The European Union of Packaging Registers (EUNR) has published its first guideline on the interpretation of the PPWR. The focus is on the question of which economic operator assumes the obligations of extended producer responsibility (EPR).
The guideline provides greater clarity in determining the responsible producer.
Official EUNR infographic for reference: EUNR PPWR Publication
The decisive factor here is who acts as the first entity in the national supply chain within a Member State.
The EUNR distinguishes between the different types of packaging:
- Sales and outer packaging: For the purpose of determining the responsible producer, the relevant supply chain begins with filling.
- Transport, service, and primary production packaging in their final form (typically rigid packaging): The supply chain begins with the empty packaging.
- Transport, service, and primary production packaging that only take their final form upon filling (typically flexible packaging): The supply chain begins only upon filling.
The guideline also explains the responsibilities in cross-border supply chains:
Domestic manufacturers: If the manufacturer of the empty packaging or the packaged product is based in the respective EU member state, it is automatically considered the responsible producer, as it is the first link in the national supply chain.
Foreign manufacturers (B2B trade): If the manufacturer is located abroad, responsibility passes to the first domestic economic operator (e.g., the importer or wholesaler) who places the goods on the market in the respective Member State
Direct Sales Abroad (B2C/B2B Direct): If a foreign company delivers packaging or packaged goods directly to private or commercial end-users in the destination country, the foreign company remains the producer and must comply with EPR requirements there.
With the application of the EPR requirements set to begin on August 12, 2026, it is advisable to review existing supply chains and roles as soon as possible.
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