Roles and Responsibilities

2. What does KARTON-PAK provide as a supplier?

Where the customer is the manufacturer of the packaging concerned, KARTON-PAK acts as the supplier of the packaging or packaging material. In accordance with Article 16 of the PPWR, the supplier provides the manufacturer with the information and documents necessary to demonstrate the conformity of the packaging – to the extent relating to the product, materials and processes under KARTON-PAK’s control.

A similar division of responsibilities was adopted in the DAKO guidance: the supplier does not replace the customer in the performance of the manufacturer’s obligations, but is a primary source of technical and material data for the customer.

Scope of the information provided

Depending on the type and specification of the packaging, KARTON-PAK may provide in particular:

• a code or name identifying the product;
• the construction type, for example the FEFCO code;
• the packaging dimensions;
• the type and grammage of the board;
• the flute type and number of layers;
• the packaging weight;
• a description of the materials used;
• information on printing, inks, varnishes, adhesives, coatings and laminates;
• information on windows, inserts and other constituent elements made by KARTON-PAK;
• data enabling the production batch to be identified;
• information on basic performance parameters;
• declarations and information obtained from suppliers of board, inks, adhesives, varnishes and other materials;
• information on restricted substances, to the extent applicable to the packaging concerned;
• test results, supplier statements or other evidence held by KARTON-PAK;
• information necessary to assess recyclability and material composition;
• documentation concerning contact with food or other sensitive applications, where such intended use was notified and agreed before production.

The documents may be provided in the form of a technical data sheet, product specification, material statement, PPWR annex or a set of source documents.

Limits of KARTON-PAK’s responsibility

KARTON-PAK’s documentation relates to the packaging in the condition in which it was supplied to the customer. It does not automatically cover the effects of activities subsequently carried out by the customer or third parties, such as:

• filling the packaging;
• closing or heat-sealing;
• applying labels;
• using tapes, films, inserts or fillers;
• laminating or coating;
• combining the packaging with other elements;
• changing the intended use;
• contact with a product whose properties were not previously disclosed;
• storage or use under conditions inconsistent with the recommendations.

Where the customer changes the composition or construction of the packaging after delivery, the documentation provided by KARTON-PAK may not be applied to the modified packaging without an additional assessment.

What does the supplier not do on behalf of the manufacturer?

Where KARTON-PAK acts solely as a supplier, it:

• does not assume responsibility for the customer’s final conformity assessment;
• does not assess the impact of the product packed by the customer unless it has received data concerning that product;
• is not responsible for elements added by the customer or other suppliers;
• does not sign the EU declaration of conformity on behalf of the customer;
• does not assume the customer’s EPR obligations;
• does not confirm properties that cannot be demonstrated on the basis of the available data and applicable assessment methods.

3. When does KARTON-PAK issue a declaration of conformity?

KARTON-PAK issues an EU declaration of conformity only where, under the PPWR, it is the manufacturer of the packaging type concerned.

The mere physical production of a box does not in itself determine who the manufacturer is. Where packaging is manufactured under the customer’s name or trademark, or where the customer orders the packaging and decides on the material aspects of the design, the manufacturer’s responsibility may rest with the customer. Where the packaging does not bear any brand, the Commission indicates that the decisive factor is to establish who placed the order and who made the decisions concerning the design specification.

KARTON-PAK may be the manufacturer in particular where it:

• manufactures standard, unmarked packaging according to its own construction and specification;
• manufactures packaging under its own name or trademark;
• manufactures unmarked transport packaging in relation to which the customer did not decide on the material features of the design;
• supplies packaging to a Polish micro-enterprise that ordered the packaging under its own name or trademark and the exception provided for in the PPWR applies;
• is, based on the circumstances of the specific order, the only entity that can be identified as the manufacturer of the packaging concerned.

A micro-enterprise is an enterprise that employs fewer than 10 persons and whose annual turnover or annual balance-sheet total does not exceed EUR 2 million. The exception relating to a brand owner that is a micro-enterprise generally requires the supplier and the micro-enterprise to be located in the same Member State.

KARTON-PAK does not issue its own EU declaration of conformity where:

• the customer owns the brand of the packaging or of the product in the packaging and is the manufacturer;
• the customer commissions the design or manufacture of the packaging according to its own design specification;
• KARTON-PAK supplies only board sheets, blanks or a semi-finished product and the customer makes the finished packaging from them;
• the customer carries out the final assembly or processing that results in the creation of the packaging;
• the customer or a third party modifies the packaging in a way that may affect compliance;
• KARTON-PAK does not have information concerning the final composition, intended use or method of use of the packaging.

In such cases, KARTON-PAK provides the customer with the source data and documents needed to prepare the technical documentation, but the declaration of conformity is drawn up and signed by the customer as the manufacturer.

One declaration or a declaration for every delivery?

The declaration is prepared for a specified packaging type, not automatically for every invoice or every delivery batch. It must, however, allow the product to be identified unambiguously and must remain up to date.

A new declaration or an update may be necessary following a change in:

• the type or grammage of the board;
• the construction;
• dimensions affecting the conformity assessment;
• the ink, varnish, adhesive or coating;
• plastic elements;
• the intended use;
• the method of closing or filling;
• legal requirements, standards or assessment methods.

Annex VII provides for a declaration for each packaging type, and Article 39 requires it to be kept up to date.

4. What information must you provide when placing an order?

Correctly determining the role of the manufacturer and the scope of the documentation requires information not only about the dimensions of the box, but also about its intended use, marking and further use.

Therefore, for a new product or a change to an existing product, the customer should provide KARTON-PAK with the following information.

1. Type of packaging

It should be specified whether the packaging is:

• sales packaging;
• grouped packaging;
• transport packaging;
• e-commerce packaging;
• service packaging;
• primary production packaging;
• reusable packaging;
• another type of packaging.

The same FEFCO construction may perform different functions. The box code alone does not tell us whether it is sales, grouped or transport packaging. Cardboard is not clairvoyant – yet.

2. Intended use of the packaging

The following should be indicated:

• which product will be packed;
• the number of products in the packaging;
• the weight and dimensions of the product;
• the arrangement of the products;
• transport and storage conditions;
• strength requirements;
• whether the packaging will reach the final consumer.

3. Brand appearing on the packaging or product

The customer should state:

• whether its name, logo or trademark will appear on the packaging;
• whether the brand of another entity will appear on the packaging;
• whether the packaging will be completely unmarked;
• under whose brand the product contained in the packaging will be sold.

A company logo and name may directly affect the determination of the manufacturer’s role.

4. Entity deciding on the design

It should be established who decides on:

• the construction;
• the dimensions;
• the material;
• the grammage;
• the minimum strength;
• the closing method;
• the printing;
• the use of coatings, varnishes, laminates, windows or inserts;
• parameters affecting recycling and minimisation.

Providing a single dimension does not always mean that the customer has become the packaging designer. However, where the customer specifies the full construction and the material design parameters, this may affect its classification as the manufacturer. For unbranded packaging, the Commission considers the order and the decisions concerning the design specification to be the decisive criterion.

5. Further activities performed by the customer

It should be stated who will:

• erect the packaging;
• glue or staple it;
• fill it;
• close it;
• heat-seal it;
• seal it with a tamper-evident closure;
• apply labels;
• add inserts, films, fillers or other components.

6. Contact with food or sensitive products

The customer should expressly state whether the packaging is intended for:

• direct contact with food;
• indirect contact with food;
• contact with cosmetics;
• contact with medicinal products, medical devices or food supplements;
• packaging other products requiring special documentation.

If this information is not provided, KARTON-PAK cannot automatically take into account the requirements applicable to a specific sensitive product. Article 16 of the PPWR provides for the supply of additional information required by legislation concerning contact-sensitive packaging, where applicable.

7. Countries of sale

The customer should state the countries in which:

• the packaging will be supplied;
• the product will be packed;
• the packaged product will be made available for the first time;
• the packaging is expected to become waste.

This information is particularly important for EPR obligations, national registrations and the language of the documentation and declarations.

8. Micro-enterprise status

Where the customer wishes to rely on the exception provided for micro-enterprises, it should submit confirmation of:

• the number of employees;
• the amount of turnover or balance-sheet total;
• the country of establishment;
• capital and organisational links affecting the enterprise’s status.

Simply writing in an email “we are a small company” is not enough. A “small company” in everyday language and a micro-enterprise under EU law are not always the same thing.

9. Planned environmental claims

The customer should state whether it intends to place terms or symbols on the packaging such as:

• “ecological”;
• “environmentally friendly”;
• “fully recyclable”;
• “zero waste”;
• “100% eco”;
• information on recycled content;
• its own sorting or recycling symbols.

Environmental claims should be capable of being substantiated and must not mislead recipients. The PPWR restricts the use of claims concerning characteristics that merely correspond to a mandatory minimum.

5. Manufacturer and EPR producer – they are not the same

The PPWR uses two separate concepts:

The manufacturer is determined for the packaging concerned at Union level. The EPR producer, by contrast, is determined separately for each Member State, depending on who first makes the packaging or packaged product available there. The same entity may be both the manufacturer and the EPR producer, but this is not necessarily the case.

7. Date of update and legal sources

The information published on the website is general and for information purposes only. It does not constitute individual legal advice or confirmation of the classification of specific packaging. The roles of KARTON-PAK and the customer are determined for the product concerned, taking into account its type, intended use, marking, design specification and the manner in which it is placed on the market.

The PPWR requirements will be gradually supplemented by delegated acts, implementing acts, harmonised standards and further European Commission guidance. The content of the website may therefore be updated accordingly.

The Commission itself notes that its guidance may be updated in the light of experience gained in implementing the PPWR, and that the binding interpretation of EU law ultimately rests with the Court of Justice of the European Union.

Main sources

1. Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, in particular:
   1. Article 3(1), point 13 – definition of manufacturer;
   2. Article 3(1), point 15 – definition of EPR producer;
   3. Article 3(1), point 16 – definition of supplier;
   4. Article 15 – obligations of the manufacturer;
   5. Article 16 – information obligations of the supplier;
   6. Article 21 – cases in which an importer or distributor assumes the obligations of the manufacturer;
   7. Article 38 – conformity assessment procedure;
   8. Article 39 – EU declaration of conformity;
   9. Articles 44-46 – registration and extended producer responsibility;
   10. Annex VII – conformity assessment procedure and technical documentation;
   11. Annex VIII – model EU declaration of conformity.
2. Commission Notice C(2026) 3702 final of 5 June 2026, published as C/2026/3084, in particular the part concerning the definitions of manufacturer and EPR producer.
3. Frequently Asked Questions on the Packaging and Packaging Waste Regulation, European Commission, DG Environment, publication of 30 March 2026.
4. Commission Recommendation 2003/361/EC concerning the definition of micro, small and medium-sized enterprises.