PPWR - Which company is responsible for EPR?

PPWR aims to clearly define a single producer for each packaging unit, regardless of whether the packaging is empty or contains products.

To support the identification of the company responsible for EPR, the regulation provides definitions for producer, manufacturer, importer, distributor, and end user, which are explained on this page. These definitions make it possible to identify the correct responsible company even within long and complex supply chains.

As of 12 August 2026, the company responsible for packaging under extended producer responsibility in Finland is

1. A manufacturer, importer, or distributor established in Finland that first makes available in Finland transport packaging, service packaging, primary production packaging, or a product packaged in packaging other than those mentioned above.

2. A manufacturer, importer, or distributor established in another country that first makes available directly to end users in Finland transport packaging, service packaging, primary production packaging, or a product packaged in packaging other than transport, service, or primary production packaging.

3. A manufacturer, importer, or distributor established in Finland that unpacks a packaged product without being the end user, if none of the definitions in the previous points apply.

Definition of a Producer

A producer is a company responsible for covering the costs of the collection and recycling of packaging waste in the EU Member State where the packaging is expected to become waste.

The producer must register with a producer responsibility organization (PRO), report annually the quantities of packaging placed on the market, and pay the recycling fees in accordance with extended producer responsibility.

A producer, and thus the company responsible for EPR:

Is a manufacturer, importer, or distributor that first makes packaging or a packaged product available in the Member State where it becomes waste.
Is responsible for waste management costs and the reporting of packaging data in that Member State.

Packaging is often part of a long supply and distribution chain where it may be made available multiple times. The producer is the actor that makes the packaging available for the first time in the relevant Member State.

“Making available on the market” refers to:

Any supply of packaging for distribution, consumption, or use that may lead to actual delivery.
In the case of e-commerce, offering a product directly to an end user in their Member State.

Definition of a Manufacturer

A manufacturer is a natural or legal person who has packaging or a packaged product manufactured. The term “manufacturer” can be misleading, as it does not necessarily refer to the entity that physically manufactures the packaging.

Under the PPWR definition, the manufacturer is generally considered the producer and is therefore responsible for fulfilling the statutory EPR obligations. The manufacturer is also the only economic operator with legal responsibility for the compliance of the packaging with regulatory requirements.

If a specific name or trademark appears on the packaging or the packaged product, the owner of that name or trademark is typically presumed to be the manufacturer, as it exercises decisive control over contractual relationships with suppliers and can determine the characteristics of the packaging.

Examples

Sales and grouped packaging:
The manufacturer is usually the economic operator that performs the final processing steps on the packaging (e.g., cutting, filling, sealing) and fills it with the product before placing it on the Union market. In practice, this is often the filler and typically also the brand owner.
Transport, service, and primary production packaging:
The manufacturer is generally the company that physically produces the packaging, unless the packaging is clearly branded with the name or trademark of its user.

Read more about branded and transport packaging:

Definition of an Importer

An importer is a natural or legal person who:

Is established in the European Union, and
Places packaging originating from outside the EU on the EU market.

“Established” means that the operator must have a registered address in a Member State.

A branch is not a separate legal entity and operates in the name of its parent company. Therefore, contracts concluded by a branch legally bind the parent company. A manufacturer established outside the EU with only a branch in the EU has two options; to establish a subsidiary within the EU, or appoint an Authorised Representative.

Definition of a Distributor

A distributor is any natural or legal person in the supply chain, other than the manufacturer or importer, who makes packaging available on the market.

Examples include wholesalers and retailers.

The distributor must ensure that the packaging complies with the requirements of the regulation when it is made available on the market. The distributor must also not handle the packaging in a way that could compromise its compliance.

Definition of an End User

An end user is a natural person residing in the EU or a legal person established in the EU to whom a product is made available as a consumer or professional end user, and who does not make the product available on the market again in the same form.

An end user can therefore be either a consumer, or a business.