d1e478-1-1__para__7

However, if the company that has the packaging or packaged product designed or manufactured under its own name or trademark is a micro-enterprise, and the company supplying the packaging is located in the same Member State, then this supplier of the packaging is the manufacturer (Article 3(1), point (13)(b)). This is regardless of whether the latter company is also a micro-enterprise. For example, if a manufacturer of a packaging container is a micro-enterprise but the manufacturer of the packaged product is not, the exemption does not apply. If a manufacturer of a packaging container is not a micro-enterprise, while a manufacturer of a packaged product is, the exemption applies, and it is the manufacturer of the container which should be considered as ‘manufacturer’ for the purpose of the PPWR.

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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.