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With the Packaging and Packaging Waste Regulation (PPWR), the European Union is establishing uniform requirements for packaging and its recycling. In this context, the terms manufacturer and producer are defined differently and carry different legal implications.
Manufacturer or Producer – What’s the Difference?
In simple terms:
Manufacturer
The manufacturer produces the packaging or the packaged product itself, or has it developed or produced under its own name or brand. The manufacturer is responsible for the conformity of the packaging – including technical documentation, conformity assessment and declaration, and labelling.
Producer
The producer is – depending on the supply chain – the manufacturer, importer, or distributor who first places the packaging or packaged product on the market in the relevant country. The producer bears the financial responsibility for subsequent waste management under extended producer responsibility (EPR), including registration and participation in a compliance scheme.
Under the PPWR, ER-elektronik GmbH qualifies as both manufacturer and producer: we package our luminaires under our own name, and as a company based in Germany, no other business precedes us in the supply chain – so both roles apply to us simultaneously.
Our Responsibility
As both manufacturer and producer, ER-elektronik GmbH takes on all obligations arising from the PPWR.
This includes registration with the Stiftung Zentrale Stelle Verpackungsregister (LUCID), Germany’s central packaging register foundation. For participation in the dual system, we work with ZENTEK Smart as our waste management partner.
Labelling Our Packaging
Together with our packaging material suppliers, we have prepared the required declarations of conformity. The corresponding conformity numbers are applied to the packaging of our technical luminaires.
Currently, labelling is done via a separate label. Going forward, we plan to integrate the conformity numbers directly into the customer-specific product labels and apply them together on the packaging.
Our Packaging at a Glance
Packaged Products
- Technical luminaires
Field of Use
- For commercial use only
Our Customers
- Specialist retailers
- Electrical wholesalers
- Electrical installation companies
Packaging Materials Used
- Corrugated cardboard
- Cardboard/carton
- Paper
- Recyclable plastics in accordance with applicable European packaging requirements
Sustainability and Material Selection
To the best of our current knowledge, the packaging materials we use do not contain any substances subject to reporting requirements.
Together with our suppliers, we are continuously working to further optimise packaging, consistently avoid environmentally harmful substances, and implement the requirements of European packaging regulations. In doing so, we make an active contribution to resource conservation and to fostering a functioning circular economy.
