PPWR Responsibilities Explained: Who Does What in the Packaging Value Chain?
The Packaging and Packaging Waste Regulation (PPWR) is one of the biggest changes to packaging legislation in Europe in decades. Yet for many food producers, brand owners and retailers, one of the most difficult questions is not what the regulation requires. It’s understanding who is responsible for what.
If you have been following PPWR discussions, you may have seen terms such as supplier, manufacturer, producer, importer and distributor. At first glance, they sound familiar. But under PPWR, these roles have specific legal meanings that don’t always match how companies describe themselves in everyday business.
This is where much of the confusion begins.
As Susan Janssen, Sustainability Manager at Wipak Group, recently told us:
“Customers are confused and lost; they try to interpret what their actual responsibilities are but miss clarity. To add complexity, the role is not related to the stage of the supply chain but to the packaging definitions and the stage at which it becomes waste.”
In other words, PPWR does not simply assign responsibilities based on whether you are a supplier, a converter, a food producer or a retailer. Instead, responsibilities are linked to legally defined roles within the packaging system.
Why understanding your role matters
PPWR introduces new requirements around packaging compliance, technical documentation, declarations of conformity and extended producer responsibility. From August 2026, certain obligations will already begin to apply.
The challenge is that not every economic operator is responsible for every requirement.
A packaging supplier will have different obligations from a food producer. A retailer may have different obligations from an importer. Understanding where your responsibilities begin and end is essential for preparing for compliance.
The easiest way to understand PPWR responsibilities is to break them down into the five key roles defined in the regulation.
The supplier: providing information and support
A supplier provides packaging materials or packaging components that will later be used to create packaging.
For example, a flexible packaging company may supply film on a reel. That film is a packaging material, but it is not yet the final packaging that reaches consumers.
As Susan explains:
“We are supplying packaging material. We are not making packaging. We are delivering a film on a reel, and that film is not yet a packaging.”
Under PPWR, suppliers are expected to provide information that helps manufacturers demonstrate compliance. This may include material specifications, statements about substances, and information about heavy metals and PFAS.
What suppliers are generally not responsible for is carrying out conformity assessments or issuing the final PPWR EU Declaration of Conformity for the finished packaging.
Practical Example
A packaging supplier produces a flexible film for sliced cheese packaging. The supplier provides material specifications, PFAS information and supporting technical data. However, the supplier is not responsible for declaring that the final cheese pack placed on a supermarket shelf complies with PPWR. That responsibility sits with the manufacturer of the final packaging.
The manufacturer: the key compliance role
The manufacturer has the central compliance responsibility under PPWR.
This is where many organisations are surprised.
Many assume that the company producing the packaging material is automatically the manufacturer. Under PPWR, that is not necessarily the case. While the role in designing or manufacturing the packaging must be considered, the trademark or branding criterion is often the determining factor. In most cases, the company whose name, brand or trademark appears on the packaged product will be considered the manufacturer and therefore carries the primary compliance responsibility.
As a result, responsibility often sits with the food producer, retailer or brand owner placing the packaged product on the market, rather than with the packaging supplier that physically manufactures the packaging material.
The manufacturer is responsible for:
- Carrying out conformity assessments
- Preparing technical documentation
- Drawing up the EU Declaration of Conformity
- Ensuring that packaging complies with applicable PPWR requirements
As Susan describes it:
“The manufacturer is the one and only economic operator in the value chain that has to do the technical documentation.”
This is why suppliers cannot simply sign declarations on behalf of customers. The final responsibility for demonstrating compliance remains with the manufacturer. In many cases, that manufacturer is the company whose brand appears on the packaged product.
Practical Example
A mozzarella producer purchases film from a packaging supplier and uses it to package and seal grated mozzarella before selling it under its brand. Under PPWR, the mozzarella producer will typically be considered the manufacturer because it is responsible for the final packaging placed on the market. It must assess compliance, prepare technical documentation and issue the Declaration of Conformity.
The producer: responsible for packaging waste
One of the most misunderstood terms in PPWR is producer.
The producer is not necessarily the company that manufactures packaging.
Instead, the producer is the organisation responsible for financing the management of packaging waste through Extended Producer Responsibility schemes. This includes registration, reporting packaging volumes and paying EPR fees.
Depending on how products move through the market, the producer may be a food company, retailer, distributor, importer or another organisation that first makes the packaged product available within a particular Member State.
In simple terms:
- The manufacturer is responsible for packaging compliance.
- The producer is responsible for packaging waste obligations.
Practical Example
A retailer that owns a private label cheese brand and places the product on the market in Germany is typically both the manufacturer and the producer. Similarly, if a food company owns the brand and places the product on the German market, that company is typically both the manufacturer and the producer. However, if the packaged product is subsequently placed on the market in another EU Member State, the organisation introducing the product into that market may become the producer for EPR purposes and assume the associated obligations. In simple terms, the manufacturer is linked to brand ownership and packaging compliance, while the producer is linked to placing the packaged product on a specific national market and financing its end of life management.
The importer: checking compliance before products enter the EU market
Importers have a vital role in ensuring that packaging entering the EU market meets regulatory requirements.
If packaging or packaged products are brought into the EU from a third country, the importer must verify that the necessary documentation is available and that relevant compliance requirements have been met.
Think of the importer as the checkpoint between non EU products and the European market.
Practical Example
A food company imports packaged snacks from a manufacturer in Asia and sells them in Europe. Before placing those products on the EU market, the importer must verify that the packaging complies with relevant PPWR requirements and that supporting documentation can be made available if requested.
The distributor: maintaining compliance through the supply chain
Distributors play a supporting role within the system.
They are responsible for ensuring that products and packaging moving through the supply chain continue to meet the necessary requirements. This includes checking that required information, documentation and labelling are available.
Their responsibilities are generally lighter than those of manufacturers or producers, but they still have a role in supporting or maintaining compliance throughout the value chain.
Practical Example
A distributor purchases packaging reels from a supplier and resells them without modifying them. The distributor is not responsible for carrying out conformity assessments, but it must ensure that the appropriate information and documentation can be passed along the supply chain.
What does this mean for food producers?
For many food producers, the most important takeaway is that they may be considered the manufacturer under PPWR.
That means they are likely to be responsible for:
- Bringing together information from suppliers
- Assessing the final packaging
- Creating the required technical documentation
- Issuing the EU Declaration of Conformity for the packaging placed on the market
Packaging material suppliers can provide valuable support and data, but they cannot take responsibility for aspects of the packaging they do not control, such as final design, filling processes, labelling or packaging configuration.
The bottom line
PPWR is changing how packaging responsibilities are allocated across the value chain.
The good news is that compliance does not sit with one organisation alone. Success will require collaboration between suppliers, manufacturers, producers, importers and distributors. Each has a role to play.
However, understanding which role applies to your business is the first step.
As Susan says:
“The first milestone is already there on the 12 of August, but more will follow in the years to come. We are just at the beginning.”
The sooner organisations understand their responsibilities under PPWR, the better prepared they will be for the changes ahead.
Source:
European Commission. Guidance Document for Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), Commission Notice C(2026) 3702 final, June 2026
