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How are Packaging, Manufacturer and supplier defined in PPWR?

Many teams get stuck on PPWR because they unconsciously apply an old mental model: packaging compliance sits at the level of packaging materials and is therefore something the packaging supplier can fully own. PPWR works differently.

This leads to a common misconception: “If each supplier gives us a PPWR DoC for their component, we are done.” Supplier declarations help, but they do not replace the PPWR Declaration of Conformity for the packaging that is placed on the market. (see also FAQ on PPWR)

Packaging (PPWR)

  • Packaging is the complete packaging setup used to contain, protect, handle, deliver or present a product.

  • In practice, packaging is the combination of all packaging elements that together form the packaging for a sales unit or logistics unit, for example bottle plus cap plus label, or tray plus film, or carton plus inserts.

  • PPWR compliance is assessed for the packaging as a whole (the total packaging system and its packaging level, like sales, grouped, or transport packaging), not only per individual packaging component.

  • One packaging system can include multiple components and materials sourced from multiple suppliers, but the manufacturer remains responsible for the overall PPWR compliance and the Declaration of Conformity for that packaging type (SyncForce term: Packaging Master System).

Manufacturer (PPWR)

  • PPWR defines a manufacturer as a legal or natural person that manufactures packaging or a packaged product.

  • For finished goods companies: if you sell finished goods under your own brand, you typically have the packaged product manufactured under your name or trademark, which makes you the PPWR manufacturer for that packaging type.

  • For private label: the retailer brand owner is often the PPWR manufacturer, because the packaged product is produced under the retailer’s name or trademark.

Supplier (PPWR)

  • PPWR defines a supplier as a party that supplies packaging or packaging material to a manufacturer.