Who does PPWR apply to?

PPWR assigns roles by what you do, not by what you call yourself, and one company routinely holds several at once. The duties attached to each are different, and two of them catch people out.

The first is Article 21: put your own name or trademark on packaging someone else made, or modify a pack already on the market, and you become its manufacturer — with the technical file, the declaration and the liability. The second is the gap between manufacturer and producer. A manufacturer makes the packaging or markets it under its own name; a producer is whoever first makes it available inside a given Member State, and that is the role that triggers registration and extended producer responsibility. A non-EU manufacturer is usually the first without being the second.