Start with scope and role. Regulation (EU) 2025/40 applies to all packaging placed on the EU market and to all packaging waste, regardless of material or source sector. The legal definitions distinguish packaging, sales packaging, grouped packaging, transport packaging, e-commerce packaging, reusable packaging, refill, producer, manufacturer, importer, distributor, final distributor, and end user.
For most FAQ journeys, the first evidence record should identify the packaging unit, the market in which it is first made available, and the economic operator role. Manufacturer and producer are separate PPWR roles: the manufacturer is tied to who manufactures or has packaging designed under its name or trademark, while the producer definition determines EPR responsibility in a Member State. The Commission's 2026 guidance gives examples for own-brand packaging, service packaging, distance sales, and reusable systems, but it is guidance rather than binding legislation.