Importing Products into the EU? What PPWR Means for Importers

Importing Products into the EU? What PPWR Means for Importers

If your organization imports products into the European Union, the Packaging and Packaging Waste Regulation (PPWR) may create responsibilities that go considerably further than simply asking your overseas supplier whether the packaging is compliant.

This is especially relevant for companies sourcing finished products from outside the EU.

A cosmetics company may import bottles, jars and cartons from China.

A retailer may purchase finished consumer products from the United States.

An industrial company may receive machinery packed in crates, film and protective materials from Türkiye.

In each case, the products arrive in the EU already packaged.

A common assumption is:

“The manufacturer is responsible for the packaging, so we just need them to confirm that it complies with PPWR.”

That is not quite how the Regulation works.

If your organization is the importer for PPWR purposes, it has its own obligations before the packaging is placed on the EU market.

First: who is an importer under PPWR?

PPWR distinguishes between several economic operators, including manufacturers, importers and distributors.

An importer is, broadly, an EU-established person or organization that places packaging from a third country on the Union market.

The important point is that the relevant packaging may arrive:

• empty;

• filled with a product;

• as sales packaging;

• as grouped packaging;

• as transport packaging; or

• as part of a larger packaged shipment.

So you do not necessarily need to be importing empty packaging materials to have PPWR importer obligations.

If your organization imports finished products that are already packaged, the packaging accompanying those products still needs to be considered.

The importer does not replace the manufacturer

Under Article 15 of PPWR, the manufacturer has primary responsibility for demonstrating the conformity of packaging with the applicable requirements.

Among other obligations, the manufacturer must carry out the applicable conformity assessment, prepare the technical documentation and draw up the EU Declaration of Conformity once conformity has been demonstrated.

That responsibility remains with the manufacturer.

But PPWR does not allow the importer simply to assume that those steps have happened.

Article 18 creates a separate verification obligation for importers.

Before placing packaging on the EU market, the importer must ensure that the manufacturer has carried out the required conformity assessment and prepared the technical documentation required under PPWR.

That difference matters.

The manufacturer demonstrates conformity.

The importer must ensure that the required conformity process has taken place before placing the packaging on the EU market.

Is a supplier email saying “PPWR compliant” enough?

On its own, probably not.

Imagine that your supplier sends this response:

“We confirm that all packaging supplied to you complies with EU PPWR requirements.”

That may be useful evidence of the supplier's position.

But it does not necessarily tell you:

• which packaging was assessed;

• which PPWR requirements were considered;

• who PPWR considers the manufacturer;

• whether a conformity assessment was performed;

• whether technical documentation exists;

• whether an EU Declaration of Conformity has been issued;

• what evidence supports the conclusion; or

• whether the documentation can be produced if an authority requests it.

For an importer, those distinctions are important because Article 18 expressly requires the importer to ensure that the manufacturer's conformity assessment and technical documentation exist.

What should an importer check before placing packaging on the market?

Article 18 identifies several areas that importers need to address.

Before placing packaging on the market, the importer must ensure that:

The manufacturer has completed the conformity assessment

The applicable conformity assessment procedure is established under Article 38 and Annex VII.

PPWR uses an internal production control procedure under which the manufacturer establishes the technical documentation and takes responsibility for demonstrating that the packaging satisfies the requirements applicable to it.

Technical documentation has been prepared

Annex VII sets out what the technical documentation should contain.

Depending on what is relevant to the packaging, this can include:

• a general description of the packaging and its intended use;

• design and manufacturing information;

• materials and components;

• applicable requirements;

• standards or technical specifications used;

• descriptions of how certain assessments were performed; and

• test reports.

This does not necessarily mean that an importer must physically hold every document before every shipment.

But the importer must ensure that the required documentation exists and can be made available.

The packaging meets applicable labelling requirements

Article 18 also requires importers to ensure that the packaging is labelled in accordance with Article 12, taking into account the dates on which the relevant PPWR labelling requirements become applicable.

This is an important nuance because PPWR requirements do not all begin on 12 August 2026.

Different substantive obligations have different application dates.

The required documents accompany the packaging

Where PPWR requires accompanying documentation, the importer must ensure that it is present.

The manufacturer has met its identification obligations

PPWR also contains traceability requirements relating to the identification and contact details of economic operators.

Importers themselves must indicate their name, registered trade name or trademark, postal address and, where available, electronic contact information on the packaging, subject to the Regulation's specific rules.

What does this mean when buying from a manufacturer outside the EU?

This is where PPWR may require a change in supplier-management practices.

Historically, a purchase order might contain information such as:

Product: 250 ml shampoo bottle
Material: PET
Colour: clear
Quantity: 50,000
Price: €0.21/unit

Under PPWR, that commercial specification may eventually need to sit alongside much more structured compliance information.

For example:

Who manufactured the packaging?

If your finished-product supplier purchases the packaging from somebody else, you may need to understand that upstream relationship.

What is the exact packaging specification?

Documentation should be traceable to the packaging actually being imported.

What materials and components are involved?

A bottle, cap, label, adhesive, sleeve and pump may each involve different materials and suppliers.

Which PPWR requirements apply?

Not every PPWR requirement applies to every packaging format at the same time.

What evidence demonstrates conformity?

Depending on the requirement, this could involve calculations, material specifications, declarations, test reports or other supporting documentation.

Does an EU Declaration of Conformity exist?

Where the relevant conformity process has been completed, the manufacturer is responsible for drawing up the EU Declaration of Conformity under Article 39 and Annex VIII.

The Declaration of Conformity matters, but so does what sits behind it

The EU Declaration of Conformity is a central PPWR document.

Annex VIII requires it to identify, among other things:

• the packaging;

• the manufacturer;

• the object of the declaration;

• the relevant Union legislation; and

• the standards, common specifications or other technical specifications used.

But the declaration is not supposed to exist in isolation.

It is the outcome of the conformity assessment.

Behind it should sit the technical documentation required under Annex VII.

For an importer, this leads to an important practical question:

If an authority challenged the conformity of this packaging tomorrow, could the supporting documentation actually be produced?

Does the importer have to keep the technical documentation?

PPWR makes an important distinction here.

Importers must keep a copy of the EU Declaration of Conformity available to market-surveillance authorities.

They must also ensure that the technical documentation can be made available to those authorities upon request.

The retention periods are:

• five years for single-use packaging; and

• ten years for reusable packaging,

calculated from the date the packaging was placed on the market.

So an importer needs more than a one-time supplier exchange.

It needs a process for maintaining access to evidence over time.

That becomes particularly important when suppliers change, products are discontinued or employees leave.

What happens if you think the packaging is not compliant?

PPWR does not allow an importer to ignore obvious gaps.

If an importer considers, or has reason to believe, that packaging does not comply with the applicable requirements, it must not place that packaging on the market until the packaging has been brought into conformity.

And if non-compliance is identified after the packaging has already been placed on the market, Article 18 provides for corrective measures, potentially including bringing the packaging into conformity, withdrawing it or recalling it, depending on the circumstances.

This makes supplier due diligence more than an administrative exercise.

It can directly affect whether a product can be placed on the market.

A practical example

Consider an EU cosmetics company importing finished skincare products from China.

The Chinese supplier manufactures the product and arranges the primary and secondary packaging.

The shipment arrives containing:

• a glass jar;

• a plastic cap;

• an inner seal;

• a printed carton;

• labels; and

• transport packaging.

The supplier tells the EU company:

“All packaging is PPWR compliant.”

A stronger importer workflow would be to identify each relevant packaging specification and establish:

1. Who is responsible for the packaging design and manufacture?

2. What are the materials and components?

3. Which PPWR requirements currently apply?

4. Has the manufacturer carried out the required conformity assessment?

5. Does the relevant technical documentation exist?

6. Is there an EU Declaration of Conformity where required?

7. Can the supporting evidence be produced if requested?

8. Are the required economic-operator and packaging identification details in place?

This does not mean creating unnecessary paperwork for every shipment.

It means establishing a repeatable compliance process for the packaging specifications your organization imports.

The biggest challenge may be upstream

For many importers, the hardest part of PPWR will not be interpreting the Regulation.

It will be obtaining structured, reliable information from non-EU suppliers.

A supplier may:

• have never heard of PPWR;

• misunderstand which requirements already apply;

• send a generic compliance certificate;

• provide test reports that cannot be linked to the packaging;

• rely on information from its own packaging supplier;

• provide documentation in inconsistent formats; or

• confirm compliance without having completed a formal conformity assessment.

This is why importer readiness increasingly depends on supplier readiness.

Organizations may need to start integrating PPWR questions into:

• supplier onboarding;

• packaging specifications;

• purchase agreements;

• quality processes;

• product launches;

• compliance questionnaires; and

• document-retention systems.

Importing compliant products is not the same as demonstrating compliant packaging

PPWR places much greater emphasis on evidence and traceability.

For an importer, the key question is therefore no longer simply:

“Did our supplier tell us the packaging complies?”

It becomes:

“Can we demonstrate that the required conformity process has taken place and that the documentation supporting this packaging can be produced?”

That is a very different standard.

And for organizations importing significant numbers of products or packaging specifications into the EU, building that process now can prevent a much larger documentation problem later.

Are you importing products or packaging into the EU?

Join our upcoming PPWR Academy webinar for a practical look at what the Packaging and Packaging Waste Regulation means for manufacturers, importers, distributors and other organizations placing packaging on the EU market.

We will cover roles and responsibilities, packaging data, supplier evidence, technical documentation, conformity assessment and the practical steps organizations should be prioritising now.

Register for the upcoming webinar:
https://events.ppwracademy.com/webinar/