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This article explains how PPWR assigns economic operator roles and gives a general overview of the manufacturer, importer, distributor, and producer categories. It does not cover every exception or edge case in the regulation. Role determination can be nuanced, and the correct classification depends on the specific facts of your packaging and supply chain. If you are unsure which role applies to you, consult the legal text of Regulation (EU) 2025/40 or reach out to the PAQR team.
Every requirement in the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, attaches to a role. Establishing whether your company needs to issue a Declaration of Conformity, register in a producer register, or audit upstream compliance documentation starts with a single question: which economic operator role do you hold for this packaging?
PPWR role determination is the starting point for every other compliance decision. Get it wrong at the outset, and it tends to affect every document, deadline, and obligation that follows.
This post covers the roles PPWR assigns along the supply chain, the principle that decides which one applies, and a step-by-step way to work out your role for a given piece of packaging.
PPWR Roles Are Assigned Per Packaging, Not Per Company
The PPWR does not classify companies. It classifies packaging, item by item.
Under the regulation, “economic operator” is the general umbrella term that covers roles like manufacturers, importers, distributors, and fulfillment service providers. However, “producer” is a separate, specialized compliance status assigned under Article 3 for Extended Producer Responsibility (EPR). It applies to whichever manufacturer, importer, or distributor is the first to place a packaged product on a specific Member State’s territory.
Because of this, the same company can easily hold multiple roles across its portfolio. A business might act as the manufacturer for its own branded product line, the importer for a second line sourced from outside the EU, and a distributor for a third EU-sourced supplier’s product, all at the same time.
This is why PPWR role determination must be run per packaging item, and, for EPR producer status specifically, per Member State. A single, company-wide answer to “what are we under PPWR” simply does not exist.
The PPWR Roles at a Glance
Each role carries a different set of obligations. This is a starting point, not the full list. Detailed breakdowns for each role are linked below.
Manufacturer
- Definition: Under Article 3(1)(13), the party that manufactures packaging, or has packaging designed or manufactured, and markets it under its own name or trademark. This includes brand owners who sell packaged products under their own brand. There is only one manufacturer per packaging item, whose company and contact details have to be indicated on the packaging, as per Article 15(5) and (6).
- What this requires: Carrying out the conformity assessment, compiling the Annex VII technical documentation, signing the EU Declaration of Conformity (DoC), and keeping these files for 5 years (single-use packaging) or 10 years (reusable packaging) after the packaging enters the market.
Importer
- Definition: Under Article 3(1)(17), any natural or legal person established in the EU that places packaging from a non-EU (“third”) country onto the Union market.
- What this requires: Before placing packaging on the market, ensuring the manufacturer completed the conformity assessment and technical documentation, and keeping a copy of the DoC on file for 5 years (single-use) or 10 years (reusable). Verifying that the packaging carries correct marking and labeling, including both the manufacturer’s and the importer’s company and contact details, as required under Article 18(3).
- Visit our Importer Spotlight for a full breakdown of importer obligations.
Distributor
- Definition: Under Article 3(1)(18), any natural or legal person in the supply chain (such as wholesalers or retailers), other than the manufacturer or importer, who makes packaging available on the EU market.
- What this requires: Before selling, verifying that the packaging is correctly labelled, that the manufacturer and importer have printed their contact/ID details on the packaging, and that the producer is registered in the national EPR register of the destination.
Producer (EPR)
- Definition: Under Article 3(1)(15), not a separate operational role, but a legal status under Extended Producer Responsibility (EPR) that applies to whichever manufacturer, importer, or distributor is the first to make packaging (or packaged products) available on a specific Member State’s territory.
- What this requires: Registering in that country’s national producer register under Article 44, reporting packaging weights annually, and paying national EPR recycling fees under Article 45.
- To learn more about what it means to be a Producer, check out our Producer Spotlight.
How to Determine Your PPWR Role
Work through this per packaging type. Sales and grouped packaging follows one path. Transport packaging determines the manufacturer differently, so it gets its own path below.
For sales and grouped packaging
Manufacturer: Do you physically produce this packaging, or have it designed and manufactured under your own brand? If yes, you are the manufacturer, and you must carry out the conformity assessment and issue the Declaration of Conformity (DoC) under Article 15. (Note: If you rebrand or modify someone else’s packaging, you also step into the manufacturer’s obligations under Article 21).
Importer: Are you bringing this packaging into the EU from outside the EU for the first time? If yes, you are the importer, and you must ensure the manufacturer completed their compliance files, and keep a copy of the DoC in your own company records under Article 18.
Supplier: Are you supplying empty packaging or packaging materials or components (like raw materials, caps, bottles, labels, or inks) to a manufacturer? If yes, you are a supplier, and you must provide the manufacturer with the technical and material data they need to prove compliance under Article 16.
Distributor: Do you buy and sell packaged products within the EU without rebranding or modifying them? If yes, you are a distributor, and you must verify that the packaging is correctly labelled, marked with manufacturer/importer contact details, and that the producer is registered for EPR under Article 19.
Fulfillment Provider: Do you warehouse, pack, or dispatch packaging or packaged products for someone else without taking ownership of them? If yes, you are a fulfillment service provider, and you must ensure your storage and handling conditions do not damage compliance under Article 20.
If none of those apply, you’re not an economic operator for this packaging, and no PPWR obligation applies.
For transport packaging
Does this transport packaging (like pallets or crates) carry your logo/trademark, or was it custom designed for your brand or product? If either is true, you are legally considered the manufacturer of that transport packaging. If not, your packaging supplier is the manufacturer.
Full breakdown: PPWR Transport Packaging: Who Is Responsible for the Declaration of Conformity?
Separately: are you also a producer?
Whichever role applies above, ask one more question per Member State: am I the first to make this packaged product available on this specific country’s market? If yes (including if you sell B2C via a webshop from another country, or unpack imported goods), you are also the “producer” under Extended Producer Responsibility (EPR), and must register and report packaging weights in that Member State.
Why Getting Your Role Right Matters
Clear role determination creates a solid foundation for your entire compliance strategy. It ensures Declarations of Conformity are issued by the correct party, EPR registrations are completed in every target market, and products move smoothly through the supply chain without legal friction. For a full overview of role-specific liabilities and regulatory requirements, explore our guide on PPWR Non-Compliance: Legal Consequences Across the Supply Chain.
Frequently Asked Questions
What is an economic operator under PPWR?
“Economic operator” is the regulatory umbrella term for the physical businesses in the supply chain. Under the PPWR, this officially includes manufacturers, suppliers, importers, distributors, authorized representatives, and fulfillment service providers. (Note: “Producer” is a separate, additional status for Extended Producer Responsibility).
Is a PPWR role tied to a company or to a specific packaging item?
To the packaging item. The same company can be the manufacturer for one packaging, the importer for another, and a distributor for a third, all at the same time, and even hold different producer status in different Member States for the same packaging.
Who is the manufacturer under PPWR?
The manufacturer is normally the party that manufactures packaging under its own name or trademark, or that effectively controls how it’s manufactured by another company. For sales and grouped packaging, this is usually the brand owner. For transport, service, and primary production packaging, it’s normally the party that makes that packaging, unless it carries the user’s branding or specification.
When does an importer become the manufacturer under PPWR?
Under Article 21, an importer that places packaging on the market under its own name or trademark, or that modifies packaging in a way affecting its conformity, is treated as the manufacturer and takes on the full set of manufacturer obligations for that packaging.
What is the difference between manufacturer and producer under PPWR?
The manufacturer holds conformity obligations (the Declaration of Conformity and technical documentation) and is determined once per packaging item for the entire EU Single market. The producer holds EPR obligations (registration, reporting, recycling fees) and is determined separately per Member State, based on who first makes the packaging available there. The same business is often both, but not always.
Can a distributor also be a producer under PPWR?
Yes. If a distributor is the first to make a given packaging or packaged product available within a specific Member State, it takes on producer status there, alongside its distributor role.
How PAQR Can Help
Once your role is determined, day-to-day work shifts to whichever documentation obligation follows from it: conformity data for manufacturers, verification records for importers and distributors. PAQR gives you a central workspace to organise that documentation by packaging and by market, so the record of what applies to which packaging item doesn’t live in someone’s inbox.
Click “Try now for free” on paqr.com to start a free trial:
