PPWR Role Navigator

Please complete this assessment once per packaging level: sales packaging, grouped packaging, transport packaging, and service / e-commerce / takeaway packaging. Your roles may differ between levels.

PPWR role decision tree: identify your roles under the Packaging and Packaging Waste Regulation

Question 1

Who filled or assembled the packaging system you are assessing?

The PPWR definition of "manufacturer" turns on who specified the finished packaging system, not who physically filled or assembled it. Choose the option that best describes your role for this packaging level. The difference between options 2 and 4: option 2 is where you commission a filling or assembly service. The supplier works to your process instructions and delivers a service. Option 4 is where you purchase a finished packaged product. The transaction is a product purchase, whether under your own brand (private label) or another company's brand.
Disclaimer

The PPWR Navigator is developed by and for the packaging industry community as a practical orientation tool. It is based on Regulation (EU) 2025/40 (PPWR) and available Commission guidance at the time of publication, but it does not constitute legal advice and should not be relied upon as a definitive compliance determination for your specific situation.

Packaging classification and producer role identification under PPWR depend on the precise facts of each case. Some provisions of the regulation are subject to implementing acts and Commission guidelines that are still in development. Classifications may change as further guidance becomes available.

SyncForce accepts no liability for decisions made on the basis of the outcomes produced by this tool. We strongly recommend verifying your classification with a qualified legal or compliance adviser before taking compliance or reporting actions.

We welcome corrections, additions and feedback from the community. If you believe something in this Navigator is incorrect or incomplete, please contact us at letssync@syncforce.com.

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