PPWR - Branded and Transport Packaging 

Branded packaging

Branded packaging refers to packaging that displays a company’s name, logo, or trademark. These are typically sales and grouped packaging, but transport packaging may also be considered branded if it bears a company’s name, logo, or trademark.

From the PPWR perspective, the decisive factor is not who physically manufactures the packaging, but who defines its design and characteristics and places it on the market under their own name or trademark.

Who is producer responsible for branded packaging?

According to the PPWR, the producer responsible is generally the company that:

• Has the packaging manufactured under its own name, logo, or trademark, and
• Makes the packaging or the packaged product available for the first time in the Member State where it becomes waste.

In practice, this is often the brand owner, who also acts as the designer and commissioner of the packaging. 

Exception: Micro-Enterprises

If the company having the packaging manufactured under its own name or trademark is a micro-enterprise, and the packaging supplier is located in the same Member State, producer responsibility may be transferred to the packaging supplier. 

A micro-enterprise is defined as a company that employs fewer than 10 employees, and has an annual turnover or balance sheet total not exceeding €2 million.

Practical examples of branded packaging

Example 1: Food Product
Company A sells food products under its own brand. The packaging is manufactured by a contract manufacturer, and the products are packed before sale.
→ Company A is the producer responsible, as the packaging is produced under its brand.

Example 2: Private Label Products
A retailer sells products under its own brand, even though manufacturing is outsourced.
→ The retailer is the producer responsible because its trademark appears on the packaging.

Example 3: Branded Transport Packaging
Company A orders transport packaging printed with its logo.
→ Company A is the producer responsible for this transport packaging.

Until 11 August 2026

Producer responsibility lies with the packer or the importer of the packaging. 

For service and primary production packaging, responsibility lies with the actual manufacturer of the packaging. 

From 12 August 2026 onwards

Producer responsibility will generally lie with the brand owner who has the packaging manufactured under its own name or trademark. 

For branded packaging, responsibility transfers to the company whose name or trademark appears on the packaging. 

Transport packaging 

Transport packaging is packaging designed to facilitate the handling and transportation of one or more sales units within the supply chain. It is used to protect, store, and move products and is typically not intended for the end user.

Examples of Transport Packaging

• Cardboard boxes and containers
• Pallets
• Plastic transport crates
• Stretch and protective films
• Pallet covers and other protective materials
• E-commerce delivery packaging

Note: Containers used in road, rail, sea, and air transport are not considered packaging.

From 12 August 2026, the producer responsible for transport packaging will be the manufacturer, importer, or distributor of the packaging. In this context, the manufacturer refers to the operator that physically manufactures the packaging. Previously, the responsibility typically rested with the packer or importer.

The impact of trademarks must also be considered. If transport packaging bears a company’s trademark, the producer responsible is the company that commissioned the packaging, i.e., the operator that defines its design and characteristics and places it on the market under its own name or trademark.

Determining the producer of transport packaging 

To identify the producer, the following factors should be considered: 

1. Is the Product Ready to Function as Packaging? 

Transport packaging may consist of several components that do not individually fulfil the function of packaging. If the packaging only functions as such after additional components are added, the assembler is considered the manufacturer and the first potential producer. 

2. Who is the Manufacturer of the transport packaging? 

• If the packaging bears a name or trademark, the producer is usually the company that commissioned the packaging (often also the filler). 
• If the packaging cannot be identified by a name or trademark, the producer is generally the actual manufacturer of the packaging. 

For transport, service, and primary production packaging, the manufacturer is typically the company that physically produces the packaging, unless it is clearly branded with the name or trademark of its user. 

Practical examples of transport packaging 

Example 1: Empty Cardboard Boxes
A packaging manufacturer supplies unbranded empty cardboard boxes to a Finnish company.
→ The packaging manufacturer is the producer responsible, as it places the packaging on the Finnish market for the first time.

Example 2: Imported Transport Packaging
A Finnish company imports transport packaging from outside the EU for its own use.
→ The importer is the producer responsible for this packaging.

Example 3: Branded Transport Packaging
Company A orders cardboard boxes printed with its logo and uses them for transporting its products.
→ Company A is the producer responsible because the packaging is produced under its brand.

Example 4: Delivery to Another Member State
A Finnish company delivers products in transport packaging to a Swedish company that is not the end user.
→ The Swedish recipient is the producer responsible in Sweden, as it makes the packaging available on the market there for the first time.

Until 11 August 2026 

Producer responsibility lies with the packer or the importer of the packaging. 

From 12 August 2026 onwards

For branded transport packaging, responsibility transfers to the company whose name or trademark appears on the packaging. 

For unbranded transport packaging, responsibility transfers to the manufacturer, importer, or distributor of the transport packaging.