EPR fundamentals

    Brand owner

    The company whose brand appears on a packaged product, and the first party in the EPR responsibility hierarchy in nearly every jurisdiction.

    A brand owner owns or licenses the trademark under which a packaged product is sold. Because the brand is the most visible and stable identifier on a pack, regulators use it as the anchor for producer responsibility: it is far easier to trace a pack back to its brand than to its converter or filler.

    The distinction matters most in private label and contract manufacturing. When a retailer sells goods under its own label, the retailer is the brand owner and carries the obligation, even though it never touched the packaging line. When a co-packer fills and packs for a brand, the co-packer is not the brand owner and should not report that tonnage.

    Licensing arrangements complicate this. If a licensee manufactures and sells under a licensed brand in a market, the licensee is usually treated as the obligated party in that market, because it is the entity placing the goods on the market rather than the trademark holder abroad.

    Related terms

    • Producer (obligated party)

      The legal entity responsible for registering and paying EPR fees on packaging, usually the brand owner and otherwise the importer or first seller.

    • Authorised representative

      A locally established entity appointed to carry a foreign producer's EPR obligations in a market where the producer has no establishment.

    • Placed on the market

      The legal moment when packaging first becomes available in a jurisdiction, determining which entity and which year the obligation falls in.

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