PPWR key terms: who is who, and who pays?

Producer (EPR)

Whoever first makes packaging or packaged products available on the territory of a Member State, or unpacks packaged products there without being the end user.

Producer status is determined per Member State, and the definition covers five situations (see the table below). The essence: for empty transport, service and primary production packaging the supplier is the producer; for all other packaging formats it is whoever first makes the packaged product available. If you supply across the border directly to end users, you are the producer in your customer’s country. If your customer resells there, they are.

For EPR: This is the role the whole of extended producer responsibility hangs on: registration in every Member State concerned (Article 44) and the financial contribution (Article 45). Holding another role — manufacturer, distributor, supplier — does not in itself mean paying a contribution.

Source: Article 3(1)(15); Articles 44 and 45

Manufacturer

Whoever makes packaging or packaged products, or has them designed or made under their own name or trademark.

The name or trademark is the condition, not the order or the drawing: if you have boxes made to your own specification but they are placed on the market under the maker’s name, the maker remains the manufacturer. A printed logo is not required — Article 15(6) also allows the manufacturer’s name via a QR code or an accompanying document. Practical test: under whose name does the packaging reach the market, and who signs the declaration of conformity? Whoever packs their own products is a manufacturer too, because they make a packaged product.

For EPR: Being a manufacturer does not in itself mean paying a contribution. It means the heaviest documentation duty: conformity assessment, technical documentation and the EU declaration of conformity.

Source: Article 3(1)(13); Article 15

Supplier

Whoever supplies packaging or packaging material to a manufacturer.

The definition names both: ready-made empty packaging (boxes, crates, bottles, film on rolls) and raw or semi-finished material (paper, board, ink, adhesive, laminate). Manufacturer and supplier do not exclude each other — a printing house makes the box and supplies it to the party that fills it. The supplier must give the manufacturer all information and documentation needed to demonstrate conformity.

For EPR: If you supply empty transport, service or primary production packaging, the contribution is yours, not your customer’s. For empty sales and grouped packaging it is the other way round: the party that fills it is the producer.

Source: Article 3(1)(16); Article 16

Importer

A party established in the Union that places packaging or packaged products from a third country on the market.

The establishment requirement is part of the definition itself: a party outside the Union cannot be the importer — their customer in the EU is. The importer checks that the manufacturer has done their work (assessment, documentation, labelling, contact details), adds their own name and postal address, and keeps a copy of the EU declaration of conformity available. If they doubt conformity, they do not place the packaging on the market.

For EPR: Importing usually makes you a producer as well, because you are the first to make the packaging available in a Member State. The roles stay separate though: the importer’s duties concern conformity, EPR concerns registration and contribution.

Source: Article 3(1)(17); Article 18

Distributor

Whoever makes packaging available on the market without being the manufacturer or the importer.

Unlike the importer, this definition carries no establishment requirement: a seller from outside the Union who makes packaging available here is a distributor too. Before making it available you verify that the packaging carries the required label, that the manufacturer’s and importer’s details are on it and — importantly — that the producer on whom EPR rests is listed in the producer register. That is a check on registration, not on payment.

For EPR: Reselling within the same Member State does not make you a producer: your supplier already was. The register is free of charge, public and searchable, precisely so that you can run that check yourself.

Source: Article 3(1)(18); Article 19; Article 44(13)

Final distributor

Whoever supplies packaged products to the end user — a shop, a hospitality business, a webshop, but also a wholesaler supplying users.

This role carries the obligations that touch the user: refill and re-use, the offer of reusable packaging in the hospitality and takeaway sector, and the take-back of beverage packaging. The heaviest requirements apply when you supply consumers.

For EPR: Being a final distributor says nothing about the contribution. If you were the first to make the product available in that country, you are also the producer; if you resell purchased products, you are not.

Source: Article 3(1)(21) and (23); Articles 28, 29, 32 and 33

End user and consumer

The end user uses or processes the product themselves and does not resell it in the same form. A business customer can be an end user too.

Supplying businesses is therefore no exemption: a company that applies your film to its own product, or uses the machine in your crate, is an end user. What they then do with the packaging — re-use it, throw it away, put it out with the waste paper — is irrelevant. The consumer is the end user acting outside a trade or profession; some requirements (refill, re-use, beverages) apply only towards consumers.

For EPR: The distinction decides whether supplying another Member State makes you a producer there: directly to end users it does, to a party that resells it does not.

Source: Article 3(1)(21) and (23)

Fulfilment service provider

Whoever stores, packages, addresses or dispatches on behalf of others without owning the goods.

The fulfilment provider is an economic operator with obligations of its own. It may only provide its services once the client has supplied the registration number and self-certification, and it must suspend the service if that information turns out to be incorrect or incomplete and is not corrected.

For EPR: It does not take over its client’s contribution, but it does check the client’s EPR status — just as an online platform does.

Source: Article 3(1)(12); Articles 20 and 45

Authorised representative for EPR

The party you appoint in a Member State where you are a producer but not established.

If you supply from the Netherlands directly to end users in Germany, you are a producer there and appoint an authorised representative to handle registration and contribution on your behalf. In a Member State where you have your own establishment this is not needed. If you are established entirely outside the EU, it applies in every Member State where you make packaging available.

For EPR: This is the only EU anchoring that can be mandatory for you. Do not confuse it with the authorised representative for conformity below: that is a different mandate, and it is voluntary.

Source: Article 45(3); Article 3(1)(15)(c) and (d) and (20)

Authorised representative of the manufacturer

A voluntary mandate under which a manufacturer has conformity tasks carried out on their behalf.

The manufacturer may authorise someone in writing to keep the EU declaration of conformity and the technical documentation, to provide them to the authorities on request and to cooperate with them. Drawing them up is not allowed — that remains the manufacturer’s own work. This mandate is not mandatory.

Source: Article 17(1) and (2); Article 3(1)(19) and (20)

Producer responsibility organisation

The organisation that collectively fulfils the EPR obligations of affiliated producers — Verpact in the Netherlands.

You may have an approved organisation carry out your obligations; Member States may even make this mandatory. It then also takes over registration and reporting. Information for end users about prevention, re-use, separate collection and the meaning of the labels runs through the organisation as well.

For EPR: Joining does not relieve you of responsibility for the accuracy of the data you supply.

Source: Article 46(1); Article 44(2); Article 55

Economic operator

The collective term for everyone in the chain: manufacturer, supplier, importer, distributor, final distributor and fulfilment service provider.

Some obligations attach not to one role but to everyone. The most important is traceability: at the request of the market surveillance authority you must be able to identify which economic operators supplied packaging to you, and which economic operators you supplied yourself.

Source: Article 22(1) and (2)

Extended producer responsibility (EPR)

The principle that whoever places packaging on the market contributes to its collection and treatment.

In Dutch this is UPV (uitgebreide producentenverantwoordelijkheid), in German erweiterte Herstellerverantwortung. The PPWR sets out the duty; the level and the collection are national and therefore differ per Member State.

For EPR: Two things belong to it and are often forgotten: registration is unconditional, even where no national contribution applies to your packaging, and reporting is done per Member State.

Source: Articles 44, 45 and 46

Producer register

The national register in which every producer enrols, per Member State.

As long as you are not registered you may not make anything available in that country. Changes to your details and definitive cessation are reported without delay. Member States make the list available free of charge, publicly, searchably and machine-readably, so that customers can verify your registration.

For EPR: Ask a new supplier once for their registration number, record it with the supplier details and review it periodically — in the same round as your supplier assessment, for instance.

Source: Article 44(2), (4), (12) and (13); Annex IX, Part A

Waste management contribution

The financial contribution the producer pays for collection, sorting and treatment of its packaging.

The PPWR adds two cost items: the labelling of the collection receptacles and the survey of the composition of mixed municipal waste. The rates themselves are national.

For EPR: If your country has an exemption for certain packaging — logistics aids in the Netherlands — it only concerns the contribution. Registration and reporting continue to apply.

Source: Article 45(1) and (2)

Annual report

The yearly report of how much packaging you placed on the market, by 1 June at the latest.

You report the weight per packaging category of Table 1 of Annex II — the combination of main material and packaging format, for instance paper and board separately from beverage carton. Below ten tonnes in a Member State the short report suffices, per material: glass, plastic, paper and board, ferrous metals, aluminium, wood and other. Member States may have the report certified by an independent auditor and may ask for quarterly reporting.

For EPR: This is the requirement that shapes your administration: your packaging records must produce weights per category, not just totals per invoice.

Source: Article 44(7), (8) and (9); Annex IX, Part B; Annex II, Table 1

Eco-modulation

Differentiating the contribution according to the recyclability of the packaging.

Poorly recyclable packaging becomes more expensive. This starts eighteen months after both the delegated acts (by 1 January 2028) and the implementing acts (by 1 January 2030) have entered into force — so count on after 2030. Member States may in addition modulate the contribution by the share of recycled content in plastic packaging.

For EPR: This turns packaging design into a direct cost item: the material, adhesive or label you choose today determines your rate later.

Source: Article 6(8); Article 7(7); Annex II, Table 3

Deposit return system

A mandatory return system for single-use plastic beverage bottles and metal beverage containers of up to three litres.

Member States must have a system collecting 90% by weight separately by 1 January 2029 at the latest. You join the system in every country where you make those containers available, with the corresponding marking and administration. Wine and similar fermented beverages, spirits and milk and dairy are among the exemptions; glass and beverage cartons fall outside these two formats anyway.

Source: Article 50(1), (2), (4), (5) and (11); Annex X

Self-certification to platform and fulfilment

The statement by which you confirm to a marketplace or fulfilment provider that you meet the EPR requirements.

An online platform may only admit you once you have supplied your registration number in the consumer’s country and declared that you offer there only packaging for which EPR has been complied with. The platform assesses that information for completeness and reliability; your fulfilment provider asks the same when the contract is concluded.

For EPR: In practice this is where a missing registration hurts first: no number, no sales channel.

Source: Article 45(4), (6), (7) and (8)

Logistics aids (Dutch national practice)

The Dutch category covering pallets, crates, roll containers and similar carriers.

Under the PPWR pallets are simply transport packaging with full EPR; the Regulation grants no exemption here. In the Netherlands Verpact treats them as logistics aids: the shape decides, not the material or the use. Multiple use means no declaration and no contribution, single use means a declaration but no levy. The list is exhaustive and includes pallets, crates from 8 litres (an open wooden crate qualifies), boxes from 1 m³ internal volume (a closed wooden machine crate), big bags from 250 litres and cores or reels from 50 cm.

For EPR: This is national practice, not an EU rule. Other Member States do not have it, and the eco-modulation of Article 6(8) does not guarantee that the zero rate survives 2030.

Source: National implementation — Verpact, List of Logistics Aids and step-by-step guide; PPWR Article 3(1)(15)(a) and Article 45

Packaging

Anything intended to contain, protect, handle, deliver or present a product.

An item hung on or attached directly to a product that performs a packaging function counts too: a hang tag on a garment is packaging, a sewn-in label that stays with the product for its whole life is not. A label or sticker applied directly to an unpackaged product — a barcode on a tool, a sticker on fruit — is packaging as well. Annex I gives the examples and the counter-examples: a core or reel with film wound around it is packaging, a toolbox or a plant pot that stays with the plant is not.

Source: Article 3(1)(1); Annex I

Sales packaging

Constitutes the sales unit for the end user at the point of sale.

The box, bottle or bag the product is bought in — and also the core, reel or roll around which your film, cable or paper is wound: it travels with the product to the customer. A crate or pallet in which a product is transported is not sales packaging, even if your customer buys the crate.

For EPR: For sales packaging the producer is the party that first makes the packaged product available — not the supplier of the empty packaging.

Source: Article 3(1) (definitions); Annex I

Grouped packaging

Groups a number of sales units into one stock or shelf unit.

An outer case, a tray, shrink wrap around six bottles. Its hallmark is that it can be removed without affecting the product.

For EPR: As with sales packaging, the contribution rests with whoever first makes the packaged product available.

Source: Article 3(1) (definitions); Annex I

Transport packaging

Facilitates handling and transport and prevents damage in transit.

Pallets, wooden crates, crates, trays, drums, pallet wrappers and strapping bands. Road, rail, ship and air freight containers are excluded, and the core or reel your product is wound on is sales packaging. If the shipping box goes to the end user in an online sale, it is e-commerce packaging.

For EPR: For empty transport packaging the contribution rests with the supplier who first supplies it, not with you who fills or uses it. Ask for the registration number.

Source: Article 3(1)(15)(a); Annex I

E-commerce packaging

The shipping box in which an online-ordered product reaches the end user.

Legally a form of transport packaging, but with its own rules: the sorting label does apply here, and so does the empty-space limit.

Source: Article 3(1) (definitions); Article 12(1); Article 24

Service or takeaway packaging

Filled at the point of sale to hand the product over.

A coffee cup, a chip tray, a bread bag.

For EPR: For empty service packaging the contribution rests with the supplier, just as with transport packaging.

Source: Article 3(1)(15)(a); Annex I

Primary production packaging

Packaging for unprocessed products straight from the field, the farm or the sea.

Harvested fruit and vegetables, milk, eggs, fresh fish — think of the harvest crate or the fish box. Once the product has been processed or packed for the consumer, the packaging around it is no longer primary production packaging.

For EPR: Here too, the contribution for the empty packaging rests with the supplier.

Source: Article 3(1)(15)(a); Annex I

Reusable packaging

Designed and placed on the market for multiple rotations, repairable and emptied without damage.

The design decides, not whether you get the packaging back: an EPAL pallet remains reusable even if your customer never returns it. A thin one-way pallet is not. Re-usability is a property alongside the format, not a format of its own, and it must be substantiated against nine conditions in the technical documentation — without that substantiation “reusable” means nothing legally.

For EPR: The retention period for the file is ten years instead of five, and reusable packaging counts towards the re-use targets of Article 29.

Source: Article 3(1)(28); Article 11(1), (2) and (3); Annex VI

Composite packaging

Packaging made of several materials that cannot be separated by hand, where the additional material exceeds 5% of the mass.

The two conditions are cumulative. A beverage carton is composite; the nails in a pallet or crate stay well below 5% and therefore do not make the packaging composite. Labels, varnish, paint, ink and adhesive never count towards it. “Composite” is a property, not a material category: the packaging remains classified by its main material.

For EPR: The classification determines your annual report — per packaging category of Table 1 of Annex II — and your recyclability class.

Source: Article 3(1)(24); Article 44(7) and (8); Annex II, Table 1

Integrated and separate components

Parts attached to the packaging or coming off it: a cap, a lid, a sleeve, a spout.

Components are assessed separately or together with the packaging, and must not harm the recyclability of the main material. Mind the plastic cap on a glass bottle or a carton: it falls under the recycled-content requirement of Article 7, unless the plastic makes up less than 5% of the weight of the packaging unit.

Source: Article 3(1)(43) to (45); Article 6(9); Article 7(5)

Making available on the market and placing on the market

“Placing on the market” is the first time packaging becomes available on the Union market; “making available” is every supply after that.

Both concepts are expressly limited to the Union market. What you export outside the EU therefore falls outside the PPWR — provided you can separate that flow in your packaging records.

For EPR: EPR hangs on a third concept: first making available on the territory of one Member State. That is why producer status is a question per country.

Source: Article 3(1)(9) and (10)

Conformity assessment (module A)

The internal production control the manufacturer completes before placing packaging on the market.

You compile technical documentation: a description of the packaging and its intended use, drawings and material data, the standards applied, the assessments of recyclability, minimisation and where applicable re-usability, test reports and a risk analysis. No notified body, no CE marking. If an authority asks, you provide the documentation within ten days.

Source: Article 38; Article 15(2) and (10); Annex VII

EU declaration of conformity

The declaration by which the manufacturer assumes responsibility for conformity, per packaging type.

It follows the model of Annex VIII, has no expiry date and is kept up to date: a change of design, material or standard triggers a fresh assessment. An authorised representative may keep and provide it, but not draw it up. Technical documentation and declaration are kept for five years for single-use packaging and ten years for reusable packaging.

Source: Article 39; Article 15(3); Article 17(2); Annex VIII

Recyclability and recyclability class

Designed for recycling, with a performance class A, B or C from 2030.

That all packaging must be recyclable has applied as a principle since 12 August 2026. The class requirement comes later: from 1 January 2030 — or 24 months after the delegated acts, whichever is later — only classes A, B or C; from 1 January 2038 only A or B. From 2035 whether the packaging is recycled at scale counts as well, with a threshold of 30% for wood and 55% for the other materials.

For EPR: This is the requirement with the longest lead time, and the one your rate will hang on.

Source: Article 6(1), (2), (3) and (9); Article 3(1)(39); Annex II

Recycled content

The mandatory minimum share of recycled material in plastic packaging.

The percentages start on 1 January 2030 and rise towards 2040; they differ per packaging format. Plastic making up less than 5% of the weight of the packaging unit is out of scope. For a number of product groups — medicinal products, medical devices and infant formula among them — the requirement does not apply, but that exemption hangs on the product, not on the packaging.

Source: Article 7(1), (2), (4), (5) and (6)

Minimisation and empty space

Packaging may not be heavier, larger or emptier than functionally necessary.

From 12 February 2028 every packaging must be reduced to the functional minimum in weight and volume; false bottoms and misleading double walls are then prohibited, with re-usability weighing in as a function. For grouped, transport and e-commerce packaging a hard limit is added on 1 January 2030: no more than 50% empty space, with filling material counting as empty space.

Source: Article 10; Article 24; Annex IV

Sorting label

The harmonised pictogram on the material composition, so the end user can sort.

Mandatory from 12 August 2028, or 24 months after the implementing acts if that is later. It does not apply to transport packaging between businesses nor to packaging under a deposit return system — a pallet or transport crate carries no sorting label — but it does apply to e-commerce packaging. Stock produced before the start date may still be made available without the label for three years. Reusable packaging carries a label of its own, with a QR code.

Source: Article 12(1), (2), (3), (5), (6), (7), (11) and (12)

Traceability

Being able to identify who supplied packaging to you and whom you supplied.

At the request of the market surveillance authority you name your suppliers and your customers. For your suppliers the law sets a period: five years for single-use packaging and ten years for reusable packaging, counted from the supply. This obligation applies to every economic operator, even if you have nothing else to declare.

Source: Article 22(1) and (2)

System for re-use and re-use targets

The organisation behind reusable packaging, and the percentages to be met from 2030.

Whoever makes reusable packaging available ensures there is a system meeting Annex VI — with return, cleaning and repair — and whoever participates follows the rules and confirms this in writing. From 1 January 2030 targets apply to the use of reusable transport packaging, with exemptions for dangerous goods and very small undertakings among others.

Source: Articles 11, 26, 27 and 29; Annex VI

Substances of concern and the 100 mg/kg limit

The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg.

Three things go wrong here regularly. It is a sum limit: 60 mg/kg lead plus 60 mg/kg cadmium is too much. It applies per packaging component too: chromium(VI) passivation on nails counts on the nail and may not be averaged away over the weight of the pallet. And exactly 100 mg/kg is allowed, 100.5 is not. A generic REACH statement from your supplier is not enough; compliance must be demonstrated in your own technical documentation.

Source: Article 5(1), (4), (6) and (8); Annex VII, point 2