PPWR: Your role determines your responsibilities - companies need to know their place in the value chain
A company is not automatically assigned one specific role under the PPWR. The same company may, for example, be a manufacturer for one packaging flow and a distributor or importer for another.
That is why one of the first questions companies preparing for the PPWR need to ask is:
What is our role?
This question was at the heart of Emballageretur’s webinar series in August 2026 on the roles of manufacturers, importers, distributors and suppliers under the PPWR.
The webinars helped companies identify their role in the value chain and, consequently, the obligations that come with it. Here, Emballageretur’s Subject Matter Expert, Rikke Halkjær Kristensen, summarises the key takeaways from the webinars.
One of the most common misconceptions when working with the PPWR is that many companies associate the role of manufacturer with the physical production of packaging.
However, the manufacturer role is not determined by who physically produces the packaging, but by who designs it, determines its specifications or markets it under their own name or trademark.
This means, for example, that a retail chain with private-label products may be considered a manufacturer even if the packaging is produced by an external supplier. Similarly, a company may have several different roles at the same time, depending on the individual packaging flows and products.
The manufacturer is the economic operator with primary responsibility for documenting that the packaging complies with the requirements of the PPWR. This includes carrying out a conformity assessment, preparing technical documentation, issuing an EU declaration of conformity and keeping the documentation up to date.
Authorities may request access to materials specifications, test reports, compliance declarations and technical files, among other documentation. Documentation processes, data collection and supplier management will therefore become key areas for companies with manufacturer responsibilities.
Although the supplier does not assume the manufacturer’s responsibilities, suppliers play an important role in the documentation chain.
Suppliers must provide the information and documentation that manufacturers need to demonstrate that their packaging complies with the PPWR.
This includes materials specifications, test reports and other data related to the requirements of the PPWR. For many suppliers, it will therefore become necessary to systematically manage packaging portfolios, documentation and data sharing across customers and markets.
Distributors are companies that make packaging or packaged products available on the EU market without themselves being the manufacturer or importer. Their main task is to verify that the necessary requirements have been met before the packaging is made available on the market.
If there is reason to suspect that the requirements have not been met, the packaging must not be made available on the market until the issue has been resolved. Distributors must also ensure that handling, storage and transport do not affect the packaging’s compliance with the rules.
The importer is the company that first places packaging from a third country on the EU market. Importers may only place packaging on the market if it complies with the requirements of the PPWR and must therefore ensure that the manufacturer has completed the necessary documentation and labelling.
Importers must also retain documentation and be able to provide it upon request from the authorities.
An important point to be aware of is that both distributors and importers may be considered manufacturers if they market packaging under their own name or modify the packaging in a way that may affect its compliance with the PPWR. In such cases, they assume the manufacturer’s responsibilities and documentation obligations.
It is therefore essential that companies continuously assess their role in each individual product and packaging flow rather than relying on their organisational title or traditional function in the value chain.
The key message from the webinar series is that companies should start by mapping their product and packaging flows to identify their role or roles under the PPWR. Only then can they determine which documentation requirements, controls and processes need to be established.
To support this work, Emballageretur has developed a screening tool that can help companies clarify their role in the value chain and gain an overview of the associated obligations.