PPWR Obligations of Importers: Bringing Packaged Goods into the EU

Since 12 August 2026, Article 18 of the PPWR (Regulation (EU) 2025/40) obliges every importer, a person established in the EU that places packaging from a third country on the EU market, to check, mark and document that packaging before it is sold. The importer does not design the packaging or assess its conformity; it verifies that the manufacturer outside the Union has done so.

Article 18 is one of the operator duties in the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40 of 19 December 2024, in force since 11 February 2025. An importer makes four checks under Art. 18(2), adds its own contact details under Art. 18(3) and keeps records for 5 years (single-use packaging) or 10 years (reusable packaging) under Art. 18(7). Where it first makes the packaging available in its own Member State, the same company is usually also the producer for extended producer responsibility (EPR).

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every value on this page is checked against EUR-Lex and Commission guidance, see our methodology and fact-checking.

The key facts of the PPWR importer obligations are summarised in the table below.

Who Is an Importer under the PPWR?

Under Art. 3(1)(17) PPWR, an importer is any natural or legal person established within the Union that places packaging from a third country on the market. The German text calls the role Importeur and the French text importateur. Importer, distributor and manufacturer are separate PPWR definitions in Art. 3(1).

The importer is one of seven economic operators listed in Art. 3(1)(12) PPWR: the manufacturer, the supplier, the importer, the distributor, the authorised representative, the final distributor and the fulfilment service provider.

Can a non-EU company be the importer under the PPWR?

No: the importer must be established within the Union, so a company established in a third country cannot hold the importer role. Commission Notice C/2026/3084 (OJ C, 10.6.2026), section 4, which is non-binding, adds two limits: a branch without legal personality cannot qualify as importer or distributor, and VAT registration alone is not establishment. This page covers the EU rule only. What a supplier outside the Union must hand over to its EU importer is covered under PPWR for non-EU exporters.

When is the importer also the manufacturer?

An EU importer is the manufacturer when the packaging or packaged product is designed or manufactured under its own name or trademark, since Art. 3(1)(13)(a) PPWR makes that person the manufacturer.

There is always only one manufacturer in a supply chain, according to Notice C/2026/3084, section 2. Art. 21 PPWR, titled "Case in which obligations of manufacturers apply to importers and distributors", deals with this shift. An importer that becomes the manufacturer takes on the full PPWR manufacturer obligations.

When Is Imported Packaging Placed on the EU Market?

Imported packaging is placed on the market when it is released for free circulation, according to Commission Notice C/2026/3084, section 5, and the PPWR rules in force on that day apply to it.

The Notice and the Commission's PPWR FAQ (non-binding) are non-binding PPWR guidance, and where they differ from the Regulation, the Regulation prevails.

Does packaging in transit have to comply?

No: goods in transit that are not released for free circulation do not need to comply with the PPWR, according to the Commission's PPWR FAQ (non-binding), section X. The obligations of Art. 18 start with the release for free circulation.

Can imported packaging placed on the market before 12 August 2026 still be sold?

Yes: packaging placed on the market before 12 August 2026 may remain on the market, but packaging produced or imported before that date and released afterwards must comply when it is placed on the market. The Commission's PPWR FAQ (non-binding), section X, states that such stock does not have to be destroyed, remanufactured or re-labelled. For the PFAS limits in food-contact packaging there is no sell-off period at all.

What Must a PPWR Importer Check before Placing Packaging on the Market?

Before placing packaging on the market, the importer must ensure four things under Art. 18(2) PPWR: the manufacturer has carried out the conformity assessment and drawn up the technical documentation, the packaging is labelled under Art. 12, the required documents accompany it, and the manufacturer has met Art. 15(5) and (6).

The four Art. 18(2) checks are listed below.

1. Point (a): the manufacturer has carried out the conformity assessment procedure of Art. 38 and drawn up the technical documentation set out in Annex VII. The importer checks that both exist; it does not perform the assessment itself.
2. Point (b): the packaging is labelled in accordance with Art. 12. The harmonised material label of Art. 12(1) applies from 12 August 2028 at the earliest, or 24 months after the Art. 12(6) implementing acts, whichever is the latest.
3. Point (c): the packaging is accompanied by the required documents. For stock produced before 12 August 2026, the Commission's PPWR FAQ (non-binding), section X, accepts the Art. 15(5) and (6) manufacturer data in an accompanying document.
4. Point (d): the manufacturer has complied with Art. 15(5) and (6). Art. 15(6) covers the manufacturer's own identification on the packaging or through a data carrier.

The technical documentation stays a manufacturer document, which the importer must be able to make available to authorities under Art. 18(7). What the Annex VII file contains is set out under PPWR technical documentation.

Does imported packaging need a notified body, a CE mark or an EU declaration of conformity?

It needs an EU declaration of conformity but no notified body and no CE marking: PPWR conformity assessment is the internal production control of Annex VII, carried out by or for the manufacturer. Art. 38 PPWR includes no third-party assessment, and the PPWR provides no CE marking and no PPWR certificate.

The manufacturer draws up the EU declaration of conformity under Art. 39 PPWR, one per packaging type, following the Annex VIII model. The manufacturer signs the EU declaration of conformity and the importer keeps a copy; the EU declaration of conformity page shows the Annex VIII contents.

How Must the Importer Be Identified on Imported Packaging?

Under Art. 18(3) PPWR the importer must indicate its name, registered trade name or registered trademark, postal address and, where available, electronic means of communication on the packaging, through a data carrier or in a document accompanying the packaging. These details appear alongside the manufacturer's own identification under Art. 15(6), so imported packaging carries two sets of contact details.

The Art. 18(3) details and where they may be placed are listed below.

• Name of the importer.
• Registered trade name or registered trademark.
• Postal address.
• Electronic means of communication, where available.
• Placement: on the packaging, through a digital data carrier, or in a document accompanying the packaging.

Does the address duty apply to unbranded packaging materials?

Yes: the importer's address duty also covers imported generic or unbranded packaging materials, and a shipping document may serve for the Art. 18(2)(d) check, according to the Commission's PPWR FAQ (non-binding), section X.

Which Records Must a PPWR Importer Keep, and for How Long?

An importer keeps a copy of the EU declaration of conformity at the disposal of market surveillance authorities and ensures the technical documentation can be made available to them, for 5 years for single-use packaging and 10 years for reusable packaging (Art. 18(7) PPWR). Under Art. 18(8) PPWR, the importer provides the documents within 10 days of a reasoned request from a national authority.

Art. 22 PPWR adds a traceability record: on request, every economic operator identifies the suppliers that supplied it and the customers it supplied, again for 5 years (single-use) or 10 years (reusable). The importer's three records are compared in the table below.

Which PPWR Requirements Fall on the Importer of Packaging?

Several PPWR requirements name the importer next to the manufacturer: the REACH fluorine proof of Art. 5(5), the recycled content proof of Art. 7(6) and the minimisation duty of Art. 10(1). The Art. 6(3) recyclability grades apply to all packaging placed on the market, imported packaging included. Every design rule is explained under PPWR requirements for packaging.

The user of transport packaging under Art. 29 is the operator placing the product on the Union market in it, which may be the manufacturer, importer or distributor (Notice C/2026/3084, point 20). The targets apply to imported goods from the first EU warehouse to the final EU destination, and consignments with a single final destination need not be repacked (point 19). The table below lists the five provisions and their dates.

Is the Importer Also the Producer under PPWR EPR?

An importer that makes packaging or packaged products available for the first time in its own Member State is usually the producer there, and must then register in that Member State's producer register under Art. 44 PPWR. Art. 3(1)(15) PPWR defines the producer in five points, (a) to (e); points (a) and (b) cover first making available on the territory where the operator is established. There is one producer per packaging unit per Member State, and there is no de minimis exemption from registration. Registration, reporting and fees follow from EU packaging EPR under the PPWR.

A third-country seller that supplies an EU business is not the producer; the EU importer or distributor is. Logistics companies that unpack or repack goods from third countries are the producer of the original transport packaging, according to recital 123.

A third-country seller that supplies end users directly is treated differently. Under points (c) and (d), a manufacturer, importer or distributor established in a Member State or in a third country that makes packaging or packaged products available for the first time on the territory of another Member State directly to end users is the producer there. The five producer cases are compared in who is the producer under the PPWR.

Must a non-EU producer appoint an EPR authorised representative?

Only in some cases: Art. 45(3) PPWR requires an EPR authorised representative from producers that supply end users directly in another Member State, and lets each Member State require one from producers established in third countries. The first sentence applies in each Member State other than the producer's own.

Germany used the option: under VerpackDG § 5(2), third-country producers without a German establishment appoint an EPR authorised representative, since 12 August 2026. Proposal COM(2025) 982 (procedure 2025/0395(COD)) would suspend Art. 45(3) until 1 January 2035; the European Parliament adopted amendments on 20 October 2026 (T10-0345/2026) and referred the file back to the ENVI committee, according to the Legislative Observatory. Nothing is suspended as of 24 October 2026. When an authorised representative for EPR is mandatory, and the proposed suspension, are explained there.

What Happens When Imported Packaging Does Not Comply?

Missing, false or incomplete importer contact details, or any other unmet administrative requirement of Art. 18, are formal non-compliance under Art. 62(1)(e) and (f) PPWR. If the formal non-compliance persists, Art. 62(2) PPWR leads to a prohibition of making the packaging available on the market, a recall or a withdrawal.

The PPWR itself sets no fine amount: Member States lay down penalty rules under Art. 68 PPWR and notify them by 12 February 2027, as explained under PPWR penalties and market surveillance.

How Do Importer Obligations Fit into PPWR Compliance for Every Operator?

The importer is one of seven economic operators in Art. 3(1)(12) PPWR and the link between a manufacturer outside the Union and the distributors that sell inside it. Upstream, the manufacturer assesses conformity and draws up the documentation; downstream, the distributor, defined in Art. 3(1)(18), makes the packaging available. The duties of every other operator are listed in the PPWR compliance plan.

Is the Article 17 authorised representative the same as the importer?

No: the Art. 17 authorised representative is an optional mandatary of the manufacturer, established in the Union, while the importer is the EU-established person that places third-country packaging on the market. The representative acts under a written mandate, and the Art. 15(1) duties and the drawing up of the technical documentation cannot form part of it (Art. 17(2), last subparagraph). The representative's tasks are listed in Article 17 in the PPWR legal text.

What do distributors check after the importer?

Distributors, defined as operators other than the manufacturer or importer that make packaging available, verify that the producer is registered in the Art. 44 register and that the packaging is labelled under Art. 12. Unlike the 10-day limit of Art. 18(8) for importers, Art. 19(6) sets no 10-day limit for distributors; the full list is under PPWR obligations of distributors.

Do customs authorities check PPWR compliance at the border?

Art. 61 PPWR links market surveillance to customs: measures taken under Art. 58(5) are communicated to the authorities designated under Art. 25(1) of Regulation (EU) 2019/1020 through the customs risk management environment. Under Art. 61(4), an automated interconnection operates no later than 24 months from the adoption of the implementing act under Art. 61(5). Art. 66 PPWR adds the PPWR as point 75 to Annex I of Regulation (EU) 2019/1020 (OJ L 169, 25.6.2019, p. 1), the EU market surveillance regulation.