Not always; this is the first question to resolve. The regulation defines packaging by its function: containing, protecting, handling, delivering or presenting a product (Article 3). An item needed to contain or preserve the product throughout its life is not packaging when it is an integral part of the product. Annex I gives an indicative list: items that are not packaging include graveyard lights (containers for candles), toolboxes, printer cartridges and flowerpots intended to be sold with the plant. In our reading, a jar designed to hold a candle throughout its use follows the same logic. Beware of misleading comparisons: a sweets box is still packaging, and a tea bag or coffee capsule is packaging under the regulation. When your container is not packaging, it requires neither a declaration of conformity nor a packaging EPR fee (éco-contribution): your obligations concern the shipping box and void fill. There are two qualifications: describing such an object as reusable is an environmental claim (in French) that must remain accurate, and what happens to it at the end of its life must be described accurately.
Read the source article: Who is affected by PPWR? Company roles and obligations