PPWR: own brand when an importer or distributor becomes the manufacturer (Art. 21)

Article 21: manufacturer treatment

Article 21 PPWR provides that an importer or distributor that places packaging on the market under its own name or trademark, or that modifies packaging, shall be considered a manufacturer for the purposes of the Regulation and shall be subject to the obligations of the manufacturer under Article 15.

Confirm with your adviser whether Article 21 applies to a specific product line, including packaging modifications and trademark use. Product Registry stores your declarations; it does not classify your company.

Article 15(3): retention of technical documentation and EU DoC

Article 15(3) PPWR requires manufacturers to keep technical documentation and the EU declaration of conformity for 5 years from the date single-use packaging was placed on the market, or 10 years for reusable packaging.

Plan retention on signed declarations and linked evidence. Product Registry records retention dates on packaging declarations and blocks deletion while retention applies.

Article 15(10): 10-day hand-over to authorities

Article 15(10) PPWR states that the relevant documents shall be made available within 10 days of receipt of the request from the national authority. The same sentence appears for importers in Article 18(8) and for authorised representatives in Article 17(2)(d).

Log reasoned authority requests on the packaging authority requests board and export a hand-over pack you submit yourself. Product Registry does not transmit files to any authority.

Article 16(1): supplier documentation

Article 16(1) PPWR requires suppliers to provide the manufacturer with all the information and documentation necessary to demonstrate conformity, including the technical documentation referred to in Annex VII. The regulation text does not set a deadline for suppliers.

Use supplier evidence requests and the org-wide evidence requests board to track what you asked for and what arrived. Product Registry never emails suppliers.

Annex VII Module A point 2: technical documentation contents

• General description of the packaging and intended use.
• Conceptual design, drawings and materials of components.
• Explanations needed to understand those drawings and the operation of the packaging.
• List of harmonised standards or common specifications applied, or a description of solutions adopted where standards were not applied.
• Qualitative description of assessments under Articles 6, 10 and 11 PPWR.
• Test reports and an adequate analysis and assessment of risks of non-conformity.

Complete packaging units (Article 6(9))

Article 6(9) PPWR requires that where a unit of packaging includes integrated components, the assessment of compliance with design for recycling criteria and with recycled-at-scale requirements shall include all integrated components. Where a unit includes separate components, the assessment shall be carried out separately for each separate component.

Article 3(1)(45) defines a unit of packaging as a unit, including any integrated or separate components, which as a whole serves a packaging function. Record every component on the PPWR sheet before you sign a declaration.

Producer registration timing (Article 44(4))

Whether Article 44(4) PPWR already applies before new national PPWR registers are fully operational, and whether existing national EPR registers count, is to confirm with your adviser. Product Registry does not interpret national register law.

How Product Registry helps

On each SKU, use the PPWR markets tab to record per-country EPR facts and the own-brand as manufacturer flag when your team declares that scenario.

Per packaging unit, draft the EU declaration of conformity and work through the Annex VII checklist. Use the technical readiness board, supplier evidence requests, authority requests board and the org-wide evidence library to see expiry dates and links across SKUs and packaging.

Product Registry does not decide whether you are a manufacturer, does not verify register entries, does not email suppliers or authorities and does not certify conformity.