Am I a manufacturer if I pack my own boxes?

Whoever fills their shipping box is usually the manufacturer

Yes, in most cases you are the manufacturer of your shipping box if you pack your own products in it yourself and send the box under your own name to the end user. The definition of "manufacturer" in Article 3 of Regulation (EU) 2025/40 is based on who fills the packaging and places it on the market — not on who produced the cardboard box itself. An online shop that purchases empty boxes, fills them with ordered items and ships them is the party that places the packaging on the market for the first time, and thus bears the manufacturer obligations: the EU declaration of conformity according to Annex VIII, name and postal address on the packaging, and registration in the producer register.

One exception deserves attention: if the brand owner is a micro-enterprise (fewer than ten employees and maximum €2 million turnover or balance sheet total) and the supplier of the shipping box is located in the same country, then that supplier is the manufacturer, not you. If the supplier is located in another country, this exception does not apply and the filling obligation remains with you. Where you must subsequently register varies by country: in the Netherlands a threshold of 50,000 kg per year applies which is expected to be removed once the PPWR producer register becomes operational, at the earliest 12 August 2027, whereas Germany has no threshold and registration in LUCID is already mandatory from the first shipped box.

What this is based on: Article 3 and the guidelines on the manufacturer concept

The qualification as manufacturer follows from the definition in Article 3 of Regulation (EU) 2025/40, which names the filling and placing on the market of packaging as the determining criterion, and is further specified by the Commission guidelines C/2026/3084 of 10 June 2026, which also clarify the micro-exception and the condition regarding the Member State of the supplier.