No, if 2 conditions are met: you are a micro-enterprise under Recommendation 2003/361/EC (fewer than 10 employees and turnover or a balance sheet total below €2 million) and your packaging supplier is established in the European Union. In that case, Article 15(12) transfers the Article 15 conformity obligations to that supplier. When the supplier is also in the same Member State as you, Article 3 recognises it as the manufacturer under the regulation's general definition. For a French micro-enterprise, a French supplier therefore provides the most complete legal position. This clause covers packaging conformity, however, rather than your EPR obligations: registration, EPR fees and the authorised representative remain your responsibility (see the dedicated section). If you print and assemble your packaging yourself from sheets bought in the Union, the approach is unchanged: the material is inherently compliant and your forming process raises a question only if you add a varnish or component compromising recyclability. Simply keep records of your raw materials' origin.
Read the source article: PPWR small business obligations: the micro-enterprise rule