am I responsible for the packaging if I only put my brand on it

Private label usually makes you the manufacturer yourself

Yes, in most cases, the person who places their own brand on packaging thereby becomes the manufacturer within the meaning of the PPWR — even if someone else has designed or produced the packaging. What matters is not who filled the box or who ordered the film, but whose name or brand appears on it. Anyone who has a product packaged under their own brand by a third party and places it on the market in this way is thereby designated as the party responsible for that packaging, with all the registration and reporting obligations that entails.

This applies strongly to private label, but also to white-label purchases, to own shipping boxes printed by a third party, and to products that are delivered to you already packaged by a manufacturer abroad. For the PPWR, the question "who made the packaging" is less relevant than "under whose brand does this product come to market". Anyone unsure whether this also applies to own shipping boxes without brand printing can read more about it separately at the explanation about manufacturer status in own packaging work; for those using a fulfilment partner there is a separate page on the own obligations of a fulfilment service provider.

Where this follows from: Article 3 and the guidelines on the manufacturer concept

Article 3 of Regulation (EU) 2025/40 defines the manufacturer partly on the basis of the brand under which a product is placed on the market, regardless of who actually produced the packaging. The Commission's guidelines on the concept of manufacturer (C/2026/3084) elaborate this further for situations such as private label, and confirm that applying your own brand to already existing packaging normally suffices to be classified as a manufacturer.

Because the PPWR obligation as such is the same in every EU country, but registration of it runs per country at a different register and under different conditions, the role of manufacturer in itself is not enough to know what must be done. In the Netherlands, a threshold of 50,000 kg of packaging material per year applies for the reporting obligation to Verpact, a threshold that is expected to be abolished from August 2027 onwards; anyone approaching that limit will find the details at the explanation on the Dutch 50,000 kg threshold. For supplies to Germany, a different system applies without comparable exemption, whereby registration in the German LUCID register is required from the very first package; see for that the registration obligation in LUCID from the Netherlands.