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. It is even possible for a single economic operator to be assigned both of these roles. 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.
Producer
The producer (German „Erzeuger", Art. 3(13)(a+b)) is any natural or legal person who manufactures packaging or packaged products under their own name or brand, or has them manufactured. Example: if you buy carton, tape and filler separately and turn them into the finished packaging by filling and sealing it, you are the producer.
- Register your company.
- Report volumes for packaging subject to scheme participation, if applicable (when the manufacturer role is also assumed).
Manufacturer
The manufacturer is the natural or legal person who manufactures packaging or a packaged product and is responsible for its technical conformity. They ensure that the required technical evidence and test documents are available and correct — these form the basis for the subsequent declaration of conformity (DoC) by the producer. This role triggers extended producer responsibility (EPR): you finance the collection, sorting and recovery of the packaging you place on the market.
- Extended producer responsibility (EPR): finance collection, sorting and recovery of your packaging.
- Responsible for the technical design and construction of the packaging.
- Provide and verify technical evidence and test documents.
- Establish the basis for the producer's declaration of conformity (DoC).
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. Important: if you are the first to place the packaging on the market in your country, you may additionally be assigned the manufacturer role.
- 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.
Supplier
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.
Authorised representative
The authorised representative is a person or body appointed by the company to carry out certain PPWR duties on behalf of the obligated party — especially in cross-border situations, e.g. for companies without an EU establishment.
- Carries out designated PPWR duties on behalf of the obligated party.
- Especially relevant in cross-border cases and for companies without an EU establishment.
When is the producer also the manufacturer?
Under the PPWR: if the producer is located in the EU member state where the packaging becomes waste, they are also the manufacturer – because there is no other company earlier in the supply chain.
This also explains why, in the dual role with the manufacturer, the producer additionally bears the EPR obligation.
ZSVR: producer/manufacturer distinctionThe producer² is the manufacturer, because there is no one earlier in the supply chain.
- –for transport, service and primary production packaging: producer of the complete empty packaging in its final form
- –for sales and grouped packaging: producer² of the packaged product
Note: in the case of a re-import, the last national supply chain applies.
¹ „Domestic importer" refers to the party that first makes packaging or packaged products available in the territory of this member state.
² or the „importer" (as defined in the PPWR) if the manufacturer is established outside the EU.
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.
The two terms that are constantly confused
In German the distinction is especially delicate:
- Erzeuger is whoever manufactures packaging or packaged products under their own name or brand, or has them manufactured.
- Hersteller is the party technically responsible for the design and properties of the packaging: design, construction, material selection and compliance with the limit values (PFAS, REACH, heavy metals). This role triggers extended producer responsibility (EPR).
A company can be both at the same time.
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 producer. 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 producer 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 producer obligations for it.
Important — who does this affect? Article 21 mainly matters for the distributor and manufacturer roles: if your brand appears there, you are additionally upgraded to a producer. Anyone who is already a producer carries these obligations anyway — for them, Article 21 changes nothing and can be ignored.
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 — because their brand appears on the packaging and they place it on the market for the first time in several Member States — also a producer.
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 definitions above.
- List the evidence obligations for each role and compare them with what you can document today — easiest in our packaging database, which manages every packaging together with all its PPWR evidence centrally and audit-ready.
- 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 |
|---|---|---|
| Heavy metals | Sum of lead, cadmium, mercury and hexavalent chromium below 100 mg/kg, evidenced by a certificate of analysis from an accredited laboratory. | Manufacturer |
| PFAS (for food contact) | No more than 25 ppb per individual substance and 250 ppb in total, proven by a specific test report. Blanket "PFAS-free" claims are not enough. | Manufacturer (in production), producer (when commissioning) |
| Recyclability | Assessment under the Design-for-Recycling methodology with sorting and recovery data (with minimum grades from 2030). | Manufacturer (individual components), producer (whole packaging) |
| Recycled content | Audited mass-balance or chain-of-custody evidence from the recycler on the post-consumer share. | Manufacturer |
| Packaging minimisation | Written justification of why weight and volume cannot be reduced further without compromising protection, hygiene and logistics. | Producer |
| Declaration of Conformity (DoC) | One signed document per packaging type with all nine mandatory items from Annex VIII. | Producer |
| Technical documentation | Structured file per packaging type that backs every entry in the DoC; available within 10 days on request by authorities. | Created by the producer, data from the manufacturer |
| EPR registration | Registration plus volume reporting in every Member State of first placing on the market – with no EU-wide single registration. | Manufacturer, producer, importer, distributor — depending on the route to market |
Frequently Asked Questions
- I buy in packaging and my logo is on it — am I a producer?
- Yes. Under Article 21 PPWR you are classified as a producer 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 producer'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/manufacturer 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.