d1e478-1-1__para

A manufacturer is a natural or legal person who manufactures packaging or a packaged product. It is not necessarily the natural or legal person that physically produces the packaging. Two elements need to be considered: (1) the role in the design or manufacturing of packaging criterion and (2) the trademark or the branding criterion. If the packaging or packaged product carries a certain name or trademark, it can be assumed that the owner of that name or trademark is the ‘manufacturer’ pursuant to Article 3(1), point (13)(a), as it will have the decisive power in the contractual relation with its suppliers and will therefore be able to determine also the packaging characteristics.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.