The brand, EU importer and packaging supplier can all have PPWR responsibilities. The manufacturer is responsible for demonstrating packaging conformity; the importer has its own verification duties; and the supplier must provide supporting information and documentation. For packaging designed or manufactured under a brand’s own name or trademark, that brand will usually be the legal manufacturer—even when a factory in China physically makes the boxes. Separately, the business identified as the producer has packaging waste obligations in the relevant EU country.
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and generally applies from 12 August 2026. Individual requirements have their own application dates. Responsibility therefore means assessing the requirements applicable to the particular packaging and market-placement date, while preparing for later design and labeling rules.
Who does what under the PPWR?
| Role | How it is identified | Main responsibility |
|---|---|---|
| Manufacturer | The business identified under the manufacturing and own-name or trademark rules, subject to specific exceptions. | Ensure conformity with applicable requirements, complete the conformity assessment and technical documentation, issue the EU declaration of conformity, and maintain conformity during production. |
| Packaging supplier | A business supplying packaging or packaging materials to the manufacturer. | Provide the information and documentation the manufacturer needs to demonstrate conformity, under Article 16. |
| Importer | An EU-established person that first places packaging from outside the EU on the Union market, whether empty or containing products. | Verify the manufacturer’s assessment and documentation, check applicable labeling and identification, retain the declaration, and ensure access to the technical documentation. |
| Distributor | A business making packaging available further along the supply chain, other than the manufacturer or importer. | Check relevant producer registration, labeling and identification; preserve conformity during handling; and act on suspected non-compliance. |
| Producer for EPR | The business identified by the packaging category and supply route in a particular Member State. | Fulfill extended producer responsibility obligations, including relevant registration, reporting and financing of packaging waste management. |
One company may hold several roles. Equally, a shipment may contain packaging with different responsible businesses: the branded retail box, the outer transport carton and packaging added during fulfillment each need consideration. Assigning a single role to an entire supplier relationship can miss these differences.
How three China-to-EU supply routes divide the work
1. An EU brand commissions its own packaging in China
An EU jewelry company commissions rigid gift boxes under its own trademark. Its jewelry is packed in China, and the EU company brings the finished products onto the EU market. In this arrangement, the EU company has the manufacturer obligations for its branded packaging and also handles the import responsibilities. The Chinese box factory supplies the packaging and the information supporting its assessment.
The practical consequence is that the brand needs evidence from the factory to support a declaration issued under the brand’s responsibility. At CMIC, we can develop the structure and materials, coordinate information from material suppliers, and arrange appropriate samples and project-specific testing. That work helps the brand assess the packaging it will actually sell, including its insert, printed wrap and closure.
2. An EU business imports another brand’s packaged goods
A French trading company buys finished gift sets from a Chinese skincare brand and first places them on the EU market for resale in France. The skincare brand has commissioned the packaging under its own trademark and remains the PPWR manufacturer. The French company is the importer: it must verify the manufacturer’s conformity work, check the required documents and identification, and ensure that the technical documentation can be supplied to authorities.
The answer changes if the French business develops a gift set under its own private label. It may then become the manufacturer for that packaging. Article 21 also brings manufacturer obligations into play when an importer or distributor modifies packaging already placed on the market in a way that could affect compliance. A business moving from reselling an unchanged product to redesigning its presentation should review its role along with the new specification.
3. A non-EU brand sells directly to EU customers
A non-EU skincare brand commissions its own branded paper packaging in China and sells the packaged products directly to EU consumers through its website. It has no EU subsidiary or reseller, and its courier only handles transport and customs formalities. The brand is the PPWR manufacturer under the own-name or trademark rule. Direct supply to end users also makes it the EPR producer in each destination country for those sales.
In this arrangement, there is no separate PPWR importer. That role requires an EU-established person placing third-country packaging on the Union market through a commercial supply. The consumer receiving the parcel for private use does not perform that activity, and transport or customs services alone do not make the courier the PPWR importer. The non-EU brand retains its manufacturer duties, including the required conformity assessment, technical documentation, declaration and identification. If an EU subsidiary or trading business instead first places the packaged goods on the market, that entity takes on importer duties.
For conformity-related work, Article 17 permits the manufacturer to appoint an EU authorized representative by written mandate, including to keep documents available to authorities. Article 17 does not itself require that appointment merely because there is no importer. The Commission’s guidance separately addresses a non-EU manufacturer with an EU branch: a branch lacking separate legal personality cannot act as importer, and the guidance refers to a manufacturer’s representative where the relevant Member State requires one. That conditional guidance should be applied to the actual arrangement; a branch address or VAT registration alone does not establish importer status.
The direct seller must also address destination-country EPR representation. Article 45(3) expressly allows Member States to require third-country producers to appoint an EPR representative. Where that requirement applies, the brand appoints a representative established in that country under a written mandate for its EPR obligations. The resulting allocation is clear: the brand remains the manufacturer and producer, the representative performs the mandated EPR work, and there is no separate PPWR importer unless an EU business actually performs that role. An EPR appointment alone does not cover the manufacturer’s conformity obligations.
When the packaging supplier becomes the manufacturer
Packaging without a visible brand still needs an identified manufacturer. The Commission’s PPWR guidance points to who places the order and decides the design specifications. It also distinguishes packaging functions: for sales packaging and grouped packaging that bundles sales units, the manufacturer is normally the business performing the final processing and filling. For finished transport packaging and service packaging intended to be filled at the point of sale, it is normally the packaging maker, unless the user’s branding or other relevant circumstances change that conclusion.
The micro-enterprise exception depends on the supplier’s location. Article 3(1)(13)(b) identifies the packaging supplier as manufacturer where a qualifying micro-enterprise has packaging or a packaged product made under its own name or trademark and the supplier is in the same Member State.
Article 15(12) separately assigns the Article 15 manufacturer obligations to an EU-located packaging supplier supplying qualifying own-name packaging to a micro-enterprise; this provision is broader than the same-Member-State condition. Article 21 contains a related rule for importers and distributors. A direct purchase from a China-based supplier does not meet the EU-supplier condition. Qualification must follow the EU definition of a micro-enterprise, rather than the quantity ordered.
Turn supplier information into a usable conformity file
The manufacturer’s task is to assess the packaging against applicable requirements and document why it complies. Under Articles 15, 38 and 39, this involves the conformity assessment, technical documentation and an EU declaration of conformity once conformity has been demonstrated. A laboratory or another specialist can carry out assessment work on the manufacturer’s behalf; the manufacturer remains responsible for the conformity declaration.
For custom paper packaging, the approved specification gives that work a common reference. It should identify the packaging version, intended use, dimensions, component materials and relevant finishes. We can help bring this information together during development: the board and wrapping paper, insert construction, coating or lamination, printing, adhesives and closures. Recording the approved sample alongside the specification helps connect the customer’s visual approval with the materials that production will use.
Evidence then needs to match that configuration. A heavy-metal test report for one board sample supports a conclusion about the sample and substances tested. Applying it to a finished box with additional papers, inks and adhesives requires an explained basis, with further information or testing where needed. The supplier’s useful contribution is to identify what the evidence covers, obtain the missing material information and coordinate appropriate testing. This gives the manufacturer something it can assess and use in its technical file.
Make the evidence available for import checks
Before market placement, the importer must verify that the manufacturer has completed the required assessment and technical documentation, and check applicable labeling, accompanying documents, packaging identification and manufacturer details. The importer also has its own identification obligations under Article 18. These checks are easier to complete when the declaration, specification and shipment records clearly identify the same packaging.
The manufacturer must retain the technical documentation and declaration for five years for single-use packaging or ten years for reusable packaging, measured from market placement. The importer must keep a copy of the declaration and ensure the relevant technical documentation remains available for those periods. Both must provide the relevant documents within ten days of receiving a reasoned request from a national authority. Agreeing document access at the order stage makes this a workable obligation, including when an upstream material supplier holds part of the evidence.
Responsibility continues when the packaging changes
A seasonal gift box may look unchanged after a wrapping-paper substitution, while its coating or adhesive has changed. The approved appearance alone cannot establish that the earlier evidence still applies. Article 15 requires the manufacturer to take account of design and characteristic changes and reassess conformity where it could be affected. The declaration must also be kept updated. In practical terms, the supplier flags the change, the manufacturer reviews its significance, and any importer receives the updated information needed for its checks.
A useful supply agreement therefore identifies the approved version, the changes requiring notification, the evidence to be delivered and the contacts responsible for responding to a problem. Commercial terms can allocate work and costs, while statutory duties continue to follow the actual PPWR roles. If an importer has reason to believe the packaging is non-compliant, it must hold market placement until conformity is restored; problems discovered later can require corrective action, withdrawal or recall and authority notification.
Identify the EPR producer country by country
Extended producer responsibility concerns the financing and organization of packaging waste management. It is part of the PPWR framework, but its producer definition answers a different question from the manufacturer definition. The manufacturer is responsible for packaging conformity; the EPR producer is identified through the packaging category, first supply in a Member State and whether the recipient is an end user or another business distributing the goods.
Consider the French importer of skincare gift sets. For its first supply of those products in France, it is also the EPR producer there. If it supplies a German retailer that first makes the products available in Germany, that retailer is the producer in Germany. If the French business instead sells directly to German consumers, the French business is the producer for that direct-sales route. The packaging manufacturer can remain the same throughout these arrangements.
Transport packaging can produce another result. A logistics business may remove imported outer cartons at its warehouse and send the retail boxes onward. Where no other person is the producer under the preceding categories in Article 3(1)(15), the business unpacking the goods without being an end user can become the producer for that packaging. Its responsibility for those discarded cartons does not automatically make it the manufacturer of the branded retail box.
The identified producer needs to address the applicable national registration, packaging-volume reporting and waste-management financing requirements. Producer responsibility organizations can perform agreed EPR tasks under the relevant national arrangements. Material and unit-weight information from the packaging supplier supports reporting, but the business responsible for reporting also needs quantities supplied and destination data. A conformity declaration and an EPR registration serve different purposes; each needs its own supporting records.
Where one service provider supports both conformity and EPR work, the written arrangements should identify each role, its scope and the countries covered. Appointment for one purpose does not automatically cover the other. As of September 2026, the Commission’s packaging-waste page describes a proposal to suspend certain EPR representative obligations as still under examination; that proposal should not be treated as an exemption already in force.
Bring the responsibilities into the packaging brief
When discussing an EU-bound packaging project with us, share the product, packaging concept, ordering company, selling countries and intended supply route. Through our EU packaging solutions, we can connect structure and material development with supplier information, sampling and appropriate testing. Establishing the responsible entities early lets that evidence reach the people preparing the conformity file, performing import checks and reporting packaging quantities. You can contact CMIC with an existing specification or a concept that still needs development.
