Stakeholders and obligations under the PPWR: producers, manufacturers, distributors, suppliers
Stakeholders and responsibilities: Who bears which responsibilities within the PPWR?
The PPWR sets out, in a uniform manner across the EU, who is responsible for which obligations. It clearly distinguishes between the terms ‘producer’, ‘manufacturer’, ‘retailer/distributor’ and ‘supplier’.
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, traders, suppliers: who does what?
- Who is this? The manufacturer is the party who makes the final decision on the design and specifications of the packaging. 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 with labelling obligations.
- Drawing up 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.
- Who is this? The manufacturer (as defined in the PPWR) is the person who first places a filled package on the market 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.
- Who is this? A business that resells packaged products, for example in shops or via online stores.
- Your obligations as a distributor:
- Verification obligations: You must check that the goods you sell are correctly registered and labelled.
- Return obligations, where applicable.
- Important note: If , as a distributor, you market packaging under your own brand name or alter its conformity, you automatically become a manufacturer as well, with all the associated obligations!
- Who is this? The supplier delivers packaging or packaging materials to the manufacturer. In the case of corrugated cardboard packaging, this is often the packaging manufacturer, such as Klingele.
- Your responsibilities as a supplier:
- Providing the technical information and evidence required for PPWR compliance.
- Providing data on material composition, recyclability and other relevant packaging properties.
- Supporting the producer in preparing the technical documentation.
- Collaborating with downstream players in the supply chain on issues relating to packaging compliance.
- For Klingele customers:
Klingele generally assumes the role of supplier. We provide you with the necessary information and documents so that you can fulfil your obligations as a producer.
Obligations as a producer – what you specifically need to do as of 12 August 2026
As a manufacturer, you are usually responsible for ensuring that ‘your’ packaging complies with the PPWR. A key element of this is the declaration of conformity, which will be required as of 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 was issued for.
What must you keep on file, and for how long?
- The declaration of conformity and the accompanying 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 compile your technical documentation.
- Your responsibility as a manufacturer is to use this to complete your documentation and to draw up and retain 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 1: The standard option – you fill our packaging
- Scenario: You order flat-pack packaging (e.g. a folding box) from Klingele, made to your specifications. You assemble it, fill it with your product and sell the unit to your end customer.
- Your role: You are the manufacturer.
- Klingele’s role: Klingele is the supplier.
- Reasoning: According to the PPWR, the decisive factor is who makes the final decision on the design and who uses the packaging – and in this case, that is you.
- Conclusion: This scenario applies to the vast majority of our customer relationships.
- Important exception: Simplified rules apply to micro-enterprises (fewer than 10 employees and an annual turnover of less than €2 million). Please get in touch with us!
Case 2: The retailer – you specify the packaging
- Scenario: 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.
- Your role: You are the producer.
- Klingele’s role: Klingele is the supplier who manufactures the packaging to your specifications.
- Reasoning: As you define the key characteristics of the packaging, you are regarded as the one who designed it.
- Conclusion: Even as a retailer with a private label or specific packaging requirements, you are in the role of the manufacturer.
Case 3: The distinction – rigid packaging
- Scenario: A company purchases rigid but empty packaging, such as bottles or cans, from a manufacturer, in order to fill and label them.
- Parties involved: In this case, the manufacturer of the empty bottle is already the producer of the primary packaging. The company that fills the packaging becomes the ‘manufacturer’ (first place on the market).
- Reasoning: The packaging already has its final, unalterable shape.
- Conclusion: This example illustrates why our flat-packed packaging is assessed differently and why Klingele is not, as a rule, the producer.
We will guide you through the process of ensuring your products are packaged in accordance with PPWR.
Please feel free to get in touch with us.
Newsletter "Packendes"
Curious about packaging and company news? Subscribe to the Klingele newsletter "Packendes" and stay informed - directly in your mailbox!
