Site Update August 12, 2026
If you sell under your own brand and you are a very small business, the packaging obligation may not be yours. We had this wrong in two places and have corrected it.
The general rule is that putting your brand on packaging makes you the manufacturer, which is why private label normally lands on the retailer rather than the factory. There is one exception. If the brand owner is a micro-enterprise and its packaging supplier is in the same member state, the obligation belongs to the supplier instead. Both of those have to be true at once. A micro-enterprise buying its packaging from another member state is still on the hook itself.
What this means for you. If you are a micro-enterprise brand owner, check where your packaging supplier is based, because that single fact decides whether this is your obligation or theirs. If you are a packaging supplier, check whether any of your customers are micro-enterprises in your own country, because for those accounts the duty is yours, not theirs. Corrected on the Roles & Obligations tab and in the article guide. Source: Regulation (EU) 2025/40, Art. 3(1)(13)(a) and (b).
This entry is part of the PPWR Atlas update log. The Atlas is re-checked against the Official Journal, Commission guidance, and each national PRO's published schedule, and everything that changes gets logged with its source. See the week of August 10, 2026 or the full update archive.