PPWR — roles and responsibility
Who is the packaging manufacturer under PPWR
Regulation (EU) 2025/40 (PPWR) puts most obligations on one party: the packaging manufacturer. That party answers for conformity assessment, technical documentation, the EU declaration of conformity and identification of type, model and batch. In practice the manufacturer is not always the plant that die-cuts and glues the box — very often it is the pastry shop, the bakery or the brand owner ordering packaging with its own print.
What decides is not who physically produces the box, but who places it on the market under its own name or trademark — or who commissioned its design and production.
| Code | Material | Typical use |
|---|---|---|
| PAP 21 | Solid board | The material of our pastry and bakery boxes — referenced in the manufacturer's technical documentation. |
The definition of the manufacturer in PPWR
PPWR uses the definition familiar from product law. The manufacturer is the party that makes packaging, or has it designed or made, and places it on the market under its own name or trademark. The definition is functional: it does not ask about machinery, only about who stands behind the packaging on the market.
- Makes packaging itself and sells it under its own name — it is the manufacturer.
- Has packaging designed or made and places it under its own brand — it is the manufacturer.
- Buys a standard pack under the supplier's brand — the supplier remains the manufacturer.
- Imports packaging from outside the EU — it takes the importer role with a separate set of duties.
Standard box versus custom box
The question we hear most often is: does printing our logo make us the manufacturer? The distinction is simple. A standard catalogue pack sold under the AS-INTER-BOX name has the manufacturer on our side. Packaging designed for a customer and carrying its name or trademark usually shifts the manufacturer role to that customer — subject to the micro-enterprise exception.
- A white box or a catalogue design without customer print — AS-INTER-BOX is the manufacturer.
- A box printed with the customer's brand — the customer is usually the manufacturer.
- A customer that is a micro-enterprise and informed the supplier — the manufacturer duties stay with the converter.
- Whatever the role, we hand over the full information on material, coatings and production batch.
The duties that follow the manufacturer role
The manufacturer role is not a title but a package of concrete tasks. Whoever holds it keeps the documentation and answers for the packaging's compliance with PPWR requirements.
- Carrying out the conformity assessment against sustainability and labelling requirements.
- Drawing up and keeping the technical documentation.
- Issuing the EU declaration of conformity and making it available to authorities on request.
- Ensuring packaging identification: type, model, batch, serial number or an equivalent element.
- Providing the name or trademark, postal address and an electronic means of contact.
PPWR manufacturer versus EPR/BDO producer
These are two different roles in two different systems, and confusing them is the most common mistake in PPWR discussions. The PPWR manufacturer answers for the product: conformity, documentation, declaration. The producer under extended producer responsibility (in Poland registration and reporting in the BDO system) answers for the waste stream: national registration, tonnage reporting and financing of waste management. The same entity may hold both roles, but need not.
What we do as a supplier when the customer is the manufacturer
Article 16 PPWR requires the supplier to hand the manufacturer all information and documents needed to demonstrate conformity. For PAP 21 solid board boxes this means a specific data set that we provide with the delivery.
- Material specification and the PAP 21 code with grammage and coating description.
- Food-contact documentation and the FCM declaration of conformity.
- Identification data: index, type, model and production batch number.
- Information on inks, varnishes and adhesives used in the given order.
- Support in determining empty space in grouped and transport packaging.
Frequently asked questions
Related codes and topics
PPWR: obligations, DoC and traceability
The pillar page: role table, declaration of conformity, type and batch identification and application dates.
PPWR from 12 August 2026
What applies from the date of application and what comes later.
Food-contact declaration of conformity
How FCM documentation differs from the PPWR declaration and why one does not replace the other.
Production batch traceability
How we link type, model and batch with materials and quality control records.
The PAP 21 code on boxes
The material code for the solid board we use for pastry and bakery boxes.
Not sure who the manufacturer of your packaging is?
Tell us whether you order a catalogue box or one with your own print, and give us your company size. We will indicate which side holds the PPWR manufacturer role and what documentation we will prepare for your order.
Related topics
Further articles from the PPWR series — the closest topics to this page.