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:

A strategic guide for general management on the EU Packaging and Packaging Waste Regulation and Switzerland’s 2026 Packaging Ordinance (VerpV)

The EU Packaging and Packaging Waste Regulation (PPWR) and Switzerland’s Packaging Ordinance (VerpV) pursue the same goal: cutting packaging waste and building a circular economy. However, the two regulations do not use the same tools to get there. The EU relies on binding bans and fixed quotas. Switzerland relies on reporting duties, fees, and rules that only tighten if industry falls short of its own targets. Companies selling packaged goods in both markets need to track both frameworks separately, since compliance with one does not cover the other.

PPWR (Regulation (EU) 2025/40) was adopted in December 2024 and applies since August 12, 2026, with further requirements phased in through 2040. VerpV was adopted by the Swiss Federal Council on June 24, 2026, and enters into force on January 1, 2027, replacing the Ordinance on Beverage Packaging (VGV) from 2000. Both apply to businesses placing packaging on their respective markets, regardless of company size, though each includes some relief for smaller companies.

Where PPWR and VerpV Agree

PPWR and VerpV share three main commitments: limiting packaging to the minimum necessary, designing packaging for recyclability, and requiring companies to report what they place on the market.

Packaging minimization. Both regulations cap packaging weight and volume at what is needed for safety, hygiene, and product protection, and both ban design choices meant only to make a product look bigger than it is. Under PPWR (Articles 10 and 24), a maximum 50% empty-space ratio applies to grouped, transport, and e-commerce packaging from January 1, 2030. Double walls, false bottoms, and other features added purely to increase perceived volume are explicitly prohibited. VerpV (Article 3) sets a parallel requirement from the same date: packaging must be limited to what safety and hygiene demand, and features designed only to inflate a product’s apparent size are banned.

Design for recyclability. Both frameworks require packaging to be physically recyclable, not just theoretically collectible. PPWR (Article 6) introduces recyclability performance classes A, B, and C from January 1, 2030. Packaging that falls below Class C cannot be placed on the EU market, and by 2038 only Classes A and B will remain allowed. VerpV (Article 3) requires packaging to be technically suitable for collection, sorting, and high-quality recycling from the same date, without the EU’s letter-graded class system.

Reporting and producer responsibility. Both countries require companies to report what they place on the market, though the burden differs by size. PPWR (Articles 44 and 45) requires a national producer registry, with annual reporting for anyone placing packaging on the EU market, and includes administrative relief for micro-enterprises. VerpV (Articles 21 to 24) requires companies to report packaging weights by material. Switzerland limits this duty to companies with turnover above CHF 1 million that place more than 500 kg of packaging on the market each year.

Where PPWR and VerpV Diverge

The EU legislates through direct bans and fixed numbers. Switzerland legislates through reporting, fees, and conditional rules that escalate only if voluntary industry targets are missed. Four differences matter most for general management.

Bans vs. subsidiary rules. PPWR bans specific single-use plastic formats outright from January 1, 2030, including grouping films for multipacks, packaging for fresh fruit and vegetables under 1.5 kg, and single-use cups and plates for dine-in service. VerpV avoids outright bans. Instead, Article 4 sets a subsidiary return obligation: businesses must take back beverage cartons and single-use plastic packaging free of charge at the point of sale, unless they join a collective industry recycling scheme. The ordinance also sets minimum recycling rates of 70% for beverage cartons and 55% for single-use plastic packaging. If industry does not meet these rates voluntarily, the Swiss government can impose a deposit requirement (Pfandpflicht).

Recycled content quotas. PPWR (Article 7) sets binding minimum percentages for recycled plastic content, rising over time. For contact-sensitive PET, such as beverage bottles, the quota is 30% by 2030 and 65% by 2040. Other contact-sensitive plastics must reach 10% by 2030, and other plastic packaging must reach 35%. VerpV (Article 3) requires the highest possible share of recycled material without setting a fixed percentage, leaving the exact figure to what is technically and economically feasible.

Deposit return systems. PPWR (Article 50) requires all EU member states to run a deposit return system for single-use plastic bottles and metal cans up to 3 liters by January 1, 2029, targeting 90% separate collection. VerpV takes a narrower approach: a deposit of at least 30 Rappen applies to reusable beverage containers once the ordinance enters into force. For single-use glass, PET, and aluminum, Switzerland sets a 75% target recycling rate, and a deposit on single-use formats only becomes mandatory if that voluntary rate is missed.

Switzerland’s glass fee (VEG). The EU funds glass recycling through eco-modulated EPR fees built into its general producer responsibility system. Switzerland instead keeps a dedicated Advanced Disposal Fee, the vorgezogene Entsorgungsgebühr (VEG), on glass, charged per bottle at 1 to 10 Rappen. The fee already applies to beverage glass and extends to food and cosmetics glass packaging from January 1, 2028.

Key Deadlines for PPWR and VerpV

Both regulations phase in over several years. These dates matter most for planning:

• January 1, 2027: VerpV enters into force in Switzerland, replacing the 2000 Ordinance on Beverage Packaging. Deposits of at least 30 Rappen on reusable beverage containers apply from this date.
• January 1, 2028: Switzerland’s VEG glass fee extends to food and cosmetics packaging.
• August 12, 2028: Harmonized EU-wide labeling for packaging material composition becomes mandatory.
• January 1, 2029: EU deposit return systems for single-use plastic bottles and metal cans must be operational.
• January 1, 2030: EU bans on specified single-use plastic formats, the 50% empty-space limit, and the first recycled content quotas take effect. Switzerland’s minimization and recyclability requirements apply from the same date.
• January 1, 2031: Swiss reporting duties and subsidiary take-back obligations for beverage cartons and single-use plastic packaging become legally binding.

What This Means for Businesses Selling in Both Markets

Swiss law does not exempt companies from EU rules. If your business is based in Switzerland but exports to the EU, PPWR applies to that packaging regardless of what VerpV requires domestically. Meeting VerpV alone is not sufficient for EU market entry, and meeting PPWR alone is not sufficient for the Swiss market, since VerpV includes reporting and take-back duties that PPWR does not.

Three steps help ahead of the 2030 deadlines that apply in both markets:

1. Audit packaging formats against both frameworks. Check for empty-space violations and single-use plastic formats that PPWR will ban outright, and confirm VerpV’s minimization and recyclability rules separately.
2. Track recycled content requirements by market. PPWR’s quotas are fixed and rising. VerpV’s requirement is qualitative, but demand for certified recyclates will increase in both markets as 2030 approaches.
3. Set up material-level data tracking now. Both regulations require precise data on packaging weight, volume, and material composition, and manual tracking becomes difficult to sustain once EU and Swiss reporting duties overlap.

Frequently Asked Questions

What is the difference between PPWR and VerpV?
PPWR relies on binding EU-wide bans and fixed quotas, while VerpV relies on reporting duties, fees, and rules that only escalate if Swiss industry misses its own voluntary targets. Both aim to cut packaging waste and support a circular economy, but the EU regulates through direct legal requirements and Switzerland regulates through conditional, market-driven mechanisms.

When does VerpV enter into force?
VerpV enters into force on January 1, 2027, replacing Switzerland’s 2000 Ordinance on Beverage Packaging (VGV). Deposits of at least 30 Rappen on reusable beverage containers apply from that date.

Does a Swiss company have to comply with PPWR?
Yes, if the business exports packaged goods to the EU. That packaging must comply with PPWR regardless of what VerpV requires domestically, since meeting VerpV alone is not sufficient for EU market entry.

Does Switzerland have a deposit return system for packaging?
Switzerland currently mandates a deposit of at least 30 Rappen only on reusable beverage containers, not on single-use packaging. A deposit on single-use glass, PET, and aluminum packaging only becomes mandatory if the voluntary 75% recycling target is missed.

Does VerpV set a recycled content percentage, the way PPWR does?
No. PPWR sets binding quotas, for example 30% recycled content for contact-sensitive PET bottles by 2030, rising to 65% by 2040. VerpV requires only the “highest possible share” of recycled material, based on what is technically and economically feasible, without a fixed number.

How PAQR Can Help

PAQR gives businesses a single, structured workspace for managing packaging component data, so PPWR documentation does not end up duplicated across spreadsheets and supplier emails. Map your packaging portfolio once, generate a Declaration of Conformity for the EU market, and keep the underlying material data ready to adapt as reporting needs grow across other frameworks like VerpV.

Click “Try now for free” on paqr.com to start a free trial:

Under the Packaging and Packaging Waste Regulation (PPWR), importers are the legally accountable party inside the EU for every piece of non-EU packaging that enters the market. They act as the gatekeeper between a non-EU manufacturer and the EU market, and the regulation holds them accountable accordingly.

But importer status isn’t fixed, it depends on the specific packaging and transaction. This post breaks down who qualifies as an importer, what obligations that role carries, and what it takes to stay compliant, from the initial border crossing to the years of mandatory document retention that follow.

Am I an Importer Under PPWR?

You are an importer if you place packaging from outside the EU onto the EU market, whether that packaging is empty or already contains a product. But here’s the key: importer status is determined per packaging, not per company.

A manufacturer may produce their own packaging for their own products. The same company may also source packaging from a supplier outside the EU and place it on the market. In that transaction, they act as an importer, subject to importer obligations, even though they are also a manufacturer elsewhere in their supply chain.

Similarly, a distributor that typically sources packaging from EU suppliers may occasionally import a specialty packaging type from Asia. For that specific shipment, they step into the shoes of an importer and must comply with Article 18 (as well as Article 21 if they place that imported packaging on the market under their own brand or trademark).

The takeaway: PPWR does not assign roles to companies; it assigns roles to transactions. If you source any packaging from outside the EU and place it on the EU market, you need to read this post and ensure those specific packagings meet the requirements below.

Verification Obligations Before Placing on the Market

Under Article 18 PPWR, the obligation to place on the market only packaging that complies with Articles 5 to 12 does not fall on the manufacturer alone. It extends explicitly to importers.

Conformity assessment. The importer must ensure that the manufacturer in the third country has carried out the conformity assessment procedure under Article 38 and compiled the technical documentation required under Annex VII.

Declaration of Conformity. Article 18(7) legally obligates the importer to keep a copy of the manufacturer’s EU Declaration of Conformity, retaining it for 5 years for single-use packaging and 10 years for reusable packaging.

Labelling compliance. The importer must ensure the packaging carries the harmonised sorting labels required by Article 12. These labels become mandatory from 2028 on, so this obligation phases in rather than applying immediately, but the verification duty sits with the importer once it does.

Manufacturer identification. The importer must verify that the manufacturer has complied with their identification obligations: placing a type, batch, or serial number on the packaging under Article 15(5), and indicating their name, registered trade name or trademark, and contact address under Article 15(6).

Accompanying documents. The importer must ensure the packaging is accompanied by any legally required documents.
If the importer has reason to believe the packaging does not comply with PPWR requirements, they must not place it on the market.

Traceability and Importer Identification

Once the importer places the packaging on the market, they must make themselves identifiable to market surveillance authorities, separately from the manufacturer.

Contact information. The importer must indicate their own name, registered trade name or trademark, and postal address, plus electronic means of communication where available, on the packaging.

The accompanying document exception. Where it is not possible to display this information on the packaging, the importer may provide it via a standardised, open, digital data carrier (such as a QR code) or on a document accompanying the packaged product. If the manufacturer is already integrating a QR code into the packaging to meet their own identification and contact-detail obligations under Article 15, the importer’s contact details can typically sit on that same digital carrier rather than requiring a separate one.

Storage and transport care. While the packaging is under the importer’s responsibility (whether empty or already containing a product), they must ensure that storage or transport conditions do not jeopardise its compliance with the core sustainability and labelling requirements of Articles 5 to 12.

Record Keeping and Cooperation with Authorities

The importer’s compliance duties continue long after the packaging has entered the EU supply chain.

Document retention: the 5/10-year rule. The importer must keep a copy of the EU Declaration of Conformity at the disposal of market surveillance authorities and ensure the manufacturer’s technical documentation can be made available on request. This retention period is 5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.

The 10-day response limit. If a national authority submits a reasoned request for the technical documentation or proof of conformity, the importer must provide it electronically, and in paper if requested, in a language easily understood by that authority, within 10 days.

Corrective measures. If the importer has reason to believe that packaging they already placed on the market is non-compliant, they must immediately take corrective measures to bring it into conformity, withdraw it, or recall it, and must notify the relevant national market surveillance authorities of the suspected non-compliance and the corrective actions taken. We cover what happens across every role when this goes wrong, including the fines involved, in our post on PPWR non-compliance.

Special Structural Considerations: Branches and EPR

Branch offices cannot be importers. An EU branch office of a non-EU company typically lacks a separate legal personality, meaning it cannot legally take on the importer role under the PPWR. To handle these responsibilities directly, rather than forcing your European distributors or customers to inherit heavy importer liabilities, your non-EU company must incorporate a separate, legally distinct subsidiary within the EU to act as the importer of record.

EPR obligations. Under PPWR, an importer is legally classified as a producer if they are the first to make a packaged product, or empty transport or service packaging, available on a specific Member State’s territory. This means registering in that Member State’s producer register, reporting packaging weights annually, and paying EPR waste management fees. We cover this status in full in our post on the PPWR producer, since importer and producer status frequently apply to the same company at once.

PPWR Importer Obligations at a Glance

Frequently Asked Questions

What is an importer under PPWR?
An importer is any natural or legal person established within the EU that places packaging from a third country, empty or containing a product, on the Union market. A branch office without separate legal personality cannot hold this role.

Does an importer need to create the Declaration of Conformity?
No. The manufacturer is solely responsible for drawing up and signing the EU Declaration of Conformity. The importer’s obligation is to keep a copy of this completed DoC at the disposal of market surveillance authorities once the packaging is on the market, and to ensure the manufacturer’s supporting technical documentation can be provided upon request.

How long must an importer keep packaging documentation?
5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.

How quickly must an importer respond to an authority request?
Within 10 days of a reasoned request, providing the information electronically and, if requested, in paper, in a language the authority easily understands.

Is an importer automatically an EPR producer?
Often, but not automatically. An importer becomes a producer under Extended Producer Responsibility specifically when they are the first to make packaging or a packaged product available in a given Member State’s territory.

How PAQR Can Help

Verifying a non-EU manufacturer’s conformity assessment, holding their Declaration of Conformity, and being ready to produce technical documentation within 10 days of a request are three separate obligations that all depend on the same underlying data being organised and current. PAQR gives you a central workspace to collect and store this documentation by supplier and packaging format, so a request from a market surveillance authority is a retrieval, not a scramble.

Click “Try now for free” on paqr.com to start a free trial:

One of the most common misconceptions in PPWR compliance is what “producer” actually means. Under the regulation, it has nothing to do with who physically makes the packaging. It is a legal status tied to Extended Producer Responsibility, and it applies to a much wider range of businesses than most expect.

Here is what it means, how to tell if it applies to you, and what it requires.

From August 12, 2026, the Packaging and Packaging Waste Regulation (PPWR) creates binding obligations for packaging placed on the EU market. PPWR compliance is not optional, and the regulation sets out clear consequences for those who do not meet its requirements.

PPWR Non-compliance looks different depending on your legal role. Here is what each carries.

From August 12, 2026, food-contact packaging placed on the EU market must meet specific PPWR PFAS concentration limits under the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). The thresholds are precise, the data requirements are demanding, and the documentation burden falls directly on your supply chain as manufacturer.

This post covers the PPWR PFAS restrictions your team needs to prepare for, the supplier data you must secure, and how to structure your technical documentation before the deadline.