Who is a manufacturer under the PPWR?
Under the PPWR, manufacturer and producer are not the same role.
That distinction matters for companies, because different responsibilities attach to each role.
The manufacturer is generally responsible for packaging conformity. The producer, by contrast, carries extended producer responsibility (EPR) duties in the member state where the packaging becomes waste. In many cases one company is both; in cross-border supply chains the roles can diverge.
What does “manufacturer” mean under the PPWR?
According to the current interpretation of the German Central Packaging Registry (Zentrale Stelle Verpackungsregister), a manufacturer is generally the person or company that manufactures packaging or a packaged product itself, or has it designed or manufactured under its own name or brand.
For each packaging item there is exactly one manufacturer EU-wide.
What matters is therefore not simply who supplied the empty packaging.
Brand, contract manufacturing, packaging type and influence on its design can also play a role.
Is the brand owner automatically the manufacturer?
For private-label goods, that question can become decisive.
If a company has a packaged product designed or manufactured under its name or brand, the commissioning company can be the manufacturer. The ZSVR expressly notes that for private labels responsibility may lie with the trading company.
The role should therefore not be judged solely by who physically produces the packaging.
Are manufacturer and producer the same?
No. The PPWR separates the two roles.
Manufacturer: responsibility for design, characteristics and conformity of the packaging.
Producer: responsibility for extended producer responsibility (EPR) in the member state where the packaging becomes waste.
In simple supply chains the same company can hold both roles.
For imports and cross-border supply chains the assignment can look different.
What does the manufacturer role mean for conformity?
The role matters because the manufacturer is responsible for packaging conformity.
That includes the technical documentation and the EU Declaration of Conformity.
How can PakPruvo help?
PakPruvo does not replace a legal assessment of your own role.
Once it is clear which packaging a company is responsible for, the PPWR software then supports structured management of the related packaging and conformity data.
That can include, for example:
- Materials
- Components
- Weights
- Material shares
- Recycled content shares
- Composite structures
- Documents and Declarations of Conformity
Role clarification then becomes a structured process.
Example
Example
A trading company has a product manufactured and packed under its own brand.
The fact that an external producer actually fills the product does not automatically mean that producer is also the manufacturer of the packaging under the PPWR. Especially for contract manufacturing and private labels, the concrete arrangement must be checked.
Am I a manufacturer?
That is exactly why we built the PakPruvo self-check.
Five questions give an initial orientation on whether your company may be a manufacturer under the PPWR.
The check does not replace legal advice.
Afterwards, the relevant packaging can be structured directly in PakPruvo.