The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has been in force since August 12, 2026. If you import packaged goods into the EU, you are expected to keep a PPWR compliance file ready and to show it to a market surveillance authority on request. Below we explain which documents actually prove conformity, what already applies today, what comes later, and how to organize your file when you import from China.
Who is responsible for PPWR compliance – the importer or the Chinese manufacturer?
Under Article 15 of the PPWR, only packaging that meets the requirements of Articles 5 to 12 may be placed on the market, and this duty does not fall on the manufacturer alone. It also applies to importers and distributors. If you bring in goods in packaging from China, you are the operator placing that packaging on the EU market, so you are responsible for its compliance. You cannot pass that responsibility to your supplier through any contract clause.
Article 18 sets out what an importer must do. From August 12, 2026, you have to make sure that the non-EU manufacturer has carried out the conformity assessment procedure (Article 38) and drawn up the declaration of conformity, that the packaging meets the labeling rules in Article 15(5) and (6) (unique identification plus the manufacturer’s name and address), and that the required documents travel with the goods. You must also add your own name, postal address, and an electronic contact on the packaging or on an accompanying document. This applies to generic and unbranded packaging too: the absence of information on the packaging does not remove your responsibility to prove compliance.
What already applies from August 12, 2026 – and what comes later
The biggest mistake importers make is assuming they have until 2030. It is true that the requirements for recyclability, recycled content, minimization, and empty-space limits phase in from 2030, and that harmonized sorting labels start in 2028. But three sets of requirements apply with no transition period as of August 12, 2026:
- the general duty to minimize substances of concern,
- a combined limit on four heavy metals (lead, cadmium, mercury, and hexavalent chromium together at no more than 100 mg/kg),
- PFAS limits in food-contact packaging.
Looking for the test panel behind each parameter? See our guide to PPWR packaging requirements.
The three documents that actually prove conformity
1. EU Declaration of Conformity (Article 39)
The EU Declaration of Conformity is a written statement that the packaging meets the regulation. The manufacturer draws it up based on information from suppliers (Article 16), and it covers the whole packaging unit rather than each separate component. For a unit made of a bottle, a cap, and a label, one assessment and one declaration cover all the parts.
You must draw up the declaration in the language of the member state where the packaging is placed on the market – for the German market in German, for the French market in French.
2. Technical documentation (Annex VII)
The technical documentation must make it possible to assess whether the packaging meets Articles 5 to 12, and at a minimum it includes the conceptual design, the manufacturing drawings, and a list of the materials used in the components. This is where the lab test results go.
You cannot delegate the duty to compile this file. Even if you outsource the testing to a laboratory, responsibility for the file itself stays with the operator placing the packaging on the market. Keep the documentation for 5 years for single-use packaging and 10 years for reusable packaging.
3. Conformity assessment procedure (Article 38)
The conformity assessment is the process that demonstrates the requirements are met. The manufacturer can run it in-house or have a laboratory or certification body do it on their behalf.
Carry out the assessment for each packaging type, meaning each format or production series, not each material. If the same bottles come in different sizes and the difference does not affect any requirement in Articles 5 to 12, one declaration is enough. Transport packaging is treated separately: pallets, collars, films, and straps each need their own assessment and their own declaration.
The most common mistake: a supplier statement is not proof
A Chinese supplier’s “PFAS-free” statement, or a declaration that nothing was added on purpose, is not proof of compliance. The PFAS restriction applies regardless of whether the substance was added intentionally or ended up in the material as a contaminant. Proof means a Certificate of Analysis from an accredited laboratory, issued for the specific packaging type. A single report covering a “whole product line” is not enough – for example, a result for 12-micron LDPE film does not prove that a laminate or a 50-micron film complies.
In practice, this means three steps. First, verify the supplier before you make your compliance depend on them – a China Credit Report shows whether the company is reliable. Second, write the PPWR requirements into your commercial contract as enforceable clauses, since the Commission specifically advises importers to make contractual arrangements with third-country manufacturers. Third, secure sampling for testing during production through quality control in China.
How enforcement will work after August 12, 2026
The European Commission has said that enforcement should not disrupt trade. Under Article 62, when an authority finds non-compliance, it first asks the operator to correct it and allows time for corrective action. Only if the problem is not fixed can a member state ban sales or order a recall or withdrawal. This is not a free pass, though: missing documentation at the first inspection means testing in emergency mode and a real risk that sales are halted if you cannot complete your evidence in time.
For imported goods, packaging is considered placed on the market when it is released for free circulation after customs clearance; goods that only transit the EU are not subject to PPWR.
Frequently asked questions about PPWR
Is the importer or the Chinese manufacturer responsible for PPWR compliance?
Legal responsibility for packaging placed on the EU market lies with the importer. The importer must make sure the non-EU manufacturer has carried out the conformity assessment and drawn up the declaration of conformity, and must add its own contact details to the packaging. This responsibility cannot be shifted to the supplier by contract.
Which documents prove that packaging complies with PPWR?
Three documents: the EU Declaration of Conformity (Article 39), the technical documentation under Annex VII, and a documented conformity assessment procedure (Article 38). Keep the technical documentation for 5 years for single-use packaging and 10 years for reusable packaging.
Which PPWR requirements already apply from August 12, 2026?
The duty to minimize substances of concern, the heavy-metals limit (lead, cadmium, mercury, and hexavalent chromium combined at no more than 100 mg/kg), and PFAS limits in food-contact packaging. There is no transition period for them. Recyclability, recycled content, and minimization requirements phase in from 2030, and labeling from 2028.
Is a supplier’s “PFAS-free” statement enough as proof?
No. A statement that no PFAS were added, or that none were added intentionally, is not proof of compliance. You need a certificate from an accredited laboratory, issued for the specific packaging type, because the limit applies regardless of whether the substance was added on purpose.
When is imported packaging considered placed on the market?
For imported goods, placing on the market generally happens when the goods are released for free circulation after customs clearance. Goods that only transit the EU, without being released for free circulation, do not have to meet PPWR requirements.
From August 12, 2026, you are responsible for checking the non-EU manufacturer, the labeling, and the accompanying documents, and the substance limits (heavy metals, PFAS, substances of concern) apply with no transition period. ExamineChina helps you verify your supplier, write PPWR requirements into your contract, and collect samples for testing on-site in China. Contact us and secure your imports.