EU PPWR FAQs Updated August 2026 - Flipbook - Page 12
necessary technical documentation and information to demonstrate conformity with the applicable
requirements for the EU declaration of conformity when they place the packaging on the market.
As is also the case for sales, grouped, service and primary production packaging, if the transport
packaging does not bear a name or trademark, then the decisive criterion to establish who the
manufacturer is will be who places the order and decides on the design specifications for that
packaging. For unbranded, generic transport packaging, this company would normally be the
company who physically manufacturers the packaging. If the transport packaging is wearing a
name or trademark, the company whose name or trademark is on the packaging is manufacturer.
See further in the Commission guidance for the PPWR, point 2.
Below are two examples of who the manufacturer of transport packaging is:
•
A cardboard box has reached its final form even if it is flat and requires folding. If the box has
a name or trademark on it, the company carrying the name or owning the trademark will be the
8manufacturer9. For unbranded, standardised cardboard boxes, the company that physically
manufactures the boxes will be 8manufacturer9. If a company adds a sticker on the box for
shipment purposes, it is not considered to be branding, and this company should not be
considered 8manufacturer9.
•
Stretch wrap for stabilisation of packaged products on pallets should be considered packaging
when it is sold on a roll, even if it is subsequently cut to wrap pallet loads. The 8manufacturer9
is the company that physically manufactures the wrap and places it on the market as packaging,
if it is unbranded, rather than the company that purchases the wrap and subsequently uses it to
secure goods.
6) Who is the 8manufacturer9 of branded packaging? NEW!
According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark,
the manufacturer will be the natural or legal person who manufactures packaging or packaged
products.
Where a natural or legal person has packaging or a packaged product designed or manufactured
under its own name or trademark, that person is to be considered the manufacturer. This is
regardless of whether another trademark is displayed on the packaging or packaged product.
If a packaging bears a name or trademark, the manufacturer is the economic operator under whose
name or trademark the packaging is placed on the market, even where another operator may
physically carry out the manufacturing or filling. However, if this economic operator is a microenterprise, and if the supplier is located in the same Member State, the supplier of the packaging or
packaged product will be manufacturer.
The Commission guidance for the PPWR, point 2 explains that: 8If the packaging or packaged
product carries a certain name or trademark, it can be assumed that the owner of that name or
trademark is the 8manufacturer9 [..], as it will have the decisive power in the contractual relation
with its suppliers and will therefore be able to determine also the packaging characteristics9. The
company which commissions another company to manufacture packaging or packaged products
under its name or trademark is in a position to determine the characteristics of the packaging,
including the branding of packaging which could influence the packaging9s conformity assessment.
This is also the case when an economic operator simply chooses a standardised packaging option
and does not ask for changes to the design and the production process.
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