No theory — just what you, as the EU importer, need to do, how your supplier should prepare, and who takes responsibility.
PPWR in one sentence
The EU has turned its 30-year-old Packaging Directive into a directly applicable Regulation. Since 12 August 2026, it has been uniformly enforced across all 27 member states. Any packaging entering the EU is covered — cartons, plastic bags, tapes, labels, cushioning foam — everything counts.
What does this mean for you? Non-compliance → customs detention → your customer cannot collect the goods → return or destruction → member-state fines, and possible exclusion from the EU market.
I. What PPWR requires — 5 key points
- Heavy metals limit: The sum of Pb, Cd, Hg and Cr(VI) in each packaging material must be ≤ 100 mg/kg. Your Chinese supplier must test each homogeneous material and provide the reports. You keep copies.
- PFAS limits: For food-contact packaging, single PFAS ≤ 25 ppb, total PFAS ≤ 250 ppb, total fluorine ≤ 50 ppm. Your supplier must provide a declaration; you keep it.
- Declaration of Conformity (DoC): The packaging manufacturer compiles the technical file, but the DoC must be signed by an EU-based legal entity — your company or your authorised representative. You bear legal responsibility.
- EPR registration: You must register for packaging EPR in each EU country where you place the goods on the market, obtain registration numbers (e.g., LUCID for Germany, Citeo for France), or appoint a VAT agent.
- Technical file archiving: You must keep all documents from the above steps for 5–10 years. Customs may request them at any time.
II. 3 common pitfalls for importers
Pitfall 1 — Thinking one test report covers everything
Different materials = different homogeneous materials = separate tests. The carton, its ink, the tape and the glue each need their own heavy metals report. Ask your supplier to provide one report per material.
Pitfall 2 — Assuming reports expire every year
Same supplier, same material, same process → the report is valid indefinitely. Only a change of supplier or material requires new testing. Make sure your supplier informs you if that happens.
Pitfall 3 — Thinking your Chinese supplier can sign the DoC
The DoC must be signed by an EU-based legal entity — that is your company or your authorised representative. Your supplier's job is to supply the complete technical file; yours is to sign it and keep it on record.
In short: your supplier provides the evidence; you sign and assume legal responsibility.
III. What your supplier should do — and what you must do
Your supplier should complete all preparatory work on their side. Below is the four-step plan you should request from them.
Step 1 — Packaging BOM
Your supplier should break down every packaging component and list material, supplier and test requirements. Each homogeneous material must be identified.
Step 2 — Testing
Your supplier should send each material to an accredited lab (e.g., SGS, Intertek, TÜV) for heavy metals testing and provide the reports. For food-contact items, PFAS declarations should also be obtained.
Step 3 — Technical file compilation
Your supplier should gather all documents: BOM, test reports, supplier declarations and material safety data sheets. This file is what you will use when signing the DoC.
Step 4 — Archiving
Your supplier should set up a compliance archive for each order, storing documents for at least 5 years (we recommend 10 years).
Now you must take prompt action
1. EPR registration: Confirm whether your company is already registered for packaging EPR in each EU country where the goods will be placed on the market. If yes, provide the registration numbers (e.g., LUCID for Germany, Citeo for France, etc.) to your supplier. If not, register immediately or appoint a VAT agent.
2. DoC signing: Designate a contact person to receive the technical file and sign the DoC on behalf of your company. Remember, this is your legal obligation under PPWR.
3. Authorised representative: If your company does not have an EU establishment, appoint an EU-based authorised representative to handle regulatory matters.
IV. Division of responsibilities
- Packaging BOM: Your supplier prepares and provides it; you verify.
- Heavy metals testing: Your supplier arranges and supplies reports; you keep copies.
- PFAS compliance: Your supplier obtains and shares declarations; you keep copies.
- DoC technical file: Your supplier compiles the full file; you sign the DoC.
- EPR registration: You register (or appoint an AR).
- Packaging labelling: Your supplier prints according to your instructions; you confirm label content.
- Document archiving: Your supplier archives for 5–10 years; you keep synchronised copies.
- Customs inspection support: Your supplier provides documents upon request; you handle matters on the EU side.
Core principle: your supplier provides the evidence; you sign and bear liability.
PPWR places legal responsibility on the EU-based entity — your company or your authorised representative. Customs clearance is also your responsibility.
However, the evidence chain starts with your supplier. Without their test reports, material declarations and BOM, you cannot sign the DoC, and customs will detain the goods.
So for you, PPWR is not about whether to "do testing" — it is about ensuring your EPR registration and DoC signing are completed before the cargo arrives.
Final reminder
The regulation is already in force. Port delays due to missing documents are far more expensive than the compliance work itself.
Ask your supplier for:
- Confirmation of EPR registration status and numbers,
- A DoC signatory contact,
- Confirmation of your authorised representative (if any).
Make sure these are in place before the cargo arrives at the EU port.