PRODUCER

Your role in the value chain

You are considered a producer when you make packaging (empty or filled with products) available for the first time in an EU member state.

This is the case when you are for example a manufacturer of pallets or a brand owner and you sell your packaging/packaged products in the same country where you are
established.

This also applies to online retailers selling products to end users in the EU.

Your key obligations

  • Ensure that the packaging you place on the market fulfil the PPWR requirements
  • Comply with the EPR obligations:
    • Register with national producer registers in all EU countries you first make packaging available
    • Register with PRO for all those packaging
    • Report your packaging volumes
    • Pay the EPR fee to cover the collection and recycling costs
  • Selling directly to private and professional end users in other EU Member states? You must appoint a local authorised representative in each country of destination where you are not established.

How can we support you?

Due to changes in the definition of “packaging” and “producer” under PPWR, companies must reassess their obligations.

This may require new registrations in national producer registers and PROs, as well as adjustments to reporting obligations (e.g. removal of de minimis thresholds, additional packaging types in scope, …). From 2028 onwards, new harmonised data formats will apply.