Comment by l-one-lone
8 hours ago
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.
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.