Glossary
Manufacturer
Also called: packaging manufacturer
What it means in practice
A business does not need a factory to hold this role. Putting a logo on a mailer or ordering printed tape is enough, because the name on the packaging is what the rules look at rather than who ran the machine.
The rules that give it meaning
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
Anyone counting as the manufacturer of packaging writes a short document saying the packaging meets the design rules. It is called an EU declaration of conformity. The rules fix what goes in it and set out a model to follow. It has to be kept up to date, and written in a language the country where the packaging is sold asks for. Signing it means taking responsibility for what it says.
Source: Regulation (EU) 2025/40, Art. 39 — read from this source on
Commonly got wrong about this
Buying plain unbranded boxes does not make a business the manufacturer. Putting its own name or logo on the packaging does.