 days
- Do not place non-compliant packaging on the EU market
Important: a blanket supplier declaration ("our materials are compliant") is not sufficient. Importers cannot simply rely on supplier documentation passed down the chain.
3. Distributor
Makes packaging available on the EU market without being a manufacturer or importer — typically wholesale and retail. The distributor has no obligation to create documentation, but does have a verification duty:
- Verify that the upstream obligations have been met (labelling, DoC, manufacturer/importer details) before packaging is made available
- Do not sell or pass on non-compliant packaging
- Organise storage and transport in a way that does not compromise conformity
4. Producer — subject to EPR
First places the packaged product on the national market of a Member State. This triggers extended producer responsibility (EPR):
- Registration in every Member State in which products are placed on the market for the first time — there is no EU-wide registration
- Report packaging volumes by material category and market
- Make financial contributions to the national producer responsibility organisation (PRO)
- In Member States without a physical presence, appoint an authorised representative where applicable
The Article 21 trap
This is the most frequently overlooked mechanism in the Regulation. If your name or brand appears on the packaging — or if you modify packaging before placing it on the market — Article 21 classifies you as a manufacturer. And this applies regardless of who physically produced the packaging.
This means: you must issue the Declaration of Conformity yourself, hold the technical documentation, and bear full manufacturer responsibility, even if you never produced anything yourself. So examine every packaging type in your portfolio: does it carry your brand name or trademark? If so, you bear manufacturer obligations for it.
Third-country sellers: the e-commerce special case
If, as a company based outside the EU, you sell your own products directly to EU customers (for example via an online shop), you are functionally treated as an importer — with one additional obligation: in the Member State in which you first place products on the market, you must appoint an authorised representative established in the EU to assume your obligations.
Multiple roles are the norm
Hardly any company fits neatly into a single box. A typical example: a brand owner who imports finished products from China is an importer and — if they place products on the market for the first time in several Member States — a producer in each one. If their brand appears on the packaging, they are additionally a manufacturer under Article 21. Three roles, three sets of obligations.
PPWR-EPR and the German VerpackG — do not confuse them
The PPWR's EPR registration and the German LUCID registration with the packaging register (Zentrale Stelle Verpackungsregister) stem from two different legal frameworks. The national Packaging Act (VerpackG) with its LUCID requirement continues to exist in parallel with the PPWR. Anyone placing packaging on the market for the first time in Germany must still register with LUCID — in addition to the new PPWR obligations, not instead of them.
What you should do now
- Determine your role — using the PPWR role check or the definitions above.
- Check every packaging type against the Article 21 trap — is your brand on it?
- List the evidence obligations for each role and compare them with what you can document today.
- Organise your documentation centrally and audit-ready — when an authority comes asking, you have only 10 days.
Who provides which evidence
This overview shows, for each core duty, what the regulation requires and who in the supply chain is responsible for it.
| Duty | What is required | Who is responsible |
|---|
Frequently Asked Questions
- What is the difference between manufacturer and producer under the PPWR?
- The manufacturer (German Erzeuger) produces the packaging or has it produced under their own name and is responsible for the conformity assessment, technical documentation and Declaration of Conformity. The producer (German Hersteller) first places the packaged product on a national market, thereby triggering extended producer responsibility (EPR) with registration and financial contributions. A company can be both at the same time.
- I buy in packaging and my logo is on it — am I a manufacturer?
- Yes. Under Article 21 PPWR you are classified as a manufacturer as soon as your name or brand appears on the packaging — regardless of who physically produced it. You must then issue the Declaration of Conformity yourself and hold the technical documentation.
- Do I have to register myself as an importer?
- As an importer you do not draw up the conformity documentation yourself, but you must obtain, check and retain the manufacturer's Declaration of Conformity and technical documentation for 5 to 10 years. If you additionally place the imported product on a national market for the first time, you are simultaneously a producer and therefore subject to EPR registration in every Member State concerned.
- Is a conformity confirmation from my supplier sufficient?
- No. A blanket supplier declaration does not cover your PPWR obligations. The Regulation requires specific, third-party-backed evidence for each material and component — such as analysis certificates from accredited laboratories for substance limit values and a complete Declaration of Conformity with all 9 mandatory elements under Annex VIII.
- In how many countries do I have to register for EPR?
- EPR registration is required in every Member State in which you place packaged products on the market for the first time. There is no EU-wide registration — if you sell in five countries, you need five separate registrations, each with its own national requirements.
- Does PPWR-EPR replace the German LUCID registration?
- No. The German Packaging Act (VerpackG) with its LUCID requirement at the packaging register continues to exist in parallel with the PPWR. Anyone placing packaging on the market for the first time in Germany must still register with LUCID — in addition to the PPWR obligations, not instead of them.
Unsure which role applies to you?
The free role check places your position in six questions and names your specific obligations.
Go to the PPWR role check