Commonly got wrong
“Anyone who puts goods in a box counts as the manufacturer of the packaging.”
Why this one goes around
The word manufacturer suggests making something, so people assume it cannot mean them, or assume it means everyone who packs anything. It is neither: it turns on whose name is on the packaging, and printed tape or a branded mailer is enough.
The rules that settle it
If a business has packaging made carrying its own name or logo, the rules treat that business as the packaging's manufacturer. That is the word the rules use, and it applies even when someone else's brand also appears on the box. Printed tape, a branded mailer or a bag with a logo are enough. Buying plain unbranded boxes is not.
Source: Regulation (EU) 2025/40, Art. 3(1), point (13) — read from this source on
The exception for very small businesses
Applies nowThere is one way out of counting as the manufacturer of packaging carrying a business's own brand. Two things both have to be true: the business is a micro-enterprise, which the rules define by staff numbers and money, and the company supplying the packaging is based in the same country. When both hold, the supplier counts as the manufacturer instead.
Source: Regulation (EU) 2025/40, Art. 3(1), point (13)(b) — read from this source on
Work out which of these apply to you · Other things people get told