The criterion is not who exports, but who decides what the packaging looks like.
The "manufacturer" as defined by the regulation covers two categories: ① The person who actually manufactures the packaging ② The person who commissions the design or manufacturing, and who markets it under their own name or trademark
The second point is critical and commonly misunderstood. The person paying for the packaging is not necessarily the person who decides what it looks like.
Three common scenarios: • The packaging is the supplier's own design and brand, exported unchanged → the supplier signs • The packaging specifications are set by the user, or printed with the user's/their customer's brand, or the user repackages after delivery → the user signs themselves • Pallets, stretch film, and collection outer boxes applied by the user → the user signs themselves (the most easily overlooked item)
One company often has all three situations and must handle them separately—it cannot use a single company-wide setting.