Understanding PPWR roles: manufacturer, producer, importer, supplier and distributor – who is responsible for what?

The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) assigns specific obligations to every actor along the packaging supply chain - and these obligations determine whether a company must issue the Declaration of Conformity, merely verify it, or register for Extended Producer Responsibility (EPR). In practice, the five main roles - Manufacturer, Importer, Distributor, Supplier and the overarching term "Producer" - cause considerable confusion, particularly because the German and English versions of the Regulation use terms that appear to be swapped.

This article explains which roles the PPWR defines, how Manufacturer and Producer can be clearly distinguished from one another, when an Importer or Distributor becomes a Manufacturer under Article 21, and how the PPWR roles fit into the existing German packaging law framework around the ZSVR and the LUCID register.

What is an economic operator under the PPWR?

Article 3 of the PPWR defines the "economic operator" very broadly: It covers any company that manufactures, supplies, imports, distributes, or otherwise makes packaging or packaged products available at any point along the supply chain, including through fulfilment services. Any company that comes into commercial contact with packaging in any form falls within its scope.

The PPWR assigns obligations not by industry sector or company size, but by the actual role a company plays in relation to a specific packaging in a specific member state. This has two key consequences: a company can simultaneously hold multiple roles (e.g. Manufacturer and Importer), and the same company may hold different roles for different products or member states.

Role determination must therefore be carried out on a granular basis per packaging and per member state - the blanket company-level classification commonly practised under the previous VerpackG is no longer permissible under the PPWR.

Two role categories: operational supply chain roles and responsibility roles

The PPWR distinguishes between two fundamentally different role dimensions that are frequently conflated in day-to-day operations:

Operational supply chain roles describe what a company physically and commercially does with the packaging: manufacture, supply, import, distribute. These roles determine who carries out the conformity assessment, who creates the technical documentation, who signs the DoC, who verifies it, or who merely complies with labelling obligations.

Responsibility roles describe who bears the legal and financial responsibility for the disposal, collection and recovery of the packaging - in other words: who registers for EPR, who pays fees and who reports the volumes placed on the market. These roles are defined geographically, i.e. per member state.

The critical point: operational roles follow the packaging; responsibility roles follow the member state. A company can be a Producer (EPR) in Germany but not in France - even though it is the same Manufacturer of the same packaging for both countries.

The operational supply chain roles in detail

Supplier (Article 16)

The Supplier makes packaging or packaging materials available to other economic operators without acting as a brand owner. A classic example is a manufacturer of cartons or plastic films who supplies its products to industrial companies that subsequently use them under their own brand.

Under Article 16, Suppliers are obliged to provide their customers with all information and documentation they need for their own conformity assessment. This includes in particular information on material composition, recycled content, substances used and recyclability. The Supplier does not issue a DoC itself - but it is the Manufacturer's primary source of information.

Manufacturer (Article 15)

The Manufacturer is the company that makes or has made the packaging under its own name or brand. What matters is not who physically produces the packaging, but whose name or brand appears on it. An industrial company that has a cardboard supplier print transport packaging bearing its own logo thereby becomes the Manufacturer - the carton producer remains the Supplier.

The Manufacturer bears the most extensive obligations under the PPWR:

• Carrying out the conformity assessment under Module A (Annex VII, internal production control)
• Creating the complete technical documentation
• Issuing and signing the EU Declaration of Conformity under Annex VIII
• Labelling the packaging with a batch or serial number (Article 15(5)) and the name and contact address (Article 15(6))
• Retaining documents for five years (single-use) or ten years (reusable)
• Taking immediate corrective action when non-conformity is identified

Importer (Article 18)

The Importer is any economic operator established in the EU who places packaging or packaged products from a third country on the EU market for the first time. Importers do not issue their own DoC, but they have substantial verification and monitoring obligations.

Before placing on the market, the Importer must ensure that the (non-EU) Manufacturer has carried out the conformity assessment, created the technical documentation and issued the DoC. The Importer retains a copy of the DoC, makes it available electronically to market surveillance authorities within ten days upon request (Article 18(8)), and must additionally affix its own contact details on the packaging or in accompanying documents.

Distributor (Article 19)

The Distributor makes packaging or packaged products available on the market without itself being a Manufacturer or Importer. Its obligations are significantly reduced, but not trivial: before placing on the market, it verifies whether the Manufacturer and Importer have fulfilled their identification, contact and labelling obligations, whether the Producer in the EPR sense is registered in the relevant national register, and whether the packaging meets the requirements of Articles 5 to 12.

Distributors are not required to retain the DoC, but may not make available any packaging where they have reason to believe it is non-compliant. Where they identify risks, they are obliged to notify the Manufacturer, the Importer and the market surveillance authorities.

Fulfilment service provider (Article 20)

Fulfilment service providers - companies that provide warehousing, packaging, addressing or shipping services without owning the goods - were only added as a distinct role during the legislative process. They may only offer their services if the Manufacturer or Importer has fulfilled its obligations under Articles 15 and 18 respectively. This role targets in particular e-commerce fulfilment structures.

The responsibility roles: Producer and Authorised Representative

Producer under the PPWR - in the German version: Hersteller

The Producer under Article 3 is the actor who places a packaging or a packaged product on the market for the first time in a specific member state. Producer status is therefore defined geographically and not in terms of production. The Producer bears the EPR responsibility: it registers in the national producer register, reports the volumes placed on the market, pays licensing fees to a dual system or a Producer Responsibility Organisation (PRO), and thereby bears the financial responsibility for collection and recovery.

There is always only one Producer per packaging per member state. Depending on the situation, this may be the Manufacturer (typical case: a German industrial customer that produces and places on the market in Germany), an Importer (when the packaging arrives from a third country for the first time in an EU member state), a Distributor (when it sells directly to end consumers in another EU member state), or a final retailer (last commercial link before the end consumer, e.g. in e-commerce).

Authorised representative (Article 17)

An Authorised representative is an economic operator established in the EU that a Producer without a physical establishment in a member state has mandated in writing to fulfil its EPR obligations there. For non-EU Producers selling directly to end consumers in EU member states, appointing an authorised representative for each member state in which they are a Producer is mandatory. In Germany, the authorised representative takes over registration in the LUCID register of the ZSVR and reporting of the volumes placed on the market.

The key distinction: Manufacturer (Erzeuger) vs. Producer (Hersteller)

The German and English versions of the PPWR use terms that appear to be swapped at first glance - and in practice generate exactly that confusion:

This terminological crossover is the single most important pitfall in the entire role analysis. In general German usage, "Erzeuger" and "Hersteller" are used synonymously; under the PPWR they have distinct legal meanings. Those who conflate the terms also conflate the obligations:

• The Manufacturer (Erzeuger) bears the product-related conformity obligations: conformity assessment, technical documentation, DoC, labelling.
• The Producer (Hersteller) bears the market-access-related EPR obligations: registration, volume reporting, licensing fees.

A German mechanical engineering company that has transport packaging with its own logo produced by a carton supplier in Italy and ships machinery to Germany and France is in this example:

• Manufacturer (Article 15) of the packaging - with full responsibility for the DoC and technical documentation,
• Producer in Germany (first placing on the market in the German market) - with LUCID registration at the ZSVR,
• depending on the delivery route, also Producer in France, or alternatively one of its French customers.

There is always exactly one Manufacturer per packaging. There may, however, be multiple Producers - namely one per member state in which the packaging is placed on the market for the first time.

Article 21: When do Importers or Distributors become Manufacturers?

Article 21 of the PPWR contains the so-called reclassification or "deemed manufacturer" rule. It applies in two situations:

1. An Importer or Distributor places packaging on the market under its own name or brand.
2. An Importer or Distributor modifies packaging already on the market in a way that may affect conformity with Articles 5 to 12.

In both cases, the full Manufacturer obligations of Article 15 apply. The company must itself carry out the conformity assessment, create the technical documentation under Annex VII and sign the DoC under Annex VIII - regardless of who physically produced the packaging.

Typical constellations in practice:

• Private-label approaches: A trade or industrial company has products manufactured by a third-party supplier and places them on the market under its own brand. The company is a Manufacturer under Article 21, even though the packaging was physically produced externally.
• Retail repackaging: A Distributor purchases products and repackages them in its own packaging or supplements them with its own accompanying materials. As soon as the original conformity is affected, it is deemed to be a Manufacturer.
• OEM and ODM constellations: Industrial companies that place components on the market under their own brand, where those components were manufactured by an OEM partner, are Manufacturers of the packaging.

The European Commission clarified in its guidance of 30 March 2026 that the Manufacturer does not necessarily have to be the packaging converter: in many cases, particularly for consumer and grouped packaging, this role falls to the filler or brand owner who has control over the design and specification of the packaging.

Role determination in practice: a decision aid

Because roles are assigned per packaging and per member state, role analysis is a process, not a one-time act. The following guiding questions assist with the assignment:

Overview of obligations: who does what?

The German legal context: PPWR, VerpackG, ZSVR and LUCID

The PPWR results in a reorganisation of German packaging regulation without entirely replacing the existing framework. The Packaging Act (VerpackG) remains in place in its EPR-related parts: the Stiftung Zentrale Stelle Verpackungsregister (ZSVR) continues to operate the LUCID register in which Producers under the PPWR register and report their volumes. Licensing through a dual system (e.g. Der Grüne Punkt, Interseroh, Reclay, Zentek, Landbell, Noventiz) also remains in place.

New, however, is the second, independent layer of product-related conformity: conformity assessment, technical documentation and DoC per packaging type - precisely the obligations that fall primarily on the Manufacturer. This second layer was not part of the VerpackG and supplements the existing EPR obligations.

The ZSVR has made publicly available a decision tree for determining Producer status under the PPWR to support role clarification, explicitly distinguishing between PPWR roles and the former manufacturer concepts of the VerpackG. The implementing provisions at federal level are governed by the Packaging Implementation Act (VerpackDG); the responsible authorities for national implementation are the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) and the Federal Environment Agency (UBA).

In practice, this means for companies: the LUCID registration they currently hold as "Hersteller" under the VerpackG covers only the EPR dimension. The PPWR conformity obligations - DoC, technical documentation, conformity assessment - arise additionally from 12 August 2026 and must be structured separately.

What does this mean for companies with complex supply chains?

Companies with EU-wide distribution or multi-tier production and trading structures face three core operational questions:

First: role analysis per product and per member state. The traditional company-level role assignment ("we are an industrial operator placing packaging on the market") is too coarse under the PPWR. What is needed is a matrix of SKU, packaging variant and target market that identifies the PPWR role(s) for each combination.

Second: data structure per role. As a Manufacturer, bill-of-materials, material and conformity data are needed; as an Importer, verification evidence and supplier DoCs; as a Producer (EPR), volume data per member state. These data streams feed different processes, but draw on the same packaging master data as their foundation.

Third: authorised representative structures for non-EU constellations. Industrial companies with global supply chains or EU-wide direct sales must check per member state whether they are a Producer there, and if so appoint an authorised representative. With several dozen country combinations, this process is far from trivial and often requires several months of lead time.

The PPWR shifts the understanding of packaging compliance from a one-off registration task to a continuous, data-driven process at product level. Companies that clearly define their roles per SKU and per member state, and structure their packaging master data accordingly, create the foundation for all further requirements up to 2040 - from the DoC to recycled content quotas to EPR modulation.