Packaging EPR under PPWR: producer vs manufacturer

The EU's Packaging and Packaging Waste Regulation (PPWR) introduces a distinction that is easy to miss: the same company can hold two different legal roles for the same packaging. One role is about product compliance, the other about financing waste management. This article explains how the compliance-focused "manufacturer" differs from the EPR "producer" — and what that means for companies selling across several EU member states.

PPWR is not ESPR

An important caveat first: PPWR is not the same as ESPR, and it does not create a Digital Product Passport (DPP). It is a separate instrument, Regulation (EU) 2025/40, governing packaging design, recyclability and packaging-waste obligations.

The purpose of PPWR differs from that of ESPR. ESPR focuses on ecodesign and the product passport, whereas PPWR regulates packaging — from its design, through recyclability, to the management of packaging waste. Both acts may touch the same goods, but they do so from different angles. We go deeper in PPWR and digital packaging marking.

Two roles: manufacturer and producer

PPWR separates two responsibilities that everyday language often blurs into a single word:

• Manufacturer — responsible for the compliance of the packaging and product with the regulation's requirements, such as design rules, labelling and documentation.
• Producer — responsible for the financing of packaging-waste management under extended producer responsibility (EPR).

The crucial point is that these need not be the same entity. The company that designs the packaging may be responsible for its compliance, while the duty to finance waste management sits with a different party that places the goods on a given national market.

Who is who in practice

Consider an example: a clothing brand may design packaging that meets the requirements (the manufacturer role), yet a local distributor placing the product on a national market takes on the duty to finance the resulting waste (the producer role). The same shipment therefore creates two different responsibilities, on two different sides.

For this reason you should not assume that "producer" always means the same company in both senses. Separating the roles has real contractual and financial consequences, and getting it wrong can leave an obligation unassigned.

EPR operates at national level

The second essential point: extended producer responsibility (EPR) stays tied to national registries. There is no single, EU-wide EPR number that applies across the whole Union.

In practice, the registration obligation arises separately in each member state where a company places packaging on the market. Every country runs its own register, with its own fees and its own reporting rules. This follows from the fact that waste-management systems are organised nationally, each with its own producer-responsibility organisations.

What this means for multi-country sales

For a company selling in several EU states, the consequences are very concrete. Instead of a single registration, you have to reckon with duplicated obligations:

1. Multiple national registrations — a separate EPR registry entry in each country of sale.
2. Different fees — rates and how they are calculated vary between states.
3. Separate reporting — reports on the mass and type of packaging filed under national rules.

The manufacturer role (compliance) can be managed more centrally, but the producer role (EPR) is by nature spread across individual markets. This distinction is worth building into your plans before you expand, so that each market has a clear party responsible for its EPR duties.

Shared infrastructure, different goals

Although PPWR and ESPR are separate regimes, they increasingly draw on the same layer: a unique identifier and a QR code placed on the packaging or product. The same carrier can lead to different data sets — packaging information under PPWR and, separately, a product passport under ESPR.

For a company this is a chance to organise data once and use it across several obligations. It does not, however, remove the need to keep the legal roles apart: the same packaging can create compliance duties on one side and waste-financing duties on the other. We cover related regimes in ESPR, batteries and CBAM.

What to keep in mind when planning

The split of roles and the national character of EPR are best captured in a simple checklist. Before you enter a new market, it is worth:

• establishing who plays the "producer" role and handles EPR registration in that country,
• gathering data on the mass, materials and purpose of the packaging placed on that market,
• checking local deadlines, fees and the EPR reporting format.

This kind of data hygiene not only simplifies registrations but also makes it easier to demonstrate packaging compliance if you are ever inspected. The earlier a company sorts this out, the fewer surprises it meets when it moves into later markets.

Key takeaways

• PPWR (Regulation (EU) 2025/40) is a separate regime — it does not create a DPP and is not the same as ESPR.
• It splits two roles: the "manufacturer" (compliance) and the "producer" (EPR waste financing).
• The two roles can sit with different entities — do not assume they are always the same company.
• EPR stays national: there is no single EU EPR number, and registration is country by country.
• Selling in several states means multiple registrations, different fees and separate reports.

See how CyfroPass helps you organise product and packaging data in one place. Visit cyfropass.pl and prepare for both PPWR and ESPR obligations.