Who is responsible for the conformity of packaging?

Responsibility for product conformity lies with the manufacturer within the meaning of the PPWR. That is not necessarily the company that physically produces the packaging. Anyone who has packaging or a packaged product designed or made under their own name or brand is generally the manufacturer themselves.

In its PPWR guidance the European Commission makes clear that for sales and grouped packaging the manufacturer is regularly the party carrying out the final processing steps and filling the product. That is often also the brand owner. Within a supply chain there is generally only one manufacturer within the meaning of the PPWR.

This manufacturer bears the legal responsibility for the conformity of the packaging. Under Article 16, suppliers must provide the necessary information and documents. Responsibility for assessing conformity nevertheless remains with the manufacturer. An exception applies to microenterprises: if a microenterprise has packaging made under its own brand and the packaging supplier is located in the same Member State, the supplier is generally regarded as the manufacturer.