Role checker
Every packaging stream is different - your own-brand mailers are not your supplier's plain boxes, and goods that arrive already packaged from outside the EU are a third case again. The regulation assesses each one separately, so this checker does too: answer for one packaging type, read the result, then run it again for the next type.
Ten questions, one packaging type
Based on the answers you gave, here is what the regulation attaches to this one packaging type. It restates the rule against your answers - it doesn't assess your compliance, and where a declaration of conformity is required, it is signed by the responsible company, not by us.
Marketplace
You said you sell through a marketplace such as Amazon, eBay or Etsy. Before letting you list, the marketplace must already hold your registration number for the consumer's country Regulation (EU) 2025/40, Art. 45(4), and if you use a fulfilment provider, it must swiftly suspend your service if that registration information is missing or wrong Art. 45(8). Get your registration numbers in place before you rely on that channel.
Manufacturer
You said this packaging is printed to your own specification and your company is above the micro-enterprise thresholds. Based on your answers, the regulation attaches manufacturer obligations to this packaging stream: because it carries your name or trademark, the regulation treats you as its manufacturer Art. 3(1)(13). That means placing on the market only packaging that meets Articles 5-12 Art. 15(1), carrying out a conformity assessment and drawing up the Annex VII technical documentation before you sell it Art. 15(2), signing the EU declaration of conformity Art. 15(2), and keeping both for 5 years, or 10 if the packaging is reusable Art. 15(3).
Not a clean case
You said only the tape, labels or stickers are yours - the box or bag itself is bought-in stock. Packaging you specify under your own brand falls within the manufacturer definition Art. 3(1)(13), but no fact establishes whether Article 15's duties then attach only to that tape, label or sticker or to the whole package - Commission guidance instead describes a single manufacturer responsible for the whole of Articles 5-12 Commission Notice C/2026/3084, section 2. This is a case the regulation's text doesn't settle cleanly, so this tool won't guess at where the line falls - it's worth a closer look with us. The distributor-tier checks on the bought-in box itself still apply regardless (see below).
The carve-out applies
You said your printed packaging comes from a supplier in your own EU country and your company is below the micro-enterprise thresholds Recommendation 2003/361/EC, Annex, Art. 2(3). Both of the regulation's carve-out provisions agree on this case: Article 3(1)(13)(b) requires a supplier in the same Member State Art. 3(1)(13)(b), and Article 15(12) requires a supplier located in the Union Art. 15(12) - your supplier satisfies both, so the regulation shifts the manufacturer role onto them instead of you. Your task is to request the technical documentation and declaration of conformity from your supplier, not to produce them yourself.
Not settled by the text
You said your printed packaging comes from a supplier elsewhere in the EU - not your own country - and your company is below the micro-enterprise thresholds Recommendation 2003/361/EC, Annex, Art. 2(3). The regulation's own text disagrees with itself here: Article 3(1)(13)(b) requires the supplier to be in the same Member State as you Art. 3(1)(13)(b), which a different-country EU supplier doesn't satisfy, while Article 15(12) requires only that the supplier be located in the Union Art. 15(12), which it does. Whether the carve-out reaches your case isn't settled by the text alone - worth working through with us before you rely on it either way.
The carve-out doesn't reach this supplier
You said your printed packaging comes from a supplier outside the EU, and your company is below the micro-enterprise thresholds. Both of the regulation's carve-out provisions require an EU-located supplier Art. 15(12), Art. 3(1)(13)(b) - a non-EU supplier doesn't qualify on either reading. Based on your answers, manufacturer obligations attach to you after all: conformity assessment, Annex VII technical documentation and the EU declaration of conformity Art. 15(1)-(3). Chasing that documentation from a non-EU supplier is usually the heaviest part of getting compliant.
Importer
You said the goods you sell arrive already packaged from outside the EU. Based on your answers, the regulation attaches importer obligations to this stream: before you place the packaging on the market you must verify its manufacturer already carried out the conformity assessment and holds the Annex VII technical documentation Art. 18(2), and you must keep the declaration of conformity yourself and be able to produce the technical documentation for 5 years, or 10 for reusable packaging Art. 18(7). If any of this packaging is food-contact, PFAS limit values have applied since 12 August 2026 Art. 5(5) - ask your supplier for evidence covering that too.
Distributor
You said the box or bag itself is bought-in stock from a supplier in the EU (whether or not you also add your own tape or labels). Based on your answers, the regulation attaches distributor obligations to this stream: before making it available you must be able to verify the producer is registered in its national producer register Art. 19(2) - ask your supplier for their registration number rather than assuming it exists.
Mixed sources
You said the goods behind this packaging come from a mix of sources. Each source is assessed separately under the regulation, so treat "made by us", "EU supplier" and "imported" as three different runs of this checker rather than one blended answer - the role, and the obligations, differ by source.
What you add yourself
You said you add a box, filler or tape before a parcel leaves you. Whatever you add and place on the market for the first time makes you the producer of that packaging in that country Art. 3(1)(15) - it goes in your register under your own name, on top of whatever role attaches to the packaging you didn't add.
Countries
You said you ship this packaging type to: . In each of those countries, you must be registered before you supply there for the first time - unregistered supply isn't allowed Art. 44(4) - and the national authority can take up to twelve weeks to issue a registration number once your application is complete Art. 44(11)(b), so it's worth starting early. Because you ship to more than one country, from 12 August 2026 you also need an EPR authorised representative in each country other than your own where you sell directly to end users Art. 45(3).
Reusable packaging
You said some of this packaging is designed to be reused. Records for reusable packaging are kept for 10 years rather than 5 Art. 15(3), and a reuse system carries its own separate requirements this tool doesn't size - worth a direct conversation.
Baseline duties
Based on your answers, no manufacturer, importer or distributor role attaches to this specific packaging stream beyond the baseline every economic operator carries: know who supplied you and who you supplied it to, and be able to say so for 5 years, or 10 for reusable packaging Art. 22(2).
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