The European National Registers for Packaging (EUNR) has clarified the legal definitions of ‘producer’ and ‘end user’ under the EU Packaging and Packaging Waste Regulation (PPWR), including for sales and grouped packaging applications.

The EUNR, representing authorities from 16 EU Member States, defines a 'producer' as the first economic operator in the domestic supply chain. If the packaging is manufactured domestically, the manufacturer is the producer; if imported, the first company in the domestic supply chain is considered the producer. Overseas companies are only treated as producers if they deliver packaging directly to a private or commercial end user.

For transport, service, and primary production packaging that is filled before reaching its final form—including sales packaging, grouped packs, and flexible formats—the supply chain legally begins at the point of filling. In contrast, rigid packaging that is in its final form upon manufacture starts its legal life cycle empty.

The 'end user' is defined as the final consumer or industrial entity using the packaged product, not the packaging material itself. Packers or fillers importing packaging materials to package their own products are not considered end users.

Martin Engelmann, director general of the German Plastic Packaging Association, stated that the EUNR guidance provides clearer rules for grouped and sales packaging than the European Commission’s previous guidance released in March and June 2026.

The clarification follows ongoing discussions, including a non-paper circulated by the Czech Republic requesting guidance on Annex V’s exemption for packaging necessary for handling. Industry leaders have also urged the Commission to consider delaying deadlines, suggesting that restrictions on plastic shrink wrap for multipacks may realistically require a 2035 compliance timeline.