EU PPWR FAQs Updated August 2026 - Flipbook - Page 14
The producer definition addresses packaging used in primary production. 8Primary production9 is
to be understood as 8the production, rearing or growing of primary products including harvesting,
milking and farmed animal production prior to slaughter9 (3). Packaging material, for example foil
or straps used for hay bales, is only considered to be made available on the market, and thereby
packaging, when the bales are placed on the market and not when it is used in a production process,
in this case on the same farm.
9)
Who is the 8producer9 of transport packaging? NEW!
The producer of transport packaging must be identified when it is empty (see further explanation
above [8Who is the manufacturer of transport packaging?9]).
The following provide some typical examples of who the producer of transport packaging is:
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Company A is the manufacturer of unbranded, standardised cardboard boxes and sells them
to Company B located in the same Member State. In this case, Company A would typically
be the producer. This is also the case when the cardboard boxes are sold flat and require
folding.
If company A sells the cardboard boxes to Company C in another Member State, and
Company C fills the boxes to transport packaged products, then Company C would
typically be the producer in that Member State.
If Company A fills the cardboard boxes and sells them to an end user in another Member
State, then Company A would typically be the producer in that other Member State.
If Company A manufactures cardboard boxes under the name or trademark of Company B,
then Company B will typically become the manufacturer and producer of the boxes in that
Member State. However, if Company B is a micro-enterprise, then Company A is
manufacturer and the producer in the Member State.
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