The words, in plain English

Why a glossary is not a nicety here

Most of the arguments we see are not disagreements. They are two people using one word for two different things and getting different answers, correctly, from different questions.

The reason is that this Regulation borrows ordinary English words and gives them narrow technical meanings that do not match the ordinary ones. Producer does not mean the person who produced it. Manufacturer does not require you to own a factory. Placing on the market is not the same as selling, and making available on the market is a third thing again. None of this is obfuscation — a regulation has to be precise — but it means you cannot read the text with ordinary intuitions and get the right answer.

The roles

Producer — Art. 3(1)(15)

The EPR role: who pays for the packaging. Decided per country, by who makes packaging available for the first time on that territory. Limbs (c) and (d) are the ones that catch this audience — established in a member state or a third country, making available for the first time on the territory of another member state, directly to end users. That sentence is a description of ordinary cross-border e-commerce.

Manufacturer — Art. 3(1)(13)

The conformity role: whether the packaging itself is lawful. EU-wide, not per country. Note that the PPWR manufacturer and the GPSR manufacturer are different definitions in different regulations — the GPSR one, at its Art. 3(8), is about the product.

Deemed manufacturer — Art. 21

An importer or distributor who puts packaging on the market under their own name or trademark, or modifies it so that conformity may be affected, becomes the manufacturer of it. Branding a plain box makes it yours.

Importer — Art. 3(1)(17)

Someone established within the Union who places packaging from a third country on the market. If you are outside the EU shipping direct to consumers, there is generally no importer — which is precisely why the representative rules exist.

Distributor — Art. 3(1)(18)

Anyone in the supply chain other than the manufacturer or importer who makes packaging available on the market.

Supplier — Art. 3(1)(16)

Who supplies packaging or packaging material to a manufacturer. Your box seller. Under Art. 16 they must give you the documentation you need and cannot refuse.

Economic operator — Art. 3(1)(12)

The umbrella term: manufacturer, supplier, importer, distributor, authorised representative, final distributor, fulfilment service provider. Worth knowing because obligations are often written as applying to "economic operators", meaning all of them. (The Commission's own FAQ once cites this number for "manufacturer". It is (13).)

End user

The person the thing finally goes to. It matters because the producer limbs (c) and (d) turn on supplying directly to end users — the phrase that puts distance sellers inside the definition.

The three representatives — and they are three

This is where more money is wasted than anywhere else on this list, because the same two English words name three different jobs under two different regulations.

Authorised representative — Art. 3(1)(19) PPWR

The manufacturer's representative, on the conformity side. Written mandate from the manufacturer, for specified tasks. Under Art. 17 they may draft the declaration of conformity and hold documents — but the technical documentation cannot be delegated.

Authorised representative for the extended producer responsibility — Art. 3(1)(20) PPWR

The EPR representative. Established in the member state where you make packaging available, so you need one per country. This is the expensive one, and the one Art. 45(3) requires. When this site says "representative" unqualified, it means this.

Responsible person — Art. 16 GPSR

Nothing to do with packaging. An economic operator established in the Union responsible for the safety of the product. One for the whole Union, not one per country. An EU-established maker is already their own. See GPSR in plain language.

The market words

Three phrases that look like synonyms and are not. Getting these right is what tells you which country you owe something in.

Making available on the market — Art. 3(1)(9)

Any supply of packaging for distribution, consumption or use on the Union market, in the course of a commercial activity, whether for payment or free of charge. Free samples are in.

Placing on the market — Art. 3(1)(10)

The first making available on the Union market. Happens once, for the Union as a whole.

Making available on the territory of the Member State — Art. 3(1)(11)

The same idea, scoped to one country. This is the one that governs EPR — it is why registration and representation are per-member-state, and why twenty-seven markets means up to twenty-seven registrations.

Distance contract — Art. 3(1)(14)

Borrowed from Art. 2(7) of the Consumer Rights Directive 2011/83/EU. Concluded without the simultaneous physical presence of both parties, under an organised distance-selling scheme. Your shop.

The packaging words

Sales packaging — Art. 3(1)(5)

Packaging conceived to constitute a sales unit — products plus packaging — to the end user at the point of sale.

Grouped packaging — Art. 3(1)(6)

Packaging that groups a number of sales units, whether or not it is sold on as such.

Transport packaging — Art. 3(1)(7)

Conceived to facilitate handling and transport and prevent damage.

E-commerce packaging — Art. 3(1)(8)

Transport packaging used to deliver products sold online or at a distance. It has its own definition because it is the shipping box, and it is the item small sellers most often forget to count. See what counts as packaging.

Household vs commercial packaging

Not a PPWR distinction but the one that decides your bill in most countries: whether the packaging typically ends up with private households. Shipping to consumers puts you squarely in household. Austria has a whole delimitation ordinance for the boundary.

The scheme words, and their twenty-seven local names

There is one concept here and a different acronym for it in every country, which is why comparing national guides is so disorientating. A producer responsibility organisation (Art. 46) is a body you pay so that it discharges your EPR obligations collectively. Everything in this table is one of those.

Eco-modulation

Charging more for packaging that is harder to recycle. Italy is the clearest example: plastic from €40 to €790 a tonne by recyclability band — a twentyfold spread inside one material.

Green Dot

A trademark, not a legal mark. Paying a scheme does not oblige you to print it, and in Belgium it must come off your artwork from February 2027. Its presence on a box tells you nothing about whether anyone is compliant.

Written mandate

The instrument that appoints a representative, required in terms by Art. 44(3) and Art. 45(3). Form varies hard: Austria wants a notarially certified power of attorney in German or English; Germany wants a written agreement in German; Malta publishes a form; Slovakia imposes a minimum one-year term.

Self-certification — Art. 45(4)(b)

The statement you give a marketplace confirming you comply in the customer's country. It is your statement, the platform must assess it, and several registers are public.

The numbers you will be asked for

Registration number

Generic term for what Art. 44 gets you. Every country issues its own, in its own format, and a marketplace wants the one for the country the customer is in.

LUCID number — Germany

From the ZSVR register. Free, usually issued within about a day, and the register is public.

IDU — France

Identifiant unique, issued by ADEME. One per EPR stream. Uniquely, Art. R. 541-173 makes you publish it on your own website — the most-missed French duty.

ENV number — Spain

ENV/YEAR/XXXXXXXXX, from the RPP. Goes on your invoices.

Micro-enterprise

Recommendation 2003/361/EC as applicable on 11 February 2025: fewer than 10 employees and turnover or balance sheet total not exceeding €2 million. It buys less than people hope — see manufacturer or producer? for the three separate carve-outs and their two different geographic tests.

De minimis

Not a PPWR term. In Poland it is literally State-aid de minimis: the 1,000 kg relief is aid you must claim in writing every year by 15 March. Elsewhere people use it loosely to mean "a threshold", which is how the misunderstandings start.

Sources

Every article number on this page was read in the Regulation itself rather than copied from a summary, because a glossary that gets the citations wrong is worse than no glossary — it makes the error portable.

1. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Source for the Art. 3(1) definitions quoted throughout, and for Art. 16 (supplier documentation), 17 (the manufacturer's representative), 21 (deemed manufacturer), 44(3), 45(3), 45(4)(b) and 46. Read directly for this page
2. Regulation (EU) 2023/988 (GPSR) — EUR-Lex Source for the GPSR manufacturer at Art. 3(8) and the responsible person at Art. 16 — a different regulation with different words for adjacent things
3. Directive 2011/83/EU on consumer rights — EUR-Lex Where Art. 3(1)(14) PPWR borrows the definition of a distance contract from, at its Art. 2(7)
4. Commission Recommendation 2003/361/EC — EUR-Lex The micro-enterprise definition, as applicable on 11 February 2025

Help us finish this page

If a word sent you here and you still could not find it, that is the most useful message you can send us — a missing entry is a gap we cannot see from the inside. The same goes for a national term this page does not carry: there are twenty-seven vocabularies out there and we have transcribed a fraction of them.