How to determine your role under PPWR? A 2-minute quiz for companies

PPWR - Regulation (EU) 2025/40 on packaging and packaging waste - entered into force on 11 February 2025. From 12 August 2026, its provisions will, as a rule, apply directly in all European Union Member States, with no need for transposition into national law.

Which obligations your company will have depends primarily on its role in relation to a specific packaging item or packaged product. You may be a manufacturer, importer, distributor or supplier, and at the same time a producer for the purposes of extended producer responsibility. Importantly, a single company can play different roles for different products.

Answer a few questions and check your role under PPWR in 2 minutes, along with the key obligations that may apply to your company.

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Who does PPWR apply to?

PPWR applies to a broad range of operators - in practice, to any company that in any way places packaging or packaged products on the EU market: packaging manufacturers, companies that pack products, importers, distributors, retailers and some operators that use packaging in their business.

A key principle: company size does not exempt you from obligations. PPWR contains no automatic exemptions for micro-enterprises or SMEs. The scope of obligations depends on your role in the supply chain, not on the scale of your activity. A small e-commerce company selling under its own brand may have a broader scope of obligations than a large distributor of third-party products.

Companies will also not receive any individual, additional time to adapt to the obligations that start to apply on 12 August 2026. Some other requirements - such as labelling (from 2028) or design for recycling (from 2030 or later, depending on the implementing acts) - have their own, later deadlines.

Why does a company's role under PPWR matter?

Existing Polish rules used the concept of the "entity placing packaged products on the market". PPWR moves away from this approach and introduces a system of supply-chain roles. Obligations are not distributed evenly - their scope depends on whether you act, with respect to a given packaging item, as a manufacturer, importer, distributor or supplier.

The most common mistake: "This doesn't concern our company - the obligations sit with the packaging producer." Yet if you commission the design of packaging under your own brand or trademark, you are the manufacturer - regardless of where the packaging was physically made.

Most importantly, a role is not assigned to a company once and for all - you determine it for a specific stream of packaging. The same company can be the manufacturer of own-brand packaging, the importer of components from outside the EU and the distributor of third-party products - all at the same time.

Manufacturer, importer, distributor and supplier - how do these roles differ?

PPWR defines economic operators by their actual function in the supply chain, not by their name or legal form.

Manufacturer

A natural or legal person that actually manufactures packaging or a packaged product. You also gain manufacturer status if you commission the design or manufacture of packaging under your own name or trademark - and this applies regardless of whether your mark is visible on the packaging.

The manufacturer bears the main responsibility for the packaging's compliance with PPWR: it carries out the conformity assessment (Annex VII), draws up the technical documentation and issues the EU declaration of conformity (DoC, Article 39 + Annex VIII).

Importer

An operator established in the EU that places on the market packaging originating from a third country (outside the EU). The importer takes over responsibility for compliance where a non-EU producer cannot bear it - and this responsibility cannot be passed on to a third-country supplier.

Distributor

An operator, other than the manufacturer or importer, that makes packaging available on the market. The main obligation is due diligence: verifying that the manufacturer has carried out the conformity assessment, that the documentation is available and that the packaging is correctly labelled. The distributor must also ensure that storage and transport conditions do not impair the technical parameters of the packaging.

Supplier

Any natural or legal person that supplies the manufacturer with packaging or packaging material. The supplier's obligations consist of providing the manufacturer with the information and documentation needed to demonstrate compliance with Articles 5-12 of PPWR. The line between supplier and manufacturer can be thin - which is why, in contractual models, you need to analyse the relationships between the parties.

Manufacturer vs EPR producer - why you should not confuse them

This is one of the most important distinctions in all of PPWR - and at the same time the most common source of confusion.

"Manufacturer" and "producer" are two separate concepts under PPWR:

• The manufacturer is responsible, in principle, for the packaging's compliance: the conformity assessment, the technical documentation and the declaration of conformity.
• The producer is a concept from the extended producer responsibility (EPR) layer. The producer may be the manufacturer, the importer or the distributor - provided it meets certain conditions. It is this classification that determines the registration, reporting and waste-management financing obligations.

In short: a company can be the manufacturer (for packaging compliance) and at the same time the producer (for EPR) - or play only one of these roles. These are two separate regimes. Compliance with one does not automatically mean compliance with the other (in Poland, EPR obligations are handled, among other things, through the BDO database).

When does an importer or distributor become a manufacturer?

Roles under PPWR are not watertight. An importer or distributor takes over the manufacturer's obligations when it:

• places packaging on the market under its own name or trademark, or
• modifies packaging already placed on the market in a way that may affect its compliance with PPWR requirements.

In other words: if your logo appears on the packaging rather than the factory producer's, you are most likely the manufacturer, with all the documentation obligations - even if formally you only import or distribute.

Can one company play several roles under PPWR?

Yes - and it is very common. This is a typical situation with own brands, imports from outside the EU and cross-border e-commerce models. A producer may at the same time be an importer of components, and a distributor may be the manufacturer of grouped packaging under its own logo.

In such a mixed model the obligations stack up, which is why precisely mapping all roles - separately for each stream of packaging - is key to correctly determining the scope of responsibility.

You can get an initial sense by answering five questions:

1. Do you design packaging, or commission its production, under your own brand? -> probably a manufacturer
2. Do you import a product or packaging from a country outside the EU? -> probably an importer
3. Do you merely make the product available further down the chain (wholesaler, retailer)? -> probably a distributor
4. Do you run online sales under your own brand? -> most often a manufacturer + EPR obligations
5. Do you provide warehousing, packing and shipping as a 3PL / fulfilment provider? -> a mixed role that requires analysis

How to determine your role under PPWR? Take the quiz

The definitions sound simple, but in practice the line between manufacturer and supplier can be thin, one company combines several roles, and the classification depends on the specific packaging, the product's origin, the brand and the way it is placed on the market.

Instead of reading the regulation article by article, answer a few questions about your business model - the quiz walks you through the logic of PPWR and indicates:

• your role (or roles) in the packaging supply chain
• whether you are also a producer for EPR purposes
• the key obligations and nearest deadlines
• what to prepare first, before 12 August 2026

You start the quiz without a form - you get the basic result straight away.

Check your role and obligations ->

2 minutes - free - instant result

Want a full checklist of obligations, documents and data to collect, plus a plan for getting ready by 12 August? We will send it to your business e-mail - all we need is your address and company name.

What to do after you get your result?

Determining your role is the first step. The next ones - regardless of whether you are a manufacturer, importer or distributor - are:

• a packaging audit - an inventory of all types (unit, grouped, transport, shipping), their material composition and annual volume
• collecting documentation from suppliers - specifications, declarations, material data (PCR recyclate, PFAS, heavy metals)
• preparing the declaration of conformity (DoC) and the technical documentation (TD)
• putting your EPR obligations in order - remember this is a separate regime from packaging compliance
• a compliance-gap assessment - recyclability, labelling, over-packaging, recyclate content

Do you have hundreds of products or suppliers? Plan Be Eco automates this entire process in one module: from collecting data from suppliers, through validating Article 5 requirements, to generating and signing the declaration of conformity. No spreadsheets and no manual deadline tracking.

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FAQ - PPWR and your role in the supply chain

What is PPWR and when does it start to apply?

PPWR is Regulation (EU) 2025/40 on packaging and packaging waste, which replaces Directive 94/62/EC. It entered into force on 11 February 2025, and its provisions will, as a rule, apply directly in all EU Member States from 12 August 2026. As a regulation, it does not require transposition into national law.

How do I determine my role under PPWR?

You need to analyse your company's actual function in relation to a specific packaging item - whether you manufacture or commission the manufacture of packaging under your own brand (manufacturer), place packaging from outside the EU on the market (importer), or merely make it available further down the chain (distributor). The fastest way is to take our free PPWR quiz, which asks the right questions and points to your role together with its obligations.

What is the difference between a manufacturer and a producer under PPWR?

They are two separate concepts. The manufacturer is responsible for the packaging's compliance - the conformity assessment, the technical documentation and the declaration of conformity. The producer is a concept from the extended producer responsibility (EPR) layer; the producer may be a manufacturer, importer or distributor that meets certain conditions. A company can play both roles at once or just one of them.

Does a small company (SME) fall under PPWR?

Yes. PPWR contains no automatic exemptions for micro-enterprises or small companies. The scope of obligations depends on your role in the supply chain, not on company size. SMEs will most often feel PPWR through the requirements of their business partners (retail chains and large B2B buyers will demand declarations of conformity) and through the need to document packaging composition.

When does an importer or distributor become a manufacturer?

An importer or distributor takes over the manufacturer's obligations when it places packaging on the market under its own name or trademark, or when it modifies already-placed packaging in a way that may affect its compliance. If your logo appears on the packaging rather than the factory producer's, you are most likely the manufacturer.

Can one company have several roles under PPWR?

Yes, and it is common - especially in e-commerce, with own brands, imports from outside the EU and cross-border models. A role is determined for a specific stream of packaging, so the same company can be a manufacturer, importer and distributor at the same time. The obligations then stack up.

Who issues the declaration of conformity (DoC) for packaging?

The EU declaration of conformity is issued by the manufacturer (Article 39 + Annex VIII of PPWR), after carrying out the conformity assessment and drawing up the technical documentation (Annex VII). Importers and distributors are obliged to verify that the manufacturer has met these obligations before they make the packaging available on the market.

Are PPWR and EPR obligations (in Poland, among others, BDO) the same thing?

No. PPWR (packaging compliance) and EPR (registration, reporting, waste-management financing) are two separate regimes. Compliance with PPWR does not release you from EPR obligations - and vice versa. Both tracks must be run in parallel.

How long does it take to prepare for PPWR?

It is a process, not a one-off action: from auditing roles and packaging, through collecting data from suppliers, to implementing purchasing and reporting procedures. The sooner a company identifies its role and starts collecting data, the less costly and less rushed the adjustment will be ahead of 12 August 2026.

The above content is for educational and informational purposes only. It does not constitute legal advice or a legal opinion and may not be relied upon as the basis for decisions in an individual case. Classifying your role under PPWR depends on the specific facts - if in doubt, consult a legal adviser or a compliance specialist.

Plan Be Eco is a Polish SaaS platform for ESG and EU-regulation compliance, with a PPWR module that guides you through the full compliance path - from supplier data to a signed declaration of conformity.

Check your role under PPWR - take the quiz ->