PPWR manufacturer vs producer: obligations, definitions and practical cases at a glance
The countdown is on: By 12 August 2026, companies must adapt their packaging to the requirements of the PPWR.
A key aspect is the clear distinction between producer and manufacturer under the PPWR. Companies should assess early on which role they take within the supply chain and what obligations arise from it.
Manufacturer vs producer in the PPWR: what does this mean in practice?
For the first time, the PPWR clearly distinguishes between two separate economic operators:
manufacturer
producer
Both roles are associated with clearly defined responsibilities.
The manufacturer under the PPWR (Art. 3(1) No. 13)
A manufacturer within the meaning of the PPWR is a company that:
- has its name or trademark on the packaging, or
- has packaging or packaged products developed or manufactured under its own name or brand (e.g. private labels).
Who is the manufacturer? – Two key practical cases
The classification depends on whether contract manufacturing exists and when a packaging reaches its final form.
Case 1 – Contract manufacturing
If a company commissions a contract packer to develop or manufacture packaging or packaged products under its own brand:
👉 The commissioning company is the manufacturer.
Key criteria
- Brand ownership is not decisive
- Group companies or licensees may also be manufacturers
- The decisive factor is the link between brand and packaging design
- The indication of the contract packer does not change responsibility
Exception for micro-enterprises
For companies with:
- fewer than 10 employees
- a maximum of €2 million turnover or balance sheet total
the following applies:
- supplier in the same EU Member State → supplier is the manufacturer
- sourcing from another EU country → the company itself becomes the manufacturer
Principle: The decisive factor is who can assess the conformity of the packaging.
Case 2 – No contract manufacturing
Here, the determining factor is when a packaging reaches its final form.
Obligations of the manufacturer under the PPWR
Manufacturer are responsible for the conformity of the packaging:
- conformity assessment procedure (Art. 38 PPWR)
- technical documentation
- EU declaration of conformity
- compliance with Articles 5–12 PPWR
- marking (manufacturer + identification)
Conclusion:
The manufacturer bears primary responsibility for technical compliance.
The producer under the PPWR (Art. 3(1) No. 15)
The producer within the meaning of the PPWR is the company that:
- opens the supply chain in the Member State where the packaging later becomes waste.
For sales and grouped packaging, this is usually the company that first places the product on the market in the respective country.
Producer role is country-specific
- Must be assessed separately for each EU Member State
- Objective: one producer per packaging unit
👉 A company may take on different roles in different countries.
Basic principle – country-of-first-placement priority
The decisive factor is: Who starts the supply chain in the country where the packaging becomes waste.
Example Germany:
- First placement in Germany → producer within the meaning of the PPWR
Important:
- Producer is not automatically the producer
- The decisive factor is the first placement
If country-of-first-placement does not apply
Importer
Import of packaging or products from a third country
Important: Within the EU, this is not considered an import
Distributor
- Making packaging or products available in Germany from another EU Member State
👉 In case of re-import, the last national supply chain is decisive
When is a company both manufacturer and producer?
If:
- the manufacturer is located in the same Member State where the packaging becomes waste
👉 In this case, it automatically assumes both roles.
Obligations of the producer
- registration in the LUCID packaging register
- system participation (e.g. dual system)
- reporting of packaging volumes
PPWR 2026 – shift in producer responsibility
The PPWR significantly shifts extended producer responsibility (EPR).
👉 The obligation for system participation will increasingly lie with the retail sector.
Private labels – new role for retail
Retail companies with private labels will in future be:
- manufacturer
- and producers
This means in practice
- system participation obligation lies with retail
- no transfer to suppliers possible
- obligation applies before placing on the market
Imports without intermediaries
Companies importing directly:
- are considered producer
- are subject to system participation obligations
Practical tips for preparing for the PPWR
- review roles along the supply chain
- clearly define responsibilities
- prepare data and processes in good time
Frequently asked questions on the PPWR (FAQ)
What changes for private labels?
Companies with private labels are both producer and manufacturer.
A transfer of system participation obligations to suppliers is not possible.
Practical case – private label with contract packer
The retail company:
- is the manufacturer
- is the producer
👉 Bears full responsibility
Can the manufacturer role change?
Yes. Importers or distributors can become manufacturer if they:
- ” data-aria-posinset=“1” data-aria-level=“1”>distribute under their own brand or
- ” data-aria-posinset=“2” data-aria-level=“1”>modify packaging
(exception: micro-enterprises)
Take action now: your PPWR implementation with Noventiz
The requirements of the PPWR require clear decisions and structured implementation – especially regarding roles, data and compliance.
With our solutions, you gain clarity quickly and implement requirements efficiently.
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Ensure your packaging meets PPWR requirements
The recyclability of packaging plays a central role in the PPWR regulation. This requires recyclable packaging with an increasing proportion of recyclate from 2030. Companies should therefore optimise their packaging design now in order to meet legal requirements and strengthen the circular economy.
Further information:
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