It’s a striking figure: every EU citizen generated 177.8 kg of packaging waste in 2023, according to Eurostat. The environmental and economic implications are impossible to ignore – escalating resource consumption, loss of valuable materials, and rising regulatory pressure on businesses.
The EU’s response is the Packaging and Packaging Waste Regulation (PPWR). Unlike a directive, this regulation applies directly across all Member States since 11.02.2025, while most of its obligations and legal requirements will kick in as from 12 August 2026, leaving no room for national interpretation or delay. Its mission is clear: prevent unnecessary packaging, drive reuse, and significantly increase recycling rates. By 2030, at least 70% of all packaging waste must be recycled, with ambitious material-specific targets for plastics, paper, glass, metals, and wood.
Are you a “Producer” under the PPWR?
But there is one aspect many companies underestimate: The PPWR introduces a new, much clearer definition of who is the “producer”. And this matters — because the “producer” becomes the central responsible party for compliance and Extended Producer Responsibility (EPR).
This is where many businesses will be affected – even those who never considered themselves packaging producers before. The New PPWR Definition of “producer” (Art. 3.15) is defining a producer as the economic operator who first makes packaging or a packaged product available on the market of a Member State, whether as:
- a manufacturer
- an importer
- a distributor
- an e-commerce operator
- a brand owner
- or a contract giver
The objective is simple: every packaging unit should have one clearly identifiable responsible producer.
The Contract Giver becomes the Producer
The contract giver is automatically the producer – that is one of the most impactful changes. If you have packaging or packaged products manufactured under your own name or trademark, you are considered the producer, even if:
- another company physically manufactures the product,
- another brand name appears on the packaging,
- production happens outside the EU.
This means, the contract giver becomes legally responsible for the packaging. All EPR obligations fall to them, including fees, reporting, design requirements, and compliance documentation.
Why this matters for your Business
The new definition of a manufacturer under PPWR includes any natural or legal person who manufactures packaging or packaged products – or the customer who commissions this manufacturing. As a result, the roles of “manufacturer” and “producer” merge in many cases, thereby increasing responsibility. Responsibility may shift within a supply chain: companies that were previously ‘only distributors’ or “only brand owners” may now be classified as producers – with full compliance obligations.
You should check:
- Do you place packaging or packaged products on the EU market for the first time?
- Do you sell under your own brand or trademark?
- Do you commission manufacturing or packaging through third parties?
- Do you import packaged goods into the EU?
- Do you operate an online shop targeting EU customers?
If any of the above points apply, you may be the obligated manufacturer under PPWR. You will then need to assess your role in the supply chain.
What you need to do now:
- Map your packaging flow across countries and partners.
- Analyse design, recyclability, and minimisation requirements.
- Prepare for EPR obligations in all relevant Member States.
- Establish documentation and conformity processes early.
- From 2026, compliance will no longer be optional — and the responsibility will be clearly assigned.
Need help with EU Packaging Compliance?
The PPWR is reshaping responsibilities across the entire packaging value chain.
If you are unsure whether your company is considered a “producer” or how the regulation affects you, please contact us by answering 5 simple questions in our Quick Obligation Check.