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Overview

The PPWR (Regulation (EU) 2025/40) ties every duty to a role: whoever manufactures, imports, or distributes packaging has a different set of tasks. In Polygon One you set the role per packaging unit — from it, the platform automatically derives the matching obligation checklist.
The same company can hold different roles for different packaging: for the transport packaging you assemble yourself you are the manufacturer, for the imported product packaging you are the importer. That is why the role is set per unit, not per company.

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The roles at a glance

RoleCore duties under PPWRWhat Polygon One does for it
ManufacturerMakes packaging (or has it made) and places it on the market under its own name. Full conformity duty: conformity assessment (Module A, Art. 38), technical documentation (Annex VII), EU Declaration of Conformity (Annex VIII, Art. 39), marking (Art. 15).Derives the full obligation checklist, collects evidence per component, and generates the Declaration of Conformity from your data.
ImporterPlaces third-country packaging on the EU market (Art. 18). Verifies that the manufacturer carried out the assessment, documentation, and marking; keeps a copy of the Declaration of Conformity. Imported packaging must additionally carry the importer’s identity.Shows the Collect & retain duty for the Declaration of Conformity, tracks the verification status of collected declarations, and reminds you about the importer identity for marking.
DistributorMakes packaging available on the market without being manufacturer or importer (Art. 19). Due care: checks marking, that a Declaration of Conformity exists, and that the producer is registered.Same as the importer: Declaration of Conformity Collect & retain, status tracking of collected evidence.
Authorised representativeEU-established, under written mandate from a (often non-EU) manufacturer (Art. 17). Holds the Declaration of Conformity and technical documentation; liaises with market-surveillance authorities.Tracks the Declaration of Conformity to be kept on file, like the other collect roles.
SupplierSupplies packaging or materials to the manufacturer and provides all information and evidence needed to demonstrate conformity (Art. 16) — material data, substance and recycled-content declarations. Does not draw up a Declaration of Conformity.Tracks the substance duties (heavy metals, PFAS) on an evidence basis; no Declaration of Conformity duty.
Fulfilment service providerStores, packs, or ships packaging in e-commerce on behalf of others (Art. 20). Ensures handling and storage do not jeopardise conformity.The platform tracks no evidence duties for this role.

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Setting the role in the app

The role is set in the packaging unit form, in the Classification section:
1

Open the packaging unit

Navigate to Packaging units and open the unit you want (or create a new one — see Packaging units).
2

Select the role

Under Economic-operator role, select the applicable role. Below the select, the app shows a short description of the chosen role.
3

Check the extra switches (importer/distributor only)

For the importer and distributor roles, two additional switches appear: Placed under own brand and Modified affecting conformity — they control the Art. 21 reclassification (see below).
4

Save

After saving, the app immediately re-derives the unit’s obligation checklist.

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Art. 21: when an importer or distributor counts as a manufacturer

Art. 21 PPWR: if you place imported or distributed packaging on the market under your own brand, or modify it in a way affecting conformity, you take on the full manufacturer duties. The app models exactly that: enable either of the two switches Placed under own brand or Modified affecting conformity on an importer or distributor unit, and the unit is treated as a manufacturer for the obligation checklist. The checklist then shows the notice:
Treated as a manufacturer under Art. 21 (own-brand or modified packaging) — the full conformity duties apply.
Concretely this means: instead of merely collecting the Declaration of Conformity, you now have to generate it yourself — including conformity assessment and technical documentation.
An own-brand import is the most commonly overlooked case: whoever sources packaging from a third country and sells it under their own brand name is legally the manufacturer — with all the duties that entails.

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”Producer” in the EPR sense is a separate role

The PPWR distinguishes two concepts that are easily confused:
  • Manufacturer (Art. 3(13)): draws up and signs the Declaration of Conformity — the role from the table above.
  • Producer (Art. 3(15), EPR): makes packaging available for the first time on the territory of a Member State and therefore carries extended producer responsibility — registration (Art. 44), reporting, fees. In Germany this runs via LUCID/ZSVR.
The EPR producer status applies per Member State and is independent of the conformity role: a distributor can also be an EPR producer. In the app you set it via the Producer (EPR) switch in the same form section — it appears for the manufacturer, importer, and distributor roles. When it is active and the unit has market Member States recorded, the app adds the EPR registration duty for those Member States to the unit’s checklist.

EPR registration

How Polygon One guides you through registration in the national producer registers (e.g. LUCID).

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Next steps

Obligation checklist

Which duties the app derives from the role and what the statuses mean.

Declaration of Conformity

Generate (manufacturer) or collect (importer/distributor) — depending on the role.