PPWR Roles at a Glance: Manufacturer, Producer, Importer - Who Is Responsible for What

Executive Summary: The new EU Packaging and Packaging Waste Regulation (PPWR) not only tightens technical requirements, it also redefines roles and responsibilities across the supply chain. For FMCG companies, it is crucial to clarify whether they are considered a Manufacturer, Producer or Importer under the PPWR - because this determines product responsibility, EPR obligations and who issues the PPWR Declaration of Conformity. This article explains in practical terms the differences between these roles, typical real-world constellations and which role must provide which evidence and documents - with a particular focus on the PPWR Declaration of Conformity (DoC). A practical step-by-step guide to implementing the PPWR from 2026 onwards can be found in the PPWR Guide 2026.

1. Why getting your PPWR role right from 2026 is critical

The PPWR (Regulation (EU) 2025/40) entered into force on 11 February 2025 and will apply from 12 August 2026 to all packaging placed on the EU market. From that date, companies must be able to demonstrate for every relevant packaging type that they comply with Articles 5-12 (e.g. recyclability, material minimisation, substance restrictions).

From 12 August 2026, every packaging placed on the market for the first time will require a valid PPWR Declaration of Conformity (DoC). Who in the supply chain is responsible for this declaration, the technical documentation and EPR reporting depends directly on their PPWR role.

For packaging, procurement and sustainability teams this means:

• Incorrect role assignment creates documentation gaps and liability risks.
• Roles can differ by country and by packaging type.
• A single company can simultaneously be a Manufacturer, Producer and Importer.

Those who clarify these interdependencies early can embed PPWR requirements efficiently into existing processes and into digital packaging management.

2. Key PPWR concepts: Placing on the market, economic operator, product responsibility

Before diving into the specific roles, it is worth taking a look at three core concepts in the PPWR.

2.1 "Placing on the market"

Under the PPWR, "placing on the market" refers to the first time packaging or packaged products are made available for distribution, consumption or use in the course of a commercial activity in an EU Member State.

Key points:

• Responsibility is linked to the first making available in each Member State - not necessarily to where the product was manufactured in the EU.
• Packaging is placed on the market at several levels (sales, grouped, transport, e-commerce packaging).

2.2 "Economic operator"

The PPWR lists as economic operators, among others, Manufacturers, Suppliers, Importers, Distributors, Producers and Authorised Representatives. For FMCG companies, three roles are particularly relevant:

• Manufacturer (technical manufacturer)
• Producer (responsible party in terms of product responsibility/EPR)
• Importer (importer from non-EU countries)

2.3 Product responsibility and EPR

The PPWR is closely linked to Extended Producer Responsibility (EPR) systems. Going forward, a harmonised EU-wide definition of the "Producer" will apply, who is responsible, among other things, for the collection, recovery and financing of packaging waste.

For companies this means: The Producer bears product responsibility and must ensure that the packaging they use is PPWR-compliant - including recyclability, recycled content quotas and correct labelling.

3. The "Producer" role: Product responsibility under EPR

3.1 Producer - the key role for EPR

The PPWR uses Producer not in the sense of the technical manufacturer, but as the party that initiates the value chain in the relevant Member State.

A Producer is anyone who places packaging or packaged products on the market for the first time in a Member State - regardless of whether they actually manufacture, import or distribute the products themselves.

Typical Producer constellations in the FMCG sector:

• Brand owner with production in the EU who supplies packaged goods to retail partners
• Retailer who places products on the market under a private label
• Importer who brings packaged goods from third countries into the EU
• E-commerce provider who uses shipping packaging for the first time in a given country

3.2 Core obligations of Producers

For Producers, PPWR and national EPR laws give rise to, among others, the following obligations:

• Registration and reporting to the relevant bodies (e.g. compliance schemes, registers)
• Financing the collection and recovery of packaging waste (EPR fees)
• Ensuring compliance with PPWR design and recycling requirements
• Providing packaging data (material, weights, categories) for EPR reporting
• Coordination with the Manufacturer and Importer regarding specifications and evidence

For packaging and procurement, the Producer is usually the owner of product responsibility and budget holder for EPR fees.

4. The "Manufacturer" role: Technical responsibility and conformity assessment

4.1 Who is a Manufacturer?

According to the PPWR, a Manufacturer is the party that manufactures packaging or has it manufactured and markets it under their own name or brand.

This includes:

• Packaging manufacturers and converters (e.g. film, board, pouch manufacturers)
• Contract packers or fillers that pack products for third parties
• Private-label Producers

Packa interprets this role as the technical manufacturer, primarily responsible for specifications, testing and technical documentation.

4.2 Manufacturer responsibilities under the PPWR

Under the PPWR, the Manufacturer is in principle responsible for conducting the conformity assessment and issuing the Declaration of Conformity.

This includes:

• Creating and maintaining technical specifications for each packaging type
• Carrying out the conformity assessment (design for recycling, material minimisation, substance restrictions)
• Building and maintaining the technical documentation
• Drafting and signing the PPWR Declaration of Conformity (DoC) or providing the necessary information for it

Digital platforms such as the Packa software for digital packaging management consolidate specification data, supplier declarations and evidence centrally in an audit-ready way. A more detailed description of the implementation steps is also available in the PPWR Guide 2026.

4.3 When Importers or Distributors become Manufacturers (Art. 21 PPWR)

One important point: According to Article 21 PPWR, an Importer or Distributor is deemed to be the Manufacturer if they place packaging or packaged products on the market under their own name or brand.

Practical examples:

• A Distributor imports white-label products but applies their own branding.
• An online marketplace sells products under its own in-house brand.

In such cases, these companies themselves must:

• conduct the conformity assessment,
• issue and sign the PPWR DoC, and
• provide the technical documentation.

Companies with extensive private-label portfolios or imported goods should pay particular attention to these constellations when clarifying roles.

5. The "Importer" role: Compliance gatekeeper for goods from third countries

5.1 What Importer means under the PPWR

An Importer is any natural or legal person established in the EU who places packaging or packaged products from a third country on the EU market for the first time.

Typical Importer roles:

• National subsidiary of a global FMCG group sourcing from non-EU production sites
• Trading company importing finished products from third countries
• E-commerce companies that ship directly from third countries into the EU

5.2 Obligations of Importers

Even if the technical Manufacturer is based outside the EU, the Importer must verify compliance with all PPWR requirements before placing products on the market.

Core obligations include:

• Checking whether a valid PPWR DoC exists for each packaging
• Ensuring that technical documentation (material structures, test reports, evidence) is available
• Verifying labelling in line with PPWR (e.g. recyclability, material identification)
• Working with the non-EU Manufacturer to close data gaps

Frequently, the Importer is also the Producer in the respective country and therefore carries EPR responsibility.

6. Manufacturer, Producer, Importer compared

The following overview summarises roles and obligations. It is intended as guidance and does not constitute legal advice.

Source: Packa analysis and external expert commentary on PPWR roles. A complementary, practice-oriented overview of operational implementation is provided in the PPWR Guide 2026.

7. How to determine your PPWR roles in a structured way

For packaging and procurement teams, clear role assignment per product and country is the most important step towards PPWR readiness.

7.1 Step-by-step approach

1. Map your flows
   • Production location (EU vs. third country)
   • Brand ownership
   • Supply routes and destination markets
2. Determine the role per market
   • Who places the product on the target market for the first time?
   • Are there private-label setups or direct imports?
3. Identify multiple roles
   • National subsidiaries are often both Importer and Producer
   • A Distributor with private labels may be both Producer and Manufacturer (Art. 21)
4. Fix responsibilities
   • Who internally "owns" the PPWR DoC, who owns EPR reporting?
   • Which department is responsible for which task?
5. Map roles digitally
   • Systems like Packa assign roles, responsibilities and documents clearly to each packaging type.

8. Impact on PPWR documentation & Declaration of Conformity

8.1 Who issues the PPWR Declaration of Conformity?

Responsibility for the PPWR Declaration of Conformity lies with the Manufacturer. Importers and Distributors must verify before placing products on the market that a valid declaration and technical documentation exist.

Under Article 21, an Importer/Distributor may legally be the Manufacturer and must then prepare the DoC themselves.

For detailed requirements, see Packa's guide to the PPWR Declaration of Conformity: PPWR Guide 2026.

8.2 Data required for the DoC

The DoC requires a robust data foundation, typically including:

• Material composition, including coatings, adhesives, additives
• Evidence of recyclability
• Data on recycled content, and where relevant, reusability
• Test reports on substance restrictions (e.g. PFAS)
• Mapping of all packaging variants (sizes, materials)

All roles access the same packaging data foundation - but with different obligations.

8.3 Why digital packaging management is the right approach

Packa analyses show that with manual processes, 30-70% of critical packaging data is missing, particularly relating to material layers, additives or supplier certificates.

Digital solutions like Packa offer:

• Central management of all packaging specifications
• End-to-end role and responsibility mapping
• Automated supplier data collection and compliance checks (PPWR, EPR, PFAS)
• Audit-proof storage of DoCs and related documentation

A good starting point is the PPWR DoC template, as presented in the Packa article or available directly via the PPWR Declaration of Conformity template.

9. Recommendations for action: Next steps for packaging and procurement teams

Concrete actions based on the role logic:

Short term (0-6 months):

• Role mapping:
  • Which legal entity is Manufacturer, Producer or Importer in which country?
• Packaging inventory and identification of all data sources
• Gap analysis of existing specifications and DoCs
• Define a governance model for role assignment between procurement, packaging, sustainability and quality

Medium term (6-18 months):

• Establish or expand a digital packaging data platform
• Integrate suppliers into standardised data collection processes
• Set up PPWR DoCs for key packaging families (high volume, high risk)
• Link EPR reporting with PPWR data (e.g. eco-modulation)

Long term (up to 2030):

• Use the data foundation for portfolio management (recyclability, use of recycled content)
• Develop internal KPIs (e.g. share of compliant packaging, DoC coverage, recyclability)

A comprehensive overview of all roles and processes can be found in the supplementary Packa article "PPWR: Understanding roles and responsibilities along the supply chain" as well as in the practice-oriented PPWR Guide 2026.

Frequently Asked Questions

1. What is the difference between "Manufacturer" and "Producer" under the PPWR?

The Manufacturer is the technical manufacturer or the party that has packaging manufactured and sells it under their own name. They are responsible for specifications, conformity assessment and technical documentation, including the PPWR Declaration of Conformity.

The Producer is the party that places packaging or packaged products on the market in a Member State for the first time and assumes product responsibility (EPR). This is often the brand owner or Importer.

2. When is an Importer also a Producer or Manufacturer?

An Importer is always the Producer when they place products from third countries on the market in an EU country for the first time. Under Article 21 PPWR, they may also be the Manufacturer if they sell products under their own brand.

• Importer without own branding -> Producer, not Manufacturer
• Importer with private label -> Producer and Manufacturer with DoC responsibility

3. Who signs the PPWR DoC?

The Manufacturer or the economic operator deemed to be the Manufacturer (e.g. Importer/Distributor with a private label).

Producers, Importers and Distributors must ensure that a valid DoC is in place, even if they are not the signatory.

4. How are PPWR roles and EPR fees connected?

With the PPWR, the Producer is defined in a harmonised way across the EU - and national EPR systems are aligned with this definition.

• The Producer declares quantities and pays EPR fees
• Manufacturer and Importer provide the technical data foundation
• The Manufacturer's design decisions (material mix, recycled content) will increasingly influence EPR costs (eco-modulation)

5. How does software like Packa support PPWR roles and obligations?

Packa brings together all packaging data, roles and evidence on a single platform and enables:

• Structured capture of Manufacturer, Producer and Importer roles for each packaging type
• Automated data collection from suppliers (specifications, certificates, test reports)
• Integrated compliance checks (PPWR, EPR, recyclability, PFAS)
• Creation and versioning of PPWR Declarations of Conformity

This turns PPWR compliance from a manual risk into a data-driven, scalable process for product responsibility, procurement and engineering. Concrete implementation steps for the period up to 2026 are summarised in the PPWR Guide 2026.