Who does what under PPWR?

The EU’s Packaging and Packaging Waste Regulation (PPWR) is one of the biggest changes to packaging legislation in decades. Yet for many businesses, one of the most confusing aspects isn’t the technical requirements—it’s understanding who is responsible for what.

Terms such as supplier, manufacturer, producer, distributor and importer are often used interchangeably in everyday business. Under PPWR, however, each has a specific legal meaning, and each carries different responsibilities.

Getting these roles right is the first step towards compliance.

Why roles matter

Many companies assume they are the “manufacturer” because they make or convert packaging. Others believe they are automatically the “producer” because they sell products in Europe.

PPWR doesn’t work that way.

In many cases, a company can be a supplier in one transaction, a manufacturer in another, and a producer only in certain countries. Understanding where your business sits in the supply chain determines which legal obligations apply.

The five key PPWR roles

Supplier

The supplier provides packaging or packaging materials to the manufacturer.

Its main responsibility is to provide the information and documentation the manufacturer needs to demonstrate compliance. This may include material specifications, recycled-content information, test data or food-contact documentation where relevant.

A simple way to remember this role is:

Who supplied the packaging or packaging material?

Manufacturer

Under PPWR, the manufacturer is legally responsible for the packaging itself.

This role includes carrying out the conformity assessment, preparing technical documentation, ensuring sustainability and labelling requirements are met, and issuing the declaration of conformity.

The manufacturer is not always the company that physically produces the packaging material.

For sales packaging, for example, the manufacturer is often the brand owner or company that fills the packaging rather than the film producer.

Ask yourself:

Who is legally responsible for the packaging?

Distributor

A distributor makes packaging or packaged products available on the market but is neither the manufacturer nor the importer.

Distributors have an important checking role. They must verify that manufacturers, producers and importers have fulfilled their obligations and that packaging is correctly labelled before placing products on the market.

Think of the distributor as:

The company that passes the product along the supply chain.

Importer

An importer brings packaging from outside the European Union onto the EU market.

Importers must ensure imported packaging complies with PPWR sustainability and labelling requirements before it is placed on the market.

The question to ask is simple:

Who imports the packaging into the EU?

Producer

The producer is perhaps the most misunderstood role.

Under PPWR, the producer is the manufacturer, importer or distributor that first makes packaging or a packaged product available in a particular EU Member State where it ultimately becomes waste.

This role is responsible for Extended Producer Responsibility (EPR) obligations, including registration, reporting packaging volumes and paying EPR fees where required.

The easiest way to remember it is:

Who carries the EPR responsibility in that country?

One manufacturer, many producers

A useful principle highlighted in the guide is that there is only one manufacturer of a particular package or packaged product on the EU market.

There can, however, be a different producer in each Member State, depending on which business first makes the packaging available in that country.

That distinction explains why a distributor can sometimes become the producer, even though it is not the manufacturer.

Packaging type also makes a difference

PPWR recognises several packaging categories, including:

• Sales packaging
• Grouped packaging
• Transport packaging
• Service packaging

The packaging type helps determine who acts as the manufacturer and, ultimately, who may become the producer.

For example, the manufacturer of transport packaging in its final form may be different from the manufacturer of sales packaging carrying a brand owner’s name.

Real-world examples

The guide illustrates how roles change depending on the supply chain.

A food company filling film packaging with pasta and selling it under its own brand is generally the manufacturer of the sales packaging. The producer is whichever business first places that packaged pasta on the market in a particular Member State.

For grouped packaging, a beverage company creating retail multipacks from shrink film becomes the manufacturer, while a distributor in another Member State may become the producer there.

Transport packaging works differently. A company manufacturing finished pallet hoods is typically the manufacturer because the packaging is already in its final form.

Service packaging can also vary. A plain, unbranded carrier bag may have a different manufacturer than a branded bag produced for a retailer.

Compliance versus EPR

One of the most valuable distinctions made in the guide is between packaging compliance and Extended Producer Responsibility (EPR).

The manufacturer is responsible for ensuring the packaging itself complies with PPWR requirements, including technical documentation and declarations of conformity.

The producer is responsible for EPR registration, reporting packaging quantities and meeting national producer responsibility obligations.

Sometimes the same company fulfils both roles.

Often, they do not.

Understanding that difference can help companies avoid unnecessary compliance mistakes.

A practical starting point

As businesses prepare for PPWR implementation, one of the most useful first steps is simply mapping their own role within each supply chain.

Rather than asking, “Are we the manufacturer?” organisations should consider a series of straightforward questions:

• Who supplied the packaging material?
• Who is legally responsible for the packaging?
• Who first places it on the market in each Member State?
• Who therefore carries the EPR obligation?

Answering those questions provides a much clearer picture of where PPWR responsibilities begin and end.

Source: Adapted fromPPWR (Packaging and Packaging Waste Regulation) Roles Made Simple, published by Trioworld Group (March 2026), summarising roles under Regulation (EU) 2025/40.