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PPWR role check: which role do you have under the Packaging Regulation?

Obligations under the Packaging and Packaging Waste Regulation depend on your role, not only on company size. Answer the questions below to see which roles apply to you and what each one requires. Your answers stay in your browser.

Do you manufacture packaging or packaged products yourself?
Do you have packaging or packaged products designed or manufactured under your own name or trademark?
Do you import packaging or packaged products from outside the EU (a third country) and place them on the EU market? (Your company is established in the EU.)
Do you sell or distribute packaged products that you did not manufacture or import yourself?
Do you supply packaging or packaging materials to another company that uses them to make packaging or packaged products?
Do you make packaging or packaged products available for the first time in your own EU country (by manufacturing, importing, or bringing them in from another country)?
Do you unpack packaged products (for example remove transport packaging) that you do not use yourself as an end user, where no one else is already the producer for that packaging in your country (for example, you bought them abroad)?
Do you sell packaged products directly to end users in another EU country (for example through an online shop)?
Do you sell or hand packaged products directly to end users (shop, food service, take-away)?
Do you offer at least two of the following for goods you do not own: warehousing, packaging, addressing, dispatch? (Transport, courier or postal services alone do not count.)

Roles under the Packaging Regulation

The Regulation places obligations on economic operators (Art. 3(1)(12)). The same company can have different roles for different packaging.

ManufacturerBefore placing packaging on the market, carries out the conformity assessment and draws up the Annex VII technical documentation and the EU declaration of conformity (Art. 15(2)). Art. 3(1)(13)
ImporterBefore placing packaging on the market, ensures the manufacturer has carried out the conformity assessment and drawn up the technical documentation, the packaging is labelled, and the manufacturer's details are on it (Art. 18(2)). Art. 3(1)(17)
DistributorBefore making packaging available on the market, verifies that the producer is registered in the register of producers, the packaging is labelled, and the manufacturer's and importer's details are on it (Art. 19(2)). Art. 3(1)(18)
SupplierProvides the manufacturer with all information and documentation needed to demonstrate the conformity of the packaging and packaging materials (Art. 16(1)). Art. 3(1)(16)
Producer in your country (extended producer responsibility)Has extended producer responsibility for packaging it makes available for the first time in that Member State, or unpacks there (Art. 45(1)). Art. 3(1)(15)(a), (b), (e)
Producer in another EU countryIf you sell directly to end users in another Member State, you are a producer there and must register there once its national register is set up (Art. 44(1) and (2)). Art. 3(1)(15)(c), (d)
Final distributorIf you are in the HORECA sector and sell beverages or ready-prepared food in take-away packaging: by 12 February 2027, consumers must be able to bring their own container to be filled (Art. 32(1)). Art. 3(1)(21)
Fulfilment service providerEnsures that storage, handling, packing, addressing and dispatch do not jeopardise the packaging's conformity (Art. 20). Art. 20

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Frequently asked questions

Who is a manufacturer under the PPWR?

A manufacturer is any natural or legal person that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark (Article 3(1), point 13).

Can one company have several roles?

Yes. The role is determined per packaging: the same company can be the manufacturer of one packaging and the importer or distributor of another.

What is the difference between a manufacturer and a producer?

The manufacturer is responsible for the packaging's conformity (Article 15). The producer is the extended producer responsibility role: a manufacturer, importer or distributor that makes packaging available for the first time in a Member State, or unpacks packaged products without being the end user (Article 3(1), point 15, and Article 45).

This tool is information, not legal advice. Roles follow the definitions in Article 3(1) of Regulation (EU) 2025/40 (Official Journal text), checked 23 October 2026. Your answers stay in your browser; if you accept analytics cookies, we count anonymously which roles were shown.