PPWR: Manufacturer or Producer? Clarify Your Role

The PPWR has generally applied since 12 August 2026. Almost three months later, many supply chains have still not agreed who handles which responsibilities. A VdL statement published on 6 November describes varying levels of preparation among suppliers and customers. Businesses need to distinguish packaging conformity from extended producer responsibility. Other requirements take effect only after their respective transition periods.

PPWR manufacturer and producer: two different roles

The manufacturer, called “Erzeuger” in German, is responsible for conformity. Under Article 15 of Regulation (EU) 2025/40, this includes conformity assessment, technical documentation and the EU declaration of conformity. Records must be available to the competent authorities. They must generally be retained for five years for single-use packaging and ten years for reusable packaging, counted from placement on the market.

The producer for EPR purposes, called “Hersteller” in German, carries the relevant waste-management obligations. Article 3(1), point 15, determines who qualifies. Relevant factors include packaging type, establishment, first supply in the member state and sales channel. Looking only at the country of the final consumer is therefore insufficient. One business can hold both roles, but this is not automatic.

Private labels and suppliers need individual assessment

A business having packaging designed or manufactured under its own name or trademark may itself be the manufacturer. Changes made by importers or distributors can also trigger manufacturer obligations under Article 21. Special provisions for micro-enterprises require a separate check. Neither “always the filler” nor “always the packaging supplier” is a reliable universal rule.

The VdL highlights private labels, stretch film and shipping labels as areas of interpretation. The Commission’s FAQ dated 3 August 2026 help explain the framework but are not legally binding. Unresolved practical questions do not suspend applicable duties.

Which documents must suppliers provide?

Article 16 requires suppliers to provide the manufacturer with the information and documentation needed to demonstrate conformity. That differs from a blanket duty to issue each customer’s declaration of conformity. The joint customer information from VCI and specialist associations explains this distinction. Any additional contractual information commitments should be described clearly.

PPWR: What businesses should clarify now

• Map roles for each packaging format: identify manufacturer, EPR producer, importer and distributor.
• Allocate documentation tasks: establish who draws up the declaration and holds technical evidence.
• Agree information flows: specify the material data and supporting records each party provides.
• Check countries separately: assess registration, reporting and any applicable scheme participation.

Contracts help organise processes and responsibilities. However, they cannot freely transfer statutory roles as against authorities. EPR representation and product-conformity tasks also need separate consideration; the same representative arrangement should not simply be assumed to cover both.

ECOPV-EU supports businesses with EPR registration, compliance scheme participation and authorised representation in Germany and the EU. This article provides general information and does not constitute legal advice.

Sources: VdL, 6 November 2026; PPWR, particularly Articles 3, 15, 16, 21 and 44; Commission FAQ, 3 August 2026; VCI, 16 October 2026. Checked on 10 November 2026.

AI-generated concept illustration of PPWR roles; not official documents or certification.