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Comment by l-one-lone | Hacker News Reader

The terminology is confusing. Under the PPWR, a “producer” is not necessarily someone who manufactures packaging. The regulation also covers businesses selling packaging or packaged products directly to end users in another Member State. So a maker shipping a board in an envelope can indeed be the packaging producer for EPR purposes.

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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/publication-detail/-/publication/ad1...

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.

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.

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.

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.

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