The five roles in plain English
Start with the activity, then determine the role
The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and has applied in large part since 12 August 2026; other obligations are being phased in. The Regulation assigns obligations to roles, and those roles are defined by activity. Do not start by asking “what kind of business am I?”, but by asking “what do I do with this particular item of packaging?”.
| Role | What you do | Core obligation |
|---|---|---|
| Manufacturer | Makes the packaging, or has it made under its own name or trademark | Design, technical documentation, conformity assessment and the EU declaration of conformity |
| Supplier | Supplies packaging or packaging material to the manufacturer | Provide the technical information the manufacturer needs to carry out its assessment |
| Importer | Places packaging from outside the EU on the EU market | Verify that the manufacturer has fulfilled its obligations and provide its own details |
| Distributor | Buys within the EU and makes the packaging available further down the supply chain | Act with due care and carry out the checks prescribed by Article 19 |
| Producer (EPR) | First places the packaging on the market in a Member State | Registration in the producer register, reporting and the associated waste-management contribution |
Like any business, the role IVX fulfils depends on the activity and the specific supply flow. Where IVX purchases packaging within the EU and supplies it unchanged, its PPWR role is that of a distributor. This entails a focused duty to carry out checks, explained in practical terms below. A different supply flow may result in a different role and corresponding responsibilities.
What Article 19 requires of a distributor
Six paragraphs, in plain English
Article 19 of Regulation (EU) 2025/40 begins with a general standard: when making packaging available on the market, a distributor must act with due care in relation to the requirements of the Regulation. It then becomes specific. Before making packaging available, check three things:
- Registration. Is the producer subject to extended producer responsibility for this packaging registered in the producer register?
- Labelling. Is the packaging labelled as prescribed by Article 12? The applicable labelling requirements and their effective dates vary by packaging type and are being phased in, so assess this for each product.
- Identification details. Have the manufacturer and, where applicable, the importer provided their required details? This is required of them by Article 15(5) and (6), and Article 18(3), respectively.
The remaining paragraphs cover what happens next. If you have reason to believe that packaging does not comply with Articles 5 to 12, or that the manufacturer or importer has not met its requirements, you must not make that packaging available until it has been brought into conformity. While the packaging is under your responsibility, storage and transport must not jeopardise its conformity. If you suspect non-conformity in packaging that has already been supplied, take corrective action — bring it into conformity, withdraw it or recall it — and immediately inform the market-surveillance authorities in the Member States concerned. At the reasoned request of a competent authority, provide all information and documentation necessary to demonstrate conformity, in a language that can be easily understood, and cooperate with any resulting measures.
The same box, three different roles
What changes when the trade flow changes
You buy boxes from a Dutch manufacturer
The manufacturer makes the boxes, prepares the technical documentation and EU declaration of conformity and, in most cases, is also the producer that registers in the Netherlands. You are the distributor. Your check is limited and administrative: is the producer in the register, is the labelling correct, and are the manufacturer’s details shown? The greatest risk here is not the legislation but a change: if your supplier changes the composition, production site or printing, it is effectively a different product and the check starts again.
You buy the same boxes from a manufacturer in Germany
Formally, little changes for you: within the EU you remain a distributor because no packaging from outside the Union is being placed on the market. What does change is the question of who registers in the Netherlands for extended producer responsibility. Does the German manufacturer itself place the boxes on the Dutch market, or do you? This is regulated at Member State level and should be the first question you ask a cross-border supplier, not the last.
You import tape directly from Asia
You are now no longer a distributor but an importer, which is a more demanding role. You must establish that the manufacturer has fulfilled its obligations and provide your own details on the packaging or accompanying documentation. In practice, this means requesting and assessing the documentation before the first order, not afterwards. The same applies if you sell packaging under your own name or trademark, or modify it in a way that may affect conformity: your role changes in those cases too.
The common thread is that the role attaches to the activity, not to the business. If you buy boxes in the Netherlands and also import film from Asia, you are simultaneously a distributor for the boxes and an importer for the film, with different obligations for each flow.
What to record to demonstrate your role
Four items for each packaging product
Determining your role is not the main task; being able to demonstrate it later is. Four records are enough to make that possible.
The activity. Do you purchase, import, pack, sell under your own trademark, or repack imported goods? Record it in plain English for each item of packaging.
The trade flow. From which country to which country, through which party, and to what type of customer? This determines whether the flow crosses the EU border.
The check performed. Record the date, who carried it out, what was checked and the outcome. One line per packaging product is enough; the purpose is traceability, not a lengthy report.
Changes. Record every change in supplier, composition, production site, design or claim, together with the date. This is the point at which an earlier assessment ceases to apply.
The information you request from your supplier to carry out this check, and the reason for each question, is explained on the supplier information page. When moving from role determination to material selection, see the technical guidance in the material guide and assess a board grade with the box calculator.
Frequently asked questions about roles
Concise, practical answers in plain English
Yes. The role attaches to the activity involving a specific item of packaging, not to your business as a whole. If you buy boxes from a Dutch manufacturer and also import film directly from Asia, you are a distributor for those boxes and an importer for that film, with different obligations.
No. The manufacturer makes the packaging or has it made under its own name. For extended producer responsibility, the producer is the party that first places the packaging on the market in a Member State and must register there. These are often two different businesses.
Article 19 of Regulation (EU) 2025/40 requires three checks: that the producer subject to extended producer responsibility is registered in the producer register, that the packaging is labelled in accordance with Article 12, and that the manufacturer and importer have provided their identification details. A distributor must also act with due care and must not make the packaging available while there are reasonable grounds to doubt its conformity.
Yes. As soon as you place packaging from outside the EU directly on the EU market, you are an importer and have more extensive obligations than a distributor. The same applies if you sell packaging under your own name or trademark, or modify it in a way that may affect conformity.
Sources and scope
Basis for this guidance
- EUR-Lex — Regulation (EU) 2025/40 — the Regulation itself, including the articles on the obligations of economic operators. Opens in a new window.
- Netherlands Enterprise Agency (RVO) — EU legislation: packaging requirements (PPWR) — Dutch government information on roles and documentation. Opens in a new window.
- Verpact — All about the PPWR — extended producer responsibility, registration and reporting in the Netherlands. Opens in a new window.
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