2 ms·

Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue. [1]https://op.europa.eu/en

• kakoni 2mo ago
  According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
  • anigbrowl 2mo ago
    I'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
    • kakoni 2mo ago
      Sorry, messed up the terms here. You became producer. From the earlier faq that parent posted; > The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
      • IsTom 2mo ago
        In the following > If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State. That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.