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Importing packaging from China — your PPWR obligations

If you import goods or packaging from China, Turkey or another country outside the EU, PPWR treats you as an importer, and very often as a manufacturer too. The difference is large: an importer verifies and keeps someone else's documentation, while a manufacturer draws up the EU Declaration of Conformity itself. Most brands that import packaging under their own name are in fact manufacturers without realising it.

When you are actually the manufacturer (not "just" an importer)

This is the most important point. If you place packaging on the market under your own name or brand, or modify it in a way that could affect conformity, the regulation considers you the manufacturer and you are subject to the manufacturer's obligations (Article 21, together with the definition in Article 3). That means you yourself carry out the conformity assessment, compile the technical documentation (Annex VII), and draw up and sign the EU Declaration of Conformity (Annex VIII) under your own responsibility.

There is a relief for micro-enterprises, but only if the packaging supplier is in the EU. Because a supplier in China or Turkey is outside the EU, that relief does not apply and the manufacturer's obligation stays with you.

Importer obligations (Article 18)

If you are not the manufacturer but an importer of packaging made by someone else, before placing it on the market you must:

  • verify that the manufacturer carried out the conformity assessment and drew up the technical documentation and the EU Declaration of Conformity;
  • check that the packaging carries the required markings and manufacturer details (Article 15);
  • indicate your own name and address (and electronic contact, if any) on the packaging;
  • keep a copy of the EU Declaration of Conformity and ensure the technical documentation can be made available to the authorities for 5 years (single-use) / 10 years (reusable packaging);
  • on a reasoned request from the authorities, provide the documentation, generally within 10 days.

If you have good reason to believe the packaging is non-conforming, you must not place it on the market until that is corrected.

What to demand from a non-EU supplier

Before ordering, request (and secure contractually):

  1. the EU Declaration of Conformity under Annex VIII (and if you are the manufacturer, draw it up yourself; the supplier's is not enough);
  2. the technical documentation (Annex VII), or a commitment to make it available to the authorities;
  3. evidence of substance compliance (Article 5): heavy metals ≤ 100 mg/kg and, for food-contact packaging, PFAS test reports;
  4. correct markings and information on the packaging.

The liability is yours, not the factory's

Once you place packaging on the EU market, you are the economic operator answerable for it. You cannot shift responsibility to the supplier. If the declaration is missing or not drawn up correctly, if the technical documentation is incomplete, or if markings are absent, that is formal non-compliance (Article 62): the authority will require it to be remedied, and if that fails, it can prohibit, withdraw or recall the packaging from the market. Exceeding substance limits (e.g. PFAS) runs through a separate route: packaging presenting a risk.

For contrast, a distributor (Article 19), which merely resells the goods, has lighter duties: it checks that registration, markings and the declaration are in place, but does not have to keep the declaration or the technical documentation itself. Note that importer and manufacturer obligations apply from 12 August 2026, with no separate importer date.

For wider context see the guide to Regulation (EU) 2025/40 and what changes for the packaging declaration of conformity. We're preparing a free EU Declaration of Conformity template. Leave your email and we'll send it the moment it's ready.

This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your imports, consult a professional.