Who Owns PPWR Risk in Private Label
TL;DR: Under PPWR, private-label retailers will generally be treated as the manufacturer when packaging is designed or produced under their own name or trademark. That means retailers cannot delegate the overall compliance responsibility to suppliers. The central risk is fragmented packaging evidence. Product specifications, supplier declarations, artwork versions and market records may sit across different teams and systems, making it difficult to prove that the documentation matches the packaging currently on shelf. Private-label teams should measure evidence coverage at SKU and packaging-component level, prioritize the highest-risk products and make supplier documentation part of product development and packaging change control before PPWR applies from 12 August 2026.
