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How to override the Legal Declarant (Manufacturer) on a private label Sales Unit

Several retailers have written to their suppliers that they expect the supplier to be the packaging manufacturer under PPWR, and not the retailer.

The final PPWR rules for private label are not clear on this point yet. To help you act now, SyncForce lets you override the Legal Declarant on a private label Sales Unit with one of your own Legal Declarants.

How the Legal Declarant is normally set

In SyncForce every brand is linked to a brand owner. The brand owner of the brand on a Sales Unit automatically becomes the Legal Declarant (Manufacturer) used in the Declaration of Conformity.

You manage this link in the Settings Manager: you set the manufacturer on the brand, and one manufacturer can be linked to many brands.

Why private label is different

A private label Packaging System usually looks like this:

  • one Packaging System
  • with one or more Sales Units
  • from one or more brands
  • and those brands can belong to different brand owners, for example Rewe, Edeka, Aldi and Lidl

Because the Legal Declarant follows the brand owner, one Packaging System can lead to several Declarations of Conformity, one per brand owner. Inside the Packaging System your Sales Units are grouped per manufacturer, so you can see which Declaration of Conformity each Sales Unit belongs to.

What the Override does

The Override lets you replace the brand owner as Legal Declarant for one specific Sales Unit. When you set an override:

  • the Sales Unit uses one of your own Legal Declarants instead of the private label brand owner
  • the Declaration of Conformity for that Sales Unit is made in your own name
  • the other Sales Units in the same Packaging System are not affected, they keep their own brand owner
  • the grouping per manufacturer in the Packaging System follows the override

How to set an override

  1. Open the private label Sales Unit.
  2. Go to the Packaging tab.
  3. In Packaging System details, find the Manufacturer.
  4. Click Override next to the manufacturer name.
  5. Select one of your own Legal Declarants and confirm.

The manufacturer shown on the Sales Unit now changes to the Legal Declarant you selected.

How to remove an override

The override is a temporary answer while we wait for the final PPWR rules for private label. If the rules end up saying something else, you can simply remove it.

When you remove the override, the Sales Unit goes back to the brand owner of the private label brand, and the Declaration of Conformity follows that brand owner again. Nothing else in the packaging data changes.

Good to know
  • The override works per Sales Unit, not per Packaging System and not per brand.
  • You can only select Legal Declarants that are already set up in your own account. Add or edit them in the Settings Manager first.
  • Use the override only when you have agreed with the retailer that you act as the manufacturer under PPWR. The retailer letter you received is usually the basis for this.
  • If the final PPWR rules for private label change, review your overrides. SyncForce may remove the override function at that moment, after which every private label Sales Unit follows its brand owner again.

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