Manufacturer and producer role for retailers’ own brands: EUNR's legal interpretation confirmed
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The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) had made reference – including in its 16 April 2026 press release – to the uniform legal interpretation in the European National Registers (EUNR) network. Their view is that, once the EU Packaging and Packaging Waste Regulation (PPWR) begins applying, the producer status for packaging of own brands and imported third-party brands without a domestic intermediary retailer will lie with the retail company.
The Federal Ministry for the Environment (BMUKN) enquired about the EU Commission's guidelines and the 'manufacturer' definition included therein. The BMUKN received an answer on 16 June 2026. This answer contained e.g. the following explanatory information as a practical example which illustrates the EU Commission's official guidelines:
“When [HANDELSUNTERNEHMEN] sells [MARKENPRODUKT/DRITTMARKE], then [MARKENHERSTELLER] is deemed to be the manufacturer. When [HANDELSUNTERNEHMEN] sells its own brand, [HANDELSEIGENMARKE], then [HANDELSUNTERNEHMEN] is deemed to be the manufacturer, even if the filler is different than [HANDELSUNTERNEHMEN], maybe it is even [MARKENHERSTELLER] that packages a variety of [PRODUKT] for [HANDELSUNTERNEHMEN] only under the brand [HANDELSEIGENMARKE].”
Publication of this legal interpretation was also agreed with the BMUKN and the German Environment Agency (UBA).