Do we need to set the Manufacturer (Legal Declarant) manually when it cannot be derived from the brand?

A recurring request is to specify the Legal Declarant manually at product level, because the manufacturer seems impossible to derive from the brand in a meaningful share of the portfolio. The reasoning usually cites two cases: private label, where the retailer does not consider itself the manufacturer, and contract manufacturing, where one company physically produces goods sold under another company's brand. The concern is that without a manual field a correct Declaration of Conformity (DoC) cannot be generated for a large part of the assortment.

Short answer: a manual override is not needed, and it should not be built. Under PPWR the manufacturer is always the owner of the brand under which the product is placed on the market, and that is exactly what the SyncForce model already records. The Legal Declarant is therefore derivable for every product. The situations that look like exceptions are not declarant problems; they are on-pack labeling questions with a clear policy.

The SyncForce model

Compliance is built on the data the portfolio already lives in, so there is no second tool and no out-of-sync copy to maintain.

A Sales Unit (GTIN) carries a Brand. The Brand is owned by a Legal Entity, and that Legal Entity is the Manufacturer, which becomes the Legal Declarant on the DoC. In parallel, each Sales Unit has a BOM of Packaging Components, every Packaging Component belongs to a Packaging Master, and the unique combination of Packaging Masters forms a Packaging System. Packaging Systems are detected automatically from the BOM keys. The DoC and technical dossier are managed at Packaging System level and combined with the Legal Declarant that comes from the brand.

Benefits of this model:

• The Brand is mandatory on every Sales Unit, and every Brand resolves to a single owning Legal Entity, so the Legal Declarant is always available. The derivation is complete by design, not dependent on optional data.
• One Legal Entity can own many brands. This holds for manufacturer groups such as Unilever or Heineken and equally for a retailer that owns several private brands.
• Packaging Systems are detected and reused automatically, so one compliance object serves all Sales Units that share the same packaging.
• The Legal Declarant is enforced by construction, which keeps every generated DoC aligned with the legal definition.

Why the manufacturer can always be derived

PPWR Article 3(1)(13)(a) defines the manufacturer as the party that has the product designed or manufactured under its own name or trademark, regardless of any other trademark visible on the pack. The Commission guidance adds that the manufacturer is not necessarily the party that physically produces the packaging, and that there is only one manufacturer per supply chain. In other words, the manufacturer is the brand owner, which is the value the Brand to Owner link already provides.

The two situations that look like exceptions

Private label. A retailer sells a product under its own private brand. Under Article 3(1)(13)(a) the retailer is the manufacturer, because the product is placed on the market under its own trademark. The retailer's own view that it is not the manufacturer has no legal effect. In the model the private brand resolves to the retailer's Legal Entity, so the declarant is correct without any manual action.

Contract manufacturing within a group (Division A produces under Division B's brand). Division A physically manufactures products that are placed on the market under the brand of Division B. The manufacturer is Division B, the brand owner. Division A is a supplier in the sense of Article 16 and cannot also be the legal declarant while the product carries Division B's brand. The fact that both belong to the same group does not change this, because the test is the trademark, not corporate affiliation or which entity runs the production line. If a product were ever sold under Division A's own brand, the same link would correctly resolve the declarant to Division A.

The real issue: the address printed on pack

In both situations the legal declarant is known. What has sometimes differed is a legacy practice of printing the contract manufacturer's contact address on a pack that otherwise carries the brand owner's private-label style. That is a labeling matter, not a declarant matter. Article 15(6) requires the manufacturer's own name or trademark and contact address to appear on the pack, so an on-pack address showing only the contract manufacturer already deviates from Article 15(6), independently of the DoC. Making the DoC match that incorrect address would only extend the error to the binding declaration, contrary to Article 39(4) and the accuracy control authorities perform under Article 39(5). The correct resolution keeps the DoC based on the brand owner and corrects the pack at the next artwork revision.

This is also why a per-product manual override of the Manufacturer is not offered. Such a control would let a user assign the producer to a brand-owner's product and would systematically generate DoCs naming the wrong legal entity. Deriving the Legal Declarant from Brand to Owner keeps the declaration compliant by construction.

Advised actions

• Keep the Legal Declarant derived from Brand to Owner (Legal Entity) for all products, including private label and contract manufacturing. No manual override.
• Align with the customer on the manufacturer address in the DoC (the brand owner), and jointly accept that, for existing packs, the on-pack contact address may not yet match the DoC. Record this as a known, temporary deviation.
• Correct the on-pack address to the legal manufacturer at the next artwork or label revision, for packs that currently show a contract manufacturer address.
• Standardize the artwork input: set up the Sales Unit in SAP/SyncForce, take the Manufacturer address from SyncForce, and provide it to the Artwork Team or Agency for every new or revised pack.

Rationale: the historic mismatch is accepted because it cannot be corrected retroactively, and a defined process now updates the address the moment a pack is revised. This keeps the DoC correct today and prevents misaligned labeling on future packs.

EU PPWR Regulation (EU) 2025/40: Article 3(1)(13), Article 15(6), Article 16, Article 39(4) and (5), Annex VIII. Commission PPWR Guideline and PPWR FAQ.