Having looked into FAQ[1] it seems that it's mostly the case if you sell in branded packaging and are >10 people or >2M eur revenue.
reply[1]https://op.europa.eu/en/publication-detail/-/publication/ad1...
According to the PPWR rules, if you (as a webshop) package your shipment in non-branded box and send it from another EU country to another, then you are considered to be manufacturer(=you were the first to bring this into market) and EPR/PPWR rules apply. There is no exemption for this.
replyI'm more inclined to believe the person who backed up their argument with a citation, especially after looking at the document they linked which expressly contradicts you.
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