Roles & responsibilities

A two-step process helps you determine if your company is considered a manufacturer or a producer under the EU Packaging and Packaging Waste Regulation (PPWR).

• Step 1: determine who the manufacturer is
  Who is responsible for the design and characteristics of the complete packaging, i.e. its conformity?

• Step 2:determine who the producer is
  Who is responsible for financing the recovery of packaging waste in the relevant EU Member State, i.e. who bears extended producer responsibility (EPR)? 

Detailed information can be found on the Distinguishing between manufacturers & producers page.

Yes. Under the EU Packaging and Packaging Waste Regulation (PPWR), manufacturers and producers have different tasks and obligations. The manufacturer is responsible for packaging conformity, while the producer bears extended producer responsibility (EPR) and is responsible for financing the recovery in the EU Member State where the packaging becomes waste.

Under the PPWR: if the manufacturer is based in the same EU Member State where the packaging becomes waste, it is also considered the producer because there is no other company further upstream in the supply chain.

Detailed information can be found on the Distinguishing between manufacturers & producers page.

The supply chain is a decisive factor when determining who is a producer pursuant to the EU Packaging and Packaging Waste Regulation (PPWR). While the same company is often both the manufacturer and the producer, that may not be the case where cross-border supply chains are involved. Depending on the specific supply chain setup, the manufacturer, the importer or the distributor can be the producer. The producer is the economic operator who initiates the supply chain in the EU Member State where the packaging eventually becomes waste.

Under the PPWR, 'manufacturer' means a company that has products designed or manufactured under its own name or trademark by third parties (i.e. 'contract manufacturing'). The commissioning companies are deemed to be manufacturers and bear responsibility for preparing the packaging's technical documentation and declaration of conformity.

Please note: it does not matter if the ordering party (retail company) legally owns the trademark. Licensees or affiliated group companies can also be manufacturers. What matters is the connection between the name or the trademark and the associated influence on the packaging. Even if the contract packager (supplier) is also listed on the packaging, it does not share responsibility and the obligations are not transferred. The same applies if the medical product's  pharmaceutical company is listed on the packaging  due to requirements under other areas of law – for example labelling obligations under medical law.

Exception: if the ordering party is a micro-enterprise (pursuant to Recommendation 2003/361/EC: fewer than ten employees and an annual turnover or balance sheet total not exceeding two million euros), the following applies: if the supplier of the packaged products is based in the same Member State, it is the manufacturer.

For the purposes of extended producer responsibility (EPR), the producer under the PPWR is either the manufacturer, importer or distributor. For own brands, the brand name defines the retail company as the manufacturer of the packaged products. As such, the retail company also bears producer responsibility for this packaging.

Yes. If you are operating commercially, there is no de minimis threshold or exemption for companies with low packaging volumes.

Preparing the declaration of conformity does not fall under the ZSVR's remit, and declarations of conformity do not have to be filed in the LUCID Packaging Register either.

The Forum Rezyklat provides materials like templates, FAQs and handouts relating to technical documentation and declarations of conformity to help meet manufacturer obligations. The German Environment Agency has also published guidelines and additional information about fulfilling manufacturer obligations in its FAQ on the topic. 

Preparing/drafting the content of the technical documentation and the declaration of conformity does not fall under the remit of the ZSVR. Therefore, we cannot provide any technical guidance or instructions in this matter.

Under the PPWR, the technical documentation is part of the conformity assessment procedure and helps the manufacturer to demonstrate that a specific unit of packaging complies with the applicable PPWR requirements. The technical documentation also forms the basis for preparing the declaration of conformity.

The technical documentation must include the information and evidence specified in Annex VII of the PPWR, for example information about the specific unit of packaging and its design, along with documentation, calculations or audit results that prove compliance with the relevant requirements. The manufacturer's obligation to prepare the technical documentation arises from Article 15 in conjunction with Article 38 and Annex VII of the PPWR. The manufacturer is responsible for preparing the technical documentation and keeping it up to date. This technical documentation must be made available to the competent authorities upon request.

The Forum Rezyklat provides practical resources on this matter, including templates, FAQs and handouts. For more information, please also refer to the German Environment Agency's FAQs (available in German only).

Authorisation procedures are proceedings by the authorities for producers of packaging that is not subject to system participation. Authorisations govern how these producers fulfil their extended producer responsibility obligations, including, in particular, taking back packaging or transferring packaging for re-use or recovery. Producers may fulfil these obligations themselves or delegate them to an oPRO (other producer responsibility organisation). The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) is responsible for authorisation. Authorisation procedures are carried out electronically via the ZSVR's systems.

Further information can be found in our knowledge base dedicated to authorisation procedures.

For packaging not subject to system participation (especially packaging from industrial or large commercial enterprises), the existing return obligations and the obligation to transfer this packaging for re-use or recovery continue to apply.

What is new is that market participants who use such packaging to make their products available on the market will also need an authorisation by the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR). The same applies to other producer responsibility organisations (oPRO) that take back and recover this packaging for producers. Producers may fulfil their obligations themselves or delegate them to an oPRO. The new Verpackungsrecht-Durchführungsgesetz (German Packaging Law Implementation Act – VerpackDG) provides for automated, electronic implementation of authorisation procedures.

Please note: different authorisation deadlines apply. Producers/companies are allowed to make their packaging available on the German market without an authorisation until 31 December 2027. Other producer responsibility organisations (oPRO) are allowed to provide their services without an authorisation until 31 October 2027.

The ZSVR will develop the new electronic authorisation procedures and provide them by late summer / autumn 2027. Authorisation requires paying a fee.

Information about the procedures under development can be found in the knowledge base dedicated to authorisation procedures.

No. If your company is already registered with the LUCID Packaging Register, you do not need to register again. However, please check whether your details need to be amended or supplemented in line with the new requirements of the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG). This may for example concern the filed brand names, types of packaging or the appointment of an authorised representative.  

Under the EU Packaging and Packaging Waste Regulation (PPWR), packaging intended for shipment to end users is deemed to be e-commerce packaging if it is used for online sales or other means of distance selling. It is categorised as transport packaging. It includes shipping boxes and envelopes, as well as other packaging materials used for shipping, such as adhesive tape and filler material like plastic films, flakes or wrapping tissue.

Please note: packaging intended for shipment is always subject to system participation, without exception. 

Detailed information can be found in the knowledge base dedicated to mail order companies & online retailers.

With the application of the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG), the responsibilities relating to service packaging will also change. Going forward, companies need to check who is considered the manufacturer and who is considered the producer for the service packaging in question. What's more: in most cases, it will no longer be possible to transfer system participation to an upstream distributor by purchasing pre-participated service packaging. 

The knowledge base dedicated to service packaging provides information about the rules that apply to your service packaging.