Stakeholders and obligations under the PPWR: producers, manufacturers, distributors, suppliers
The PPWR sets out, in a uniform manner across the EU, who is responsible for which obligations. The terms ‘producer’, ‘manufacturer’, ‘distributor’ and ‘supplier’ are clearly distinguished from one another. To ensure you know exactly what responsibilities you face, we have broken down the key parties and their obligations for you. Find out which party status you hold as a Klingele customer.
Producers, manufacturers, distributors, suppliers: Who does what?
The producer: the decision-maker
Who is that?
The producer is the person who makes the final decision on the design and specifications of a package. In most cases, this is the brand owner who packages their product.Your obligations as a manufacturer:
Legal responsibility for compliance with the requirements set out in Articles 5–12 and the labelling obligations.
Preparation of the declaration of conformity for the packaging.For you as a Klingele customer:
As you have the final say on the design of the packaging for your products, you generally assume the role of the manufacturer.
The manufacturer: The first person to place the product on the market
Who is that?
The manufacturer (within the meaning of the PPWR) is the person who places a filled package on the market for the first time in an EU Member State.Your obligations as a manufacturer:
Covering the costs of collection and recovery (extended producer responsibility, or EPR for short).
Registration with the relevant national authorities.
Payment of EPR fees in the country where the packaging becomes waste.For Klingele customers:
This applies to you as soon as you sell goods packaged in our packaging in an EU country.
The distributor / dealer: The reseller
Who is that?
A company that resells packaged products, e.g. in shops or via online shops.Your obligations as a distributor:
Verification obligations: You must check that the goods you sell are correctly registered and labelled.
Return obligations may apply.
Important note: If, as a distributor, you market packaging under your own brand name or alter its conformity, you automatically become a producer as well, with all the associated obligations!
The Supplier: The Information Provider
- Who is this?: Supplies packaging or packaging materials to the manufacturer (e.g., Klingele).
- Three main obligations:
- Providing technical documentation and material data
- Sharing information on material composition and recyclability
- Supporting the producer with technical documentation
Klingele Note: Klingele acts as the supplier. We provide you with all the data you need to fulfill your obligations as a producer.
Obligations as a producer – what you specifically need to do from 12 August 2026 onwards
As a manufacturer, you are usually responsible for ensuring that ‘your’ packaging complies with the PPWR. A key element is the declaration of conformity, which will be required from 12 August 2026.
What’s new?
- You must issue a written declaration of conformity for each type of packaging.
- The declaration must clearly state which packaging it relates to.
What must you keep on file, and for how long?
- The declaration of conformity and the associated technical documentation must be made available to national authorities.
- Retention period: five years after placing on the market for single-use packaging, ten years for reusable packaging.
What does Klingele provide, and what is your role?
- Klingele supports you by providing the necessary information and documents so that you can draw up your technical documentation.
- Your responsibility as a manufacturer is to use this to complete your documentation and to draw up and keep the Declaration of Conformity.
Key players in practice – your case study
Theory is one thing, but practice is what really counts. We have analysed the most common scenarios faced by our clients to show you what roles and responsibilities this entails for you.
| Case | Scenario | You as a party | Klingele as a party | Reason | Conclusion | |
|---|---|---|---|---|---|---|
| 1. | The standard – you fill our packaging | You order flat-pack packaging (e.g. a folding carton) from Klingele, made to your specifications. You assemble it, fill it with your product and sell the unit to your end customer. | You are the manufacturer. | Klingele is the supplier. | According to the PPWR, what matters is who makes the final decision on the design and who uses the packaging – and in this case, that is you. | This scenario applies to the vast majority of our customer relationships. |
| 2. | The retailer – you specify the packaging | You are a retailer (e.g. an online shop) and order packaging for your products from Klingele. In doing so, you specify the exact requirements (dimensions, type of corrugated board, design, etc.). It does not matter whether the packaging is plain or bears your retailer’s logo. | You are the producer. | Klingele is the supplier who manufactures according to your specifications. | As you define the key characteristics of the packaging, you are regarded as the one who has designed it. | Even as a retailer with your own brand or specific packaging requirements, you are in the role of the manufacturer. |
| 3. | The distinction – rigid packaging | A company purchases rigid but empty packaging, such as bottles or tins, from a manufacturer, and then fills and labels it. | In this case, the producer of the empty bottle is already the manufacturer of the primary packaging. The company that fills the packaging becomes the ‘manufacturer’ (first distributor). | - | The packaging already has its final, unalterable shape. | This example illustrates why our flat-packed packaging is assessed differently and why Klingele is generally not considered the producer. |
Contact
We will guide you through the process of packaging your products in compliance with the PPWR.
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