Simply put, a producer is the party that first offers a product that is subject to EPR requirements. A party can also be a producer if it meets the following criteria:
• produces a product in the country and sells it domestically, or
• imports a product into the country in which it is based, or
• sells a product in a country in which it is not physically based.
If you are unsure whether EPR is your responsibility, you should seek professional advice.