Which role do you have under the PPWR?

Under the PPWR legislation your role is not determined at organisation level, but per packaging. One company can be the manufacturer of one packaging, the importer of a second and the distributor of a third at the same time. Anyone who tries to establish their role at company level will not work it out.

Your role determines which obligations you have. So this is step one, and everything after it depends on it.

The five roles

Manufacturer. Designs the packaging, or has it designed or made, and places it on the market under its own name or brand. You are the manufacturer as soon as your logo or brand name is on the packaging — even if someone else prints the box. Heaviest package: conformity assessment, technical documentation, declaration of conformity, name and identification number on the packaging.

Importer. Places packaging from a third country on the EU market. Verifies the declaration of conformity and the technical documentation of the foreign manufacturer, puts its own name, address and contact details on the packaging, keeps a copy of the declaration for five years, and responds within ten days to a request from the market surveillance authority.

Distributor. Passes on without placing the packaging under its own name. Checks whether the manufacturer and importer have met their labelling and identification obligations and whether the packaging complies with Articles 5 to 12. On non-conformity: withdraw from the market and report.

Fulfilment service provider. May only provide services if the manufacturer or importer demonstrably meets its obligations. If you provide at least two of the services storage, unpacking, repackaging, addressing or dispatch, you can in certain cases be designated as the producer yourself — namely when no other party has yet been designated as producer. This arises with e-commerce parties from outside the EU that deliver directly to European customers without an importer in the EU.

Producer. The overarching role. Whoever first places a packaging or packaged product on the market in a member state. This is the role that bears the EPR obligation: registration, declaration, contribution.

Manufacturer and producer are not the same

This is the distinction where most mistakes are made.

There is one manufacturer in the entire EU. It is the party behind the brand.

There is one producer per member state. It is the party that first places the packaging on the market there.

An example. A Dutch company has its packaging made by a German converter, under its own brand.

• The Dutch company is the manufacturer. The German converter is merely a supplier.
• If the company sells the product in the Netherlands, it is the producer there and registers with Verpact.
• If the company also sells the product in Germany, it is also the producer there — with a LUCID registration and a German authorised representative (Bevollmächtigter). See Netherlands versus Germany.

You can be a distributor and at the same time a producer. You can be a manufacturer and at the same time a producer. The roles are not mutually exclusive.

Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →

What changes on 12 August 2026

The producer definition shifts. Three consequences that are often missed:

1. Declaration on import shifts. The “discarding on import” flow is no longer declared by the Dutch company that unpacks the goods, but by the foreign consignor or the logistics service provider.
2. Contract packing is no longer exempt. A logistics service provider that unpacks and discards packaging must declare that packaging — even if it is not the owner of the goods.
3. Producers of shipment, e-commerce, service and primary production packaging are, from 12 August 2026, the manufacturer of that packaging, and on sale in the Netherlands thereby also the producer.

Do you sell via Bol.com or Amazon?

Then you, as the brand owner with your own product packaging, are the producer. All PPWR obligations lie with you: substance restrictions, traceability, declaration of conformity, registration with Verpact. The marketplace does not take that over.

With fulfilment by the marketplace, however, a grey area arises around the shipping box: it is not yours. You remain responsible for the packaging around your product itself. See PPWR for e-commerce.