PPWR for importers: Obligations when importing packaged goods

What does “importer” mean under the PPWR?

The PPWR is the European regulation on packaging and packaging waste. It applies directly in EU Member States and sets requirements for packaging design, conformity, labelling and extended producer responsibility. Put simply, an importer is a company established in the EU that places packaging or packaged products from a third country on the Union market for the first time. A third country is a country outside the EU, such as Switzerland, the United Kingdom, the United States or China. The actual supply and distribution chain is decisive. Not every purchase abroad automatically means that the buyer qualifies as an importer under the PPWR in every scenario. In particular, the following must be assessed:

• Who brings the goods into the EU from the third country?

• Who places the packaging or packaged product on the EU market for the first time?

• Under whose name or brand is the packaging or product offered?

• Is another company in the supply chain already responsible for importation and placing the goods on the market?

It is also important to distinguish between importer, manufacturer and producer. These terms serve different functions under the PPWR. The manufacturer is primarily responsible for packaging conformity. The producer bears the obligations of extended producer responsibility (EPR). EPR means that a responsible company bears, among other things, the costs of collecting and recovering packaging waste. Depending on the business model, an importer may also be a producer or, where goods are sold under its own brand, even a manufacturer.

PPWR for importers: These obligations apply before placing goods on the market

The importer’s core verification obligation is set out in Article 17 of the PPWR. An importer may place packaging or a packaged product on the market only where the required conformity assessment has been carried out and the required documents and information are available.

1. Check the manufacturer’s conformity assessment

Before import approval, the importer must check whether the manufacturer has carried out the required conformity assessment procedure. This process assesses and documents whether the packaging meets the PPWR requirements applicable to it. The importer does not automatically carry out this assessment itself. However, it must satisfy itself that it has been performed correctly. A general statement such as “EU compliant”, without being linked to the specific packaging, is not a reliable basis for this purpose.

2. Check the technical documentation and EU declaration of conformity

Technical documentation is the evidence file for the packaging. It may include a packaging description, material data, technical drawings, applied standards, calculations and test reports. Its content and scope depend on the applicable requirements and Annex VII of the PPWR. The EU declaration of conformity is the manufacturer’s formal declaration that the packaging meets the specified PPWR requirements. The importer should check at least the following:

• Are the relevant legal provisions and, where applicable, standards listed?

• Do the declaration, packaging specification and delivered goods match?

• Is the declaration clearly assigned to the specific packaging or packaging family?

• Is the responsible manufacturer named?

The importer must generally retain a copy of the EU declaration of conformity for five years after the packaging is placed on the market. The period is ten years for reusable packaging. The importer must be able to make the technical documentation available upon a reasoned request from a competent authority.

3. Check labelling and manufacturer information

The importer must verify whether the packaging bears the labelling required under the PPWR and whether the manufacturer’s mandatory information is present. The precise labelling required depends on the packaging and timing, as several labelling obligations will only apply after further transitional periods or once supplementary legal acts have been adopted. In addition, the importer must provide its name, registered trade name or registered trade mark, postal address and an electronic means of contact. This information must generally appear on the packaging. Where this is not possible, it may, in accordance with the PPWR, appear on an accompanying document.

Companies should therefore not use a standard label template without first assessing the type of packaging, space constraints and the applicable start date of each labelling obligation.

4. Do not approve goods where there are doubts about conformity

If the importer has reason to believe that packaging does not comply with Articles 5 to 12 of the PPWR, it must not place it on the market until conformity has been established. This includes, for example, requirements for substances in packaging, recyclability, recycled content, packaging minimisation and certain reusable packaging. Where the packaging presents a risk, the importer must also inform the manufacturer and the competent market surveillance authority. The response to the identified non-conformity should be documented.

Which obligations apply after importation?

Responsibility does not end with import approval. During the period for which they are responsible, importers must ensure that storage and transport conditions do not compromise the packaging’s conformity. This can be relevant, for example, where moisture, heat, incorrect stacking or subsequent repackaging changes the packaging’s properties or labelling. If an importer later finds or suspects that packaging it has placed on the market is non-conforming, it must immediately arrange appropriate corrective measures. Depending on the case, conformity may need to be restored, goods withdrawn or recalled. If there is a risk, the competent authorities of the Member States in which the packaging was made available must be informed. In particular, the non-conformity and the measures taken must be described. Importers must also keep records of complaints, non-conforming packaging, withdrawals and recalls, and keep distributors informed about relevant monitoring measures.

Importer and EPR: Why a conformity check alone is not enough

Packaging product conformity and extended producer responsibility are two separate areas of obligation. An existing EU declaration of conformity therefore does not replace EPR registration or any required packaging licence. Under the PPWR, the producer is the company in the supply chain responsible for EPR obligations in a Member State. Put simply, this depends on who first makes packaging or packaged products available in the respective Member State and where the packaging is likely to become waste. The European Commission emphasises that, as a rule, one producer should be identified for each package. For a German importer, this may mean checking the following in addition to importer obligations:

• Registration in the packaging register;

• Reporting the relevant packaging quantities;

• Participation of packaging subject to system participation in an approved system – commonly referred to as a packaging licence;

• Obligations for packaging not collected through household collection systems.

Which German obligation applies in a specific case depends on the packaging type, distribution channel, place of waste generation and applicable national implementing legislation. This assessment should be documented separately so that conformity and EPR are not confused.

Practical implementation: PPWR import verification in seven steps

1.  Record the import portfolio. Create a list of all packaging and packaged products sourced from third countries. Record the item number, supplier, country of origin, import route, brand, packaging components and target markets.

2.  Clarify the economic operator’s role for each supply chain. Document who is the manufacturer, importer, distributor and producer. Do not rely only on Incoterms or customs information: they can provide indications but do not replace the legal role assessment under the PPWR.

3.  Request documents contractually. Include the supply of up-to-date PPWR documentation in purchasing terms and supplier contracts. Require a clear link to the item, packaging version and production period.

4.  Perform the document review. Check the EU declaration of conformity, technical documents, labelling and contact details using a standard checklist. Define which deviations trigger a delivery block.

5.  Compare a sample with the goods. Compare the documents with the actual packaging. Do the material, dimensions, components, label and version match? A correct document for an outdated packaging version is not sufficient.

6.  Assess EPR obligations separately for each target country. If you sell in several EU Member States, check the producer role and EPR implementation in each Member State. Registration in Germany does not automatically cover obligations in other countries.

7.  Set up a change and escalation process. Supplier changes, material changes or new labels must be reported and assessed before use. Define contacts in procurement, quality, product development, logistics and compliance, as well as a process for blocking, correction, withdrawal and authority contact.

Common mistakes with PPWR imports

Checking only the product

Packaging is a regulated product in its own right. CE marking or conformity of the packaged product does not automatically prove PPWR conformity of the packaging.

Accepting supplier statements without verification

General certificates without a link to the item and version are often insufficient for a robust import check.

Treating importer and producer as the same role

The two roles can coincide, but they do not have to. Roles must be clarified for each supply chain and Member State.

Treating labelling deadlines as a blanket rule

The PPWR has generally applied since 12 August 2026, but not every individual substantive or labelling obligation begins on that date.

Overlooking changes after initial approval

New films, adhesives, coatings or suppliers may make a renewed assessment necessary.