- PPWR plays several roles along the supply chain
- The different roles of the PPWR
- Why Producers and Manufacturers Are Central to Many Companies
- The Manufacturer: Your Responsibility for the Packaging Itself
- The Manufacturer: Your Responsibility for Placing the Product on the Market
- Quantity Reports: How ERP Systems Can Help
- The other roles are also relevant in practice
- Many companies take on multiple roles at the same time
- Our conclusion: Those who understand their role can effectively fulfill their PPWR obligations
Responsibilities in the PPWR – Why You Should Know Exactly What Your Role Is in the Supply Chain Right Now
With the PPWR, the EU is redistributing responsibility for packaging throughout the entire supply chain. For companies, this means that in the future, it will no longer be enough to simply know in general terms that they are affected. Rather, what matters is the specific role in which they are affected. The regulation identifies several economic operators, including producers, manufacturers, importers, distributors, fulfillment service providers, and authorized representatives. However, the roles of producer and manufacturer are particularly relevant for many companies, as these roles encompass the key obligations related to compliance, registration, and participation in the system.
PPWR plays several roles along the supply chain
The PPWR is changing packaging compliance not only in terms of content but also structurally. The regulation distinguishes between different economic operators and assigns specific obligations to each. For you, this means that determining whether you are affected by the PPWR is only the first step. The second and decisive step is identifying your specific role.
This is so important in practice because, going forward, obligations will no longer arise solely from the general act of placing packaging on the market, but rather from your specific function within the supply chain. Among other things, the following factors are therefore decisive:
- anyone who manufactures packaging or has it manufactured
- under whose name or brand packaging is placed on the market
- who initiates the supply chain in a Member State
- which companies are involved in importing, distribution, or fulfillment
This makes it clear that the PPWR no longer treats packaging compliance merely as a downstream reporting requirement, but rather as the interplay of multiple responsibilities across the entire life cycle and throughout the entire supply chain.
The different roles of the PPWR
The PPWR defines several roles that your company should at least categorize. These include, in particular:
Manufacturer
The manufacturer is the role that primarily relates to the packaging itself. This primarily concerns compliance, technical documentation, and labeling.
Manufacturer
The manufacturer is the party primarily responsible for placing the product on the market in the respective market. The focus here is particularly on registration, participation in the system, and volume reporting.
Importer This role becomes relevant when packaging or packaged products are imported into the European Union from a non-EU country.
Distributor
Distributors are companies that provide or pass on packaging or packaged products within the supply chain.
Fulfillment Service Provider This role is particularly important in e-commerce when external partners handle warehousing, packaging, or shipping processes.
Authorized Representative
An authorized representative may perform formal duties on behalf of a company in certain situations, particularly in cross-border contexts.
This overview alone shows that PPWR views responsibility not just at a single point, but across multiple stages in the market. For many companies, however, two roles in particular are especially relevant— producers and manufacturers.
Why Producers and Manufacturers Are Central to Many Companies
Although the PPWR defines several roles, in practice the focus is often on producers and manufacturers. This is because the key requirements of the regulation center on these two roles.
The producer is primarily responsible for matters related to the packaging itself.
The manufacturer is primarily responsible for matters related to placing the product on the market in the respective Member State.
This distinction is so important to you because the resulting obligations vary significantly. Misclassifying these roles not only risks uncertainty in your own processes but also gaps in operational implementation.
The Manufacturer: Your Responsibility for the Packaging Itself
You are generally considered a producer if you manufacture packaging or packaged products yourself, or have them manufactured under your own name or brand.
The decisive factor here is not necessarily who physically produces the packaging. Rather, what matters is the connection between the packaging and your name or brand. This also applies to situations in which you develop packaging or have it manufactured as part of an extended workbench arrangement.
This role is particularly relevant to you because it is directly linked to the new packaging compliance requirements. These include, in particular:
- the conformity assessment procedure
- the technical documentation
- the EU Declaration of Conformity
- the labeling of the packaging
- the retention of the relevant documents
This shifts the focus significantly forward. Packaging compliance no longer begins with registration or volume reporting, but rather with the packaging itself: its design, composition, and documentation.
There is another important point to consider: Under the PPWR, it is not each individual packaging component that counts, but rather the packaging unit. This refers to the totality of all packaging components that together form a sales unit or functional packaging. For you, this means that packaging data must be more structured, complete, and consistent than ever before.
The Manufacturer: Your Responsibility for Placing the Product on the Market
The role of the producer must be clearly distinguished from that of the manufacturer.
Put simply, you are considered a manufacturer if you enter the supply chain in the member state where the packaging will later become waste. It is precisely this logic that differs in key respects from the previous interpretation under the German Packaging Act and is therefore particularly relevant for many companies.
If you are a manufacturer, your focus is on market-related obligations. These include, in particular:
- registration in the relevant registries,
- system participation,
- the quantity reports,
- and, where applicable, other organizational obligations related to market participation and data provision.
In practice, this is particularly important for companies with:
- cross-border supply chains,
- Trading structures,
- Private-label concepts,
- or e-commerce models.
For you, this means: You should not only verify the manufacturer’s role in a formal sense, but also along your actual distribution channels. Where does packaging first become relevant in a member state? Who places it on the market there? And who is responsible for registration, participation in the system, and reporting quantities?
It is precisely at this point that it is often determined whether a company will be able to properly fulfill its PPWR obligations later on.
Quantity Reports: How ERP Systems Can Help
Under the PPWR, volume reporting is a key issue, particularly at the manufacturer level. In practice, it quickly becomes clear that what matters most is not just the reporting requirement, but above all the availability of reliable packaging data.
ERP systems can help here by integrating relevant information directly into existing processes—such as product master data, bills of materials, or shipping processes. This allows volume reports to be prepared in a more structured and consistent manner, with less manual effort.
With our lizentro app, you can automate your packaging reports directly in Business Central—simply, transparently, and in a structured way. Learn more lizentro .
The other roles are also relevant in practice
Even though producers and manufacturers are the focus for many companies, the other roles should not be underestimated. This is because, in practice, the biggest coordination and data problems often arise precisely at the interfaces of the supply chain.
For example, if you import goods, work with trading partners, use external fulfillment processes, or organize formal tasks in international settings, then importers, distributors, fulfillment service providers, and authorized representatives may very well be relevant to your PPWR implementation.
For you, this means: Even though the focus is usually on producers and manufacturers at first glance, you should always take a holistic view of your supply and distribution structure. This is because compliance is often determined not by a single role, but by the interaction of multiple parties involved.
Many companies take on multiple roles at the same time
The real challenge of PPWR lies not only in the number of roles, but in how they interact. A company can be both a producer and a manufacturer, and may also have points of contact with importers, distributors, or fulfillment service providers.
This is precisely why role assignment is not merely a legal detail, but a practical management issue affecting several areas within the company—such as product management, procurement, logistics, sales, and compliance.
For you, this means: The first step should always be to clearly define your own role. Who is responsible for the packaging itself? Who places it on the market, and in which market? What other parties are involved in the supply chain? Only on this basis can responsibilities be correctly assigned and processes be structured effectively.
Our conclusion: Those who understand their role can effectively fulfill their PPWR obligations
The PPWR does not establish a simple “one-role” model, but rather a nuanced system of responsibilities throughout the supply chain. For many companies, producers and manufacturers are rightly the focus of attention. This is precisely where the key obligations regarding compliance, documentation, labeling, registration, and participation in the system lie.
At the same time, you should not lose sight of the other roles. Importers, distributors, fulfillment service providers, and authorized representatives can play a decisive role at key points in your supply and distribution structure.
By clearly defining your role within the PPWR system early on, you lay the foundation for legally compliant processes, reliable data, and significantly clearer operational implementation.
With our lizentro app, you can fulfill your manufacturer obligations for reporting packaging in accordance with PPWR requirements. We’re happy to support you.
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About the author
Philipp Respondek · Trainee Functional Consultant
As part of my trainee program to become a Functional Consultant, I am participating in the Microsoft Upskill program and am a member of the #BCTalent community.
I have a degree in business administration and gained my first experience in product management while studying. Currently, I am primarily responsible for managing the lizentro app and am also gaining additional hands-on experience through various client projects.
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