Manufacturer

Under Article 3(1)(13) PPWR, the manufacturer is responsible for ensuring that packaging meets the requirements of the PPWR. The manufacturer is whoever makes packaging or a packaged product themselves, or has it designed or made under their own name or trademark. For each piece of packaging, there is exactly one manufacturer across the EU.

Sales packaging such as stand-up pouches only becomes packaging once it is filled. Without contract manufacturing, the manufacturer is therefore whoever fills it. If a company has its products filled by a co-packer under its own brand, the commissioning company remains the manufacturer. An exception applies to micro-enterprises. The manufacturer’s obligations include the declaration of conformity and the labelling requirements. Not to be confused with the producer.