EU PPWR FAQs Updated August 2026 - Flipbook - Page 44
14) Who is the manufacturer of custom-made transport packaging that does not bear a
name or trademark? NEW!
If a company orders a custom-made packaging from another company, the company making the
order will be considered the manufacturer under the PPWR.
This is due to the fact that, for packaging that does not bear a name or trademark, the decisive
criterion is who places the order and decides on the design specifications for that packaging. If the
packaging is custom-made for a specific product, the packaging characteristics are based on the
product, and therefore the decisive power will rest with the company that orders the custom-made
packaging. The company that supplies the packaging to the manufacturer must provide the
manufacturer with the necessary technical documentation, as specified in Article 16 of the PPWR.
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