The European Commission has released long `awaited guidance and a Q&A document on the Packaging and Packaging Waste Regulation (PPWR), offering additional clarity for businesses ahead of its entry into force on 12 August. While non-binding, the approximately 55-page documents are intended to support interpretation of the regulation, which aims to advance the circular economy and reduce packaging waste across the EU.
A key area of focus is the distinction between “producers” and “manufacturers,” a topic that has raised significant questions for private label manufacturers and retailers. The Commission’s guidance confirms that the definition of “manufacturer” is not based solely on who physically produces packaging. Instead, it depends on a company’s role in designing and specifying packaging, as well as whose brand or name appears on it.
For retailers with private label products, this interpretation has important implications. In many cases, retailers will be considered both producer and manufacturer under the PPWR. As a result, they will be subject to pay extended producer responsibility (EPR) contributions and issuing declarations of conformity.
Industry stakeholders have broadly welcomed the guidance as a step toward greater legal certainty, though some ambiguity remains. The clarification of roles across the value chain is seen as especially relevant for aligning responsibilities between brand owners, manufacturers, and retailers.
However, industry associations caution that the guidance does not resolve all operational and financial challenges posed by the PPWR. Companies newly classified as manufacturers from August 2026 onward are urged to fully comply with their obligations. For private label stakeholders, the message is clear: reassess roles, ensure compliance readiness, and prepare for increased accountability in packaging design and lifecycle management.