📌In this article ESG researcher Rosaida Brahim explains which roles have been identified in the PPWR supply chain and what is expected of all of these roles before the August 12, 2026 implementation deadline.
The Packaging and Packaging Waste Regulation (PPWR) identifies the following roles in the supply chain: the supplier, the manufacturer, the producer, the distributor, and the importer.
These are, for a large part, universal terms. Regardless of what industry they're in, there's a good chance that a person will have a good idea of what a supplier is, what a supplier does, and how a supplier relates to their organization.
The tricky part with the PPWR is that, while the terms are all recognizable, the definitions have been slightly refitted so they best work within the PPWR framework.
This means that the organization you might normally understand to be a supplier, or a producer, or a distributor... could actually be a manufacturer. And this is important, because under the PPWR, the manufacturer carries both the heaviest compliance tasks and the heaviest risks if those tasks are not carried out successfully.
In this article, we take a look at these roles as defined by the PPWR and what is expected from them.
The manufacturer is any natural or legal person that manufactures packaging or a packaged product.
The supplier is any natural or legal person that supplies packaging or packaging material to a manufacturer.
The importer is any natural or legal person established within the Union that places packaging from a third country on the market
The distributor is any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market.
The producer (or producer responsibility organizations) is any manufacturer, importer or distributor who makes a packaging available in an EU Member State for the first time.
Of these, it is the manufacturer who is responsible for gathering the information and technical documentation necessary for the EU-Declaration of Conformity (EU-DoC). The EU-DoC is a legal document declaring that a product complies with Articles 5-12 of the PPWR. An incomplete or inaccurate EU-DoC means that packaging won't be allowed on the market, or that it will be recalled or removed.
That means that the manufacturer's role is central to the execution of the Packaging and Packaging Waste Regulation, and it comes with a whole swath of time consuming due diligence.
There are ways to manage all the responsibilities of being a manufacturer. One example is that, by written mandate, a manufacturer is allowed to appoint an authorized representative who keeps track of the EU-DoC's, makes them available for authorities upon request, and acts as a main contact point. But these management tactics can only really be used when organizations are aware that these responsibilities fall on them in the first place.
This brings us to the following point -- the supply chain roles that are so clearly defined on the page sometimes overlap in real life. Take the following examples:
If an importer or a distributor places packaging on the market under its own name or trademark, they shall be considered a manufacturer.
Likewise, if an importer or a distributor modifies packaging already placed on the market in a way that could affect compliance, they shall also be considered a manufacturer.
Example -- a clothing brand who buys in already made, PPWR compliant packaging but adds their brand to it becomes a manufacturer and must write up a new EU-DoC.
This means that it is extremely important for organizations to assess their packaging and ask the following questions:
These questions can help guide organizations to better understand their roles and responsibilities in the PPWR supply chain. It is always advisable for organizations to get a second opinion to eliminate any lingering doubt.
Compliance with Packaging and Packaging Waste Regulation (PPWR) is vital for businesses with packaged goods on the EU market. It is also much easier said than done.
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