Articles · 2026-09-17
Who is the manufacturer of transport packaging under the PPWR?
Under the PPWR the manufacturer of transport packaging is the company whose brand is on it, the maker of generic packaging, or whoever orders it custom-made.
Under the PPWR the manufacturer draws up the declaration of conformity and the technical documentation. For transport packaging — crates, pallets, boxes — it is often not obvious who that is. The Commission answered it in the second edition of its PPWR FAQ (August 2026).
Why does it matter who the manufacturer is?
The manufacturer carries the conformity assessment, the technical documentation and the declaration of conformity. An authorised representative may draft the declaration, but the technical documentation cannot be delegated, and no contract moves the legal responsibility (FAQ X.9).
Is the manufacturer the company that physically makes it?
Not always. "Final form" is the stage at which the manufacturer is identified — not a rule about who it is. Packaging reaches final form when it can be used without further components being added (FAQ II.5). Who the manufacturer is then depends on the packaging:
- Branded — the company whose name or trademark is on it.
- Unbranded, generic, standardised — normally the company that physically makes it.
- Custom-made and unbranded — the company that places the order and decides the design specifications (FAQ II.14).
What does that mean for a crate or a pallet?
- A joinery builds crates to a customer's drawing, with no name on them: the customer who ordered them is the manufacturer.
- The same joinery sells standard unbranded pallets from stock: the joinery is the manufacturer.
- The crate carries the joinery's logo: the joinery is the manufacturer, because its name is on it.
What if the name and the trademark belong to different companies?
Both carry equal weight. The Commission calls it a case-by-case assessment of who has the decisive power over the design and specifications (FAQ II.7).
Can one shipment have several manufacturers?
Yes. Several packaging items in one shipment — a box, the pallet under it, the film around it — can have different manufacturers, and each owes its own technical documentation and declaration. Adding a shipping label is not branding (FAQ, section II).
Is there an exception for small companies?
If the company that would be the manufacturer is a microenterprise and its supplier is established in the same member state, the supplier is the manufacturer (FAQ II.6). Watch the wording: the definition in Article 3(1)(13)(b) says the same member state, while Article 15(12) describes the supplier as located in the Union. The Commission follows the definition.
What about packaging bought from outside the EU?
The importer must give its name and address on the packaging or in an accompanying document — also for generic, unbranded imported material (FAQ X.11).
Can a contract make the supplier responsible?
No. A contract can arrange who does the work, but not who is legally responsible. The supplier, however, cannot refuse to give the manufacturer the information needed to demonstrate conformity (Article 16(1)).
What a spreadsheet cannot do here
A spreadsheet lists the packaging, not who is its manufacturer in each case. When one customer's crates are custom-made and another's are standard, the same product line has two different answers — and a list with one column cannot hold both.
What Tarafex does
Each packaging component is a row with its own material, weight and supplier, and the supplier's answer is recorded with who gave it. The declaration page explains what the manufacturer needs and in what order. Tarafex does not decide who your manufacturer is; it keeps the data that decision rests on.
Sources: Regulation (EU) 2025/40, Articles 3(1)(13)(b), 15(12) and 16; Commission communication C(2026) 2151, annex; Commission PPWR FAQ, 2nd edition, August 2026, sections II.5, II.6, II.7, II.14, X.9, X.11. Checked 17 September 2026. This is information, not legal advice.