Who is which role under the PPWR — and what do you need to do?
Manufacturer, importer, distributor, producer: the PPWR gives almost every link in the chain its own role, with its own obligations. One company can even hold several roles, depending on the country and the type of packaging. This overview shows who does what.
Product rules and waste rules are two separate systems
The PPWR regulates two things that get confused constantly. First: is this packaging even allowed on the European market, given its design, material and recyclability? That's the world of the manufacturer, supplier, importer and distributor. Second: who pays for the packaging once it becomes waste, and in which country? That's the role of the producer — a separate role with its own definition, determined afresh per country, and not automatically the same party as the manufacturer.
Who: manufacturer, supplier, importer, distributor, final distributor. Question: is this packaging allowed on the European market? Applies EU-wide — one manufacturer per packaging.
Who: the producer, potentially via an authorized representative or producer responsibility organisation. Question: who registers and pays, and in which country? Applies per Member State — one producer per country per packaging.
The chain, step by step
This is a simplified view of the product-compliance side of the PPWR: who holds which role in the physical chain. The "producer" role is deliberately left out of this chain, because it follows from a different question — see below.
Who is the producer? Three questions decide it
"Producer" isn't a position in the chain above — it's a role determined afresh per country, based on where the packaging ultimately becomes waste. That can be the manufacturer, but also the importer, the distributor, or even a web shop.
- 01Is the manufacturer of the packaging established in the country where the packaging becomes waste? Then the manufacturer is the producer.
- 02No — is there another company in that country that makes the packaging available for the first time, such as an importer or distributor? Then that company is the producer.
- 03No — does a web shop sell directly to an end user in that country, including a business end user? Then that seller is the producer.
This is a simplified version of the European Commission's official decision tree. The point: sell cross-border, directly to a business customer that doesn't resell? You can already be the producer in that country — even where that wasn't previously the case.
Two roles specific to e-commerce
These two roles can appear at any point in the chain, especially with online sales. The Netherlands had no comparable obligation for either before the PPWR.
Must check, before a seller is allowed to offer products, whether that seller is registered as a producer and self-certifies it. Doesn't apply to micro and small platforms.
Handles at least two of: warehousing, packing, addressing, dispatching for a seller — without owning the goods. Must run the same registration check, and suspend the service for a seller found not to comply. Unpacks the goods itself? Then it becomes the producer.
How this relates to the waste management contribution
The Dutch Besluit beheer verpakkingen 2014 hasn't been updated for the PPWR yet, and still refers to the older, repealed European directive. Yet the PPWR has applied directly since 12 August 2026, even where that creates friction with current practice at Verpact.
- The existing 50,000 kg threshold for registration and reporting sits uneasily alongside the PPWR, which requires registration without a threshold.
- Sell directly to a foreign business customer that doesn't resell? You can already be the producer in that country, even where that wasn't previously the case.
- Online platforms and fulfilment service providers had no comparable obligation in the Netherlands before; under the PPWR they do.
Registering as a producer has been mandatory since 12 August 2026, but the exact, harmonized shape of the European register of producers still depends on implementing rules that haven't been finalized. Until then, existing reporting through Verpact continues.
Note: there's a European proposal to suspend the requirement to appoint an authorized representative for EPR (for producers based outside the EU) until 2035. That's not final yet. Packstract keeps an eye on this for you.
Selling into other EU countries too? Supervision, EPR registration, and things like deposit return schemes differ per country. See the overview of PPWR differences by country.
Do you already know which role applies to you?
Every role calls for different packaging data and different next steps. Request the free scan, and Packstract maps out which role — and which obligations — apply to you.