Who must comply
Overview
PPWR obligations do not attach to an industry or a product list. They attach to roles, and your roles follow from what your company actually does with packaging. One company can hold several roles at once, and the same company can hold different roles in different member states. This page explains the roles and the logic kolum uses when it evaluates them in the applicability check.
The roles
| Role | Who it is | Typical obligations |
|---|---|---|
| Manufacturer | The company that manufactures packaging or a packaged product under its own name or trademark, or has it designed or manufactured and markets it under its own name. | Packaging conformity, technical documentation, Declaration of Conformity, marking and labelling. |
| Importer | The company that places packaging or packaged products from a third country on the EU market. | Verifying conformity and documentation before placing on the market, plus the obligations that follow from being the first to place the packaging on the EU market. |
| Distributor | A company in the supply chain, other than the manufacturer or importer, that makes packaging or packaged products available on the market. | Due care duties: checking that required markings and documentation are present before passing goods on. |
| Producer (per member state) | The company responsible in a given member state for the packaging it supplies there, which is the anchor for registration and extended producer responsibility. | Registration in each relevant member state, EPR contributions, appointing an authorised representative for EPR where required, and reporting. |
Watch out for the role fictions
Two patterns catch companies by surprise, and both come from the definitions in Article 3 and the operator rules around Article 21:
- Own-brand fiction. If you sell a packaged product under your own name or trademark, you can count as its manufacturer even though a contract partner physically produced it.
- Import fiction. If you bring packaged products into the EU, you take over manufacturer-like responsibilities for that packaging, because you are the first to place it on the EU market.
How this works in kolum
The Applicability section of the PPWR module runs this evaluation per company. You answer a set of questions about each company's activities, and kolum derives whether PPWR applies, which roles the company holds, and the resulting obligation programme, from packaging conformity and technical documentation to registration and EPR per member state. Your activities determine your roles, your roles determine your duty programme, your countries determine registration and EPR, and your packaging categories determine which later waves (2028 to 2030) hit you.
ℹ️ Regulatory context. The role definitions sit in Article 3 of the regulation, the economic-operator obligations in Chapter IV (Articles 15 and following), and registration and extended producer responsibility in Chapter VIII (Articles 44 and 45). See Regulation (EU) 2025/40.