PPWR: Rolls and Packaging Types

TABLE OF CONTENTS

I. Packaging types

Sales packaging (primary packaging)

The packaging that directly encloses the product and is supplied to the end user as a sales unit.

Grouped packaging (secondary packaging)

Groups together several sales units; it is not in direct contact with the product. It serves, for example, to present the product on the shelf and can be removed without altering the product's properties.

Transport packaging (tertiary packaging)

Packaging that facilitates the handling and transport of several sales units or grouped packaging. Example: pallets.

E-commerce packaging

Transport packaging used to deliver products in the context of online sales or other forms of distance selling to the end user. Legally, it is therefore a special type of transport packaging with its own scope of application (distance selling to end customers).

Service packaging

Containers designed and intended to be filled at the point of sale. If cups, food containers, or bags are sold empty, they do not count as packaging; if they are filled at the point of sale, they qualify as service packaging.

II. Roles

The PPWR assigns obligations not to the packaging, but to the economic operator. A company can hold several roles at the same time. What is decisive for determining the role is not who physically produces the packaging, but who performs which function in the supply chain.

In our solution, the role is determined per packaging unit, since one and the same company can hold different roles for different packaging.

Manufacturer

The central role, carrying product responsibility. A manufacturer is anyone who has packaging or a packaged product developed or produced under their own name or brand — regardless of whether they physically produce it, and regardless of whether other brands are visible. What matters is brand ownership, not the manufacturing itself.

Core obligations: carry out the conformity assessment, draw up and retain the technical documentation, issue the EU declaration of conformity, and apply name/address to the packaging.

Supplier

Anyone who supplies packaging or packaging materials to the manufacturer. The supplier bears no independent manufacturer obligations towards the authorities, but must hand over to the manufacturer all information and documents the manufacturer needs to demonstrate conformity (including the details required for the technical documentation).

Importer

Anyone established in the EU who places packaging from a third country on the Union market for the first time. Both conditions must be met. A mere VAT registration or a branch office without its own legal personality is not sufficient to meet the establishment requirement.

Core obligations: verify that the non-EU manufacturer has carried out the conformity assessment; request and hold available the DoC and technical documentation; apply their own name/address.

Distributor

Anyone in the supply chain — other than the manufacturer or importer — who makes packaging available on the market, typically wholesale and retail. Before making it available, the distributor checks formal points (e.g. whether the manufacturer is entered in the EPR register, whether labelling and operator identification are present) and ensures storage and transport conditions that preserve conformity.

Fulfilment service provider

Anyone who provides warehousing, packing, addressing, or dispatch for third parties without owning the goods — typically logistics/shipping service providers. The obligation is narrowly defined: they must ensure that conditions during storage, handling, packing, addressing, and dispatch do not impair the conformity of the packaging. No further verification or documentation obligations apply; the focus is on operational diligence in physical handling.