d1e705-1-1__para__8

The EPR obligations provided under the PPWR apply to ‘producers’ (manufacturers, importers or distributors) who make available for the first time packaging or packaged products on the territory of a Member State (see point 4 of this document). The Regulation does not explicitly extend EPR obligations to entities that are only VAT-registered or have a permanent establishment without legal personality. Arguing that VAT registration alone equals ‘establishment’ for the purposes of EPR obligations would conflict with the harmonised definition of importer in Article 3(1), point (17). Member States cannot impose additional requirements that undermine the harmonisation of the notion of producer and importer under 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.