d1e478-1-1__para__5
COMMISSION NOTICE Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste · European Union
Under the conditions set forth in Article 21, importers and distributors may be considered manufacturers for the purposes of this Regulation. This happens when they place on the market packaging under their own name or trademark or modify packaging already placed on the market in a way that could affect compliance with the relevant requirements of this Regulation.
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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.