The European National Registers for Packaging (EUNR) network has released a guidance document clarifying the legal definition of a ‘producer’ and ‘end user’ under the Packaging and Packaging Waste Regulation – including in sales and grouped packaging applications.
The EUNR comprises nationally competent authorities and organizations from 16 EU Member States aiming to promote the harmonized application of the Packaging and Packaging Waste Regulation across the EU’s internal market.
The document defines a ‘producer’ as the first economic operator in the domestic supply chain. For packaging manufactured in the Member State where it is sold, the manufacturer is considered the producer; if it is manufactured abroad, the producer becomes the first company in the domestic supply chain.
Overseas companies may only be considered the producer if they deliver the packaging to a private or commercial end user, EUNR explains.
For transport, service, and primary production packaging that only takes its final form once filled – this includes sales packaging, grouped packaging, and many flexible formats – the supply chain is said to begin at the point of filling.
Packaging that is in its final form once it has been manufactured, as is often the case with rigid formats, begins its legal life cycle while it is still empty.
The document also clarifies that the ‘end user’ refers to the last consumer or industrial entity to use the packaged product, not the packaging material. Packers or fillers that import pallets, films, or wrapping paper from another Member State to package their own products are not considered an ‘end user’.
The European Commission has published its own guidance documents to accompany the Packaging and Packaging Waste Regulation in March and June this year; yet Martin Engelmann, director general at the German Plastic Packaging Association, believes that the EUNR’s document specifies the rules for grouped and sales packaging “more clearly than the Commission guidance”.
This development comes after the Czech Republic circulated an informal non-paper requesting that the Commission clarify Annex V’s exemption for packaging that is ‘necessary to facilitate handling’ before official guidelines are published next year – a move set to acknowledge the necessary role of grouped packaging across the value chain.
Multiple industry CEOs also wrote to the Commission and requested that the Regulation’s deadlines be pushed back if legal certainty cannot be reached. Among their concerns was a lack of clarity as to whether the restriction on plastic shrink wrap, as listed in Annex V, applies to multipacks; in their view, a deadline in 2035 would be more realistic.
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