Foundations
PPWR importer requirements
Last regulatory verification: 12 August 2026 · 3 official sources
Importers cannot place packaging on the EU market on trust. What to verify before shipment, what to keep, and what to do when something is missing.
Free PPWR Check60 seconds. Find out whether this packaging should be reviewed.Short answer
An importer may only place packaging on the EU market after verifying that the manufacturer has carried out the conformity assessment, that the Annex VII technical documentation exists, and that the packaging is labelled and identifiable as required. The importer must also keep a copy of the EU Declaration of Conformity and be able to produce it on request.
The importer's position is weaker than it looks
Importers frequently assume the obligation sits entirely with the overseas manufacturer. Legally, the manufacturer's obligation does not travel with the goods into the EU in any enforceable way — the authority in the Member State of placement deals with the operator it can reach. That is the importer. Where the importer sells packaging under its own name or brand, or modifies it, it takes on the manufacturer's obligations outright.
Pre-shipment verification checklist
Confirm the conformity assessment was actually carried out
Not that the supplier says the packaging is compliant — that an assessment against the applicable PPWR requirements was performed for this configuration.
Usually held by: Manufacturer
Obtain and read the EU Declaration of Conformity
Check it identifies this configuration, names a real legal entity, is signed and dated, and lists provisions that actually apply.
Usually held by: Importer keeps a copy
Confirm the Annex VII technical documentation exists and can be produced
Ask for the index at minimum. A supplier who cannot show a structure has not built the file.
Usually held by: Manufacturer, retrievable by the importer
Check identification and contact details on the packaging
Type, batch or serial identification, plus the importer's name, registered trade name and address as required.
Usually held by: Importer
For food-contact packaging, obtain PFAS evidence
Total fluorine screening and, where triggered, targeted analysis per component. Coated papers, moulded fibre and greaseproof grades are the usual problem areas.
Usually held by: Manufacturer or the coating supplier
Record retention
Keep the Declaration and your verification record for five years after the packaging is placed on the market.
Usually held by: Importer
What to do when the supplier cannot produce the file
Where importers get caught
Three patterns recur. Private-label goods, where the importer's brand makes it the manufacturer for PPWR purposes without anyone noticing. Marketplace and drop-ship models, where nobody has claimed the importer role at all. And "compliance certificates" from overseas suppliers that reference the wrong legislation entirely — often a food-contact certificate offered in place of a packaging Declaration.
Importer, manufacturer, producer
These are three separate roles and a single company can hold all three. Import duties are conformity duties under PPWR; producer duties are extended producer responsibility duties registered nationally. See manufacturer vs producer for how they differ and why holding one does not discharge the other.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- Commission PPWR GuidanceCommission guidance
- EU Access2MarketsOfficial implementation / research
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.