The PPWR detail you can’t afford to miss

The European National Registers for Packaging (EUNR) has published new guidance clarifying the legal definitions of ‘producer’ and ‘end user’ under the EU’s Packaging and Packaging Waste Regulation (PPWR), with a particular focus on sales and grouped packaging.

Representing packaging authorities from 16 EU Member States, the EUNR explains that the producer is the first economic operator in the domestic supply chain. If packaging is manufactured within a Member State, the manufacturer is considered the producer. If it is imported, the first company in the domestic supply chain becomes the producer. Companies based outside the EU are only regarded as producers when they supply packaging directly to a private or commercial end user.

The guidance also distinguishes how different packaging formats enter the supply chain. For transport, service and primary production packaging that is filled before reaching its final form, including sales packaging, grouped packaging and flexible packaging, the supply chain begins when the packaging is filled. However, rigid packaging that is already in its final form when manufactured enters the supply chain as empty packaging.

EUNR also clarifies the definition of an end user, stating that this refers to the final consumer or professional user of the packaged product, not the packaging material itself. As a result, businesses that import packaging materials to pack their own products are not considered the end users of those materials.

Martin Engelmann, Director General of the German Plastic Packaging Association, said the new EUNR guidance provides greater clarity on sales and grouped packaging than the European Commission’s guidance published in March and June 2026.

The clarification follows ongoing discussions surrounding the PPWR, including a non-paper submitted by the Czech Republic requesting further guidance on Annex V’s exemption for packaging required for handling. At the same time, industry organisations have urged the European Commission to consider extending compliance deadlines, arguing that restrictions on plastic shrink wrap used for multipacks may not be achievable until 2035.