PPWR: who is the "producer"? Trade press reports first practical questions

The EU Packaging Regulation (PPWR) has applied since 12 August, and the trade press is beginning to address the first practical questions. One question comes up strikingly often: who is actually the "producer" of a packaging item? The answer determines who is responsible for conformity, registration and the associated obligations — and in practice that answer is not always self-evident.

Shipping labels: role clarified, conformity not yet automatically assured

The European Commission has clarified that a shipping label on transport packaging does not in itself make an online trader a producer. This appears to provide clarity, but the German association for online retail (BVOH) warns that this does not mean every label is risk-free. Whether the conformity of the packaging is maintained depends on factors such as the material of the label, the adhesive used, and its size and placement on the packaging. In other words: a case-by-case assessment remains necessary (EUWID, 19 August).

Lidl takes on the producer role for its private labels

The question of who the producer is also arises with private label products. According to the same explanation from the Commission, a retail company is deemed to be the producer, even where the packaging states "manufactured on behalf of". Lidl has informed suppliers of private label products that, for certain private label packaging, the company will itself assume the producer role rather than leaving this with the supplier (EUWID, 18 August).

What does this mean for your organisation?

For companies that produce, print or place wooden or cardboard packaging on the market, this is a good moment to establish exactly which role you play in the chain — producer, importer, distributor — and which obligations come with it. This applies both towards your own customers (does your packaging state "on behalf of", for example?) and towards your suppliers.

In addition, EUWID reports that the minimum recyclate quotas for plastic packaging may take effect later than the originally intended date of 1 January 2030, because the underlying implementing rules appear to require more time than planned (EUWID, 19 August). For customers with wooden or cardboard packaging this is mainly background information, but it shows that the implementation of the PPWR is still very much in flux — all the more reason to map out your own role and position in good time.

Would you like to know exactly which role you fulfil under the PPWR and what this means in practical terms for your packaging? We would be glad to discuss this with you in a short, no-obligation conversation.