Do you import or export to the EU? The PPWR is a game-changer – find out what’s in store for you

The PPWR (Packaging and Packaging Waste Regulation) came into force on 12 February 2025 and immediately sparked a flood of questions – though not from packaging manufacturers, who were expecting the changes. The questions are coming primarily from importers and exporters, who have suddenly realised that the regulation they thought ‘didn’t apply to them’ directly changes the way they operate. If you place packaged products on the EU market or export them from the EU – the PPWR affects you more than you think.

EU importer: a responsibility that cannot be passed on to the supplier

This is one of the most important and most frequently overlooked aspects of the PPWR. If you import packaged products from outside the European Union and place them on the EU market, it is you, as the importer, who are responsible for ensuring that this packaging complies with the requirements of the Regulation. Not the manufacturer in China, Turkey or Brazil. You.

What does this mean in practice? A declaration from a non-EU supplier that their packaging is ‘compliant’ is no longer sufficient. The importer must independently verify and document that the packaging meets the requirements of the PPWR – in terms of recyclability, recycled content, restrictions on hazardous substances and mandatory labelling. In the case of beverages placed on the EU market, the scope of obligations may also include requirements relating to the operation of deposit-refund schemes.

Companies that fail to do so face specific consequences: products may be detained at the customs clearance or distribution stage, and liability for non-compliance falls directly on the importer – not on the foreign manufacturer.

Packaging documentation: a new mandatory requirement in trade

A new category of documentation requirements is emerging in international trade, which did not exist as recently as two years ago. Increasingly – both from a regulatory and a contractual perspective – the following are required:

• The material composition of the packaging – specifying individual layers and components
• Recyclability classification – according to the PPWR methodology (classes A–E)
• Content of post-consumer recycled (PCR) materials – particularly for plastic packaging
• Packaging weight per unit of product – essential for EPR reporting
• Absence of PFAS substances above permissible thresholds – mandatory from 12 August 2026 for packaging in contact with food

The absence of this data is no longer merely a formal issue. It blocks customs procedures, prevents qualification with large retail chains and – in the case of food-contact packaging – may result in a ban on placing the product on the market.

EU exporters: increasing contractual requirements from overseas customers

The situation for exporters from the European Union is a mirror image – and equally demanding. Non-EU counterparties, particularly in countries that are developing their own packaging regulations modelled on the PPWR (the UK, Canada, Australia), are increasingly expecting full packaging specifications as early as the contract negotiation stage.

In practice, this means that an exporter from Poland must be prepared to provide:

• A declaration of compliance with the PPWR for packaging placed on the EU market
• A detailed material specification for the packaging, which the foreign customer can use in their own ESG reporting
• Documentation confirming recyclability classification
• Information on the EPR scheme in which they participate as a manufacturer

Companies that have this documentation ready win tenders more quickly. Those that do not waste time on clarifications – or lose the contract.

The market rewards those who have the data – not just the product

This is a phrase every importer and exporter should bear in mind: in the new regulatory landscape, the competitive advantage does not lie with the company offering the cheapest packaging. It lies with the company that can document, within 24 hours, that its packaging complies with the PPWR requirements.

The PPWR shifts the focus from the product itself to product information. Supply chains that fail to adapt to this shift will incur delays, additional verification costs and the risk of losing contracts with customers for whom compliance with environmental regulations is now a purchasing criterion – not merely an option.

Companies that establish a packaging documentation system now will have a ready answer before the question is even asked. Companies that wait will find themselves playing catch-up with requirements that the market has already adopted as standard.