d1e478-1-1__para__13
COMMISSION NOTICE Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste · European Union
When reusable packaging is designed following specific requirements of a re-use system operator and carries its trademark, the re-use system operator is the ‘manufacturer’. This will be the case notably in closed loop re-use systems (11). When reusable packaging does not carry a specific trademark, the manufacturer of the packaging is the ‘manufacturer’, unless the user (i.e. the re-use system operator) can be identified as the one having ordered such packaging and its specific design.
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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.