I import products from outside the EU - what are my PPWR obligations?

If, as an entity established in the EU, you place on the market packaging or a packaged product originating from outside the Union, then as a rule you are the importer. This means you may not place the packaging on the market until you have verified that the manufacturer carried out the conformity assessment, drew up the technical documentation and the declaration of conformity, and met the labelling requirements.

This is one of the most common traps for trading companies: the assumption that all responsibility can be left with the foreign producer. You cannot base compliance solely on a supplier's assurance that "everything meets the standards".

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Who is an importer within the meaning of PPWR?

According to the European Commission's guidance, an importer is an entity established in the European Union that places on the market packaging or a packaged product originating from a third country (outside the EU). If you source goods from, for example, China, Turkey, the USA or the UK and are the first to make them available on the EU market, then as a rule you are the importer.

Watch out for the legal structure: the importer role cannot be assigned to a branch of a foreign company, because it has no separate legal personality. In practice, many structures based solely on a VAT registration in Poland do not meet the PPWR requirements - an entity established in the EU is needed.

You cannot shift responsibility onto a non-EU supplier

This is the most important principle for an importer. A statement from a third-country producer does not release you from the obligation to verify the packaging's compliance and does not transfer responsibility outside the EU.

In practice this means that a mere "certificate from the supplier" is not enough. The importer should hold a copy of the declaration of conformity and secure access to the complete technical documentation, so that it can be made available to the authorities on request (within 10 days of receiving the request). A general factory statement may be insufficient if it does not confirm that the specific requirements applicable to the given packaging have been met.

If the supplier's documentation does not provide a sufficient basis to confirm compliance, the importer may need additional test results or analyses - especially for food-contact packaging. The scope of testing depends on the material, the packaging's intended use, the identified risks and the separate rules on food-contact materials (for PFAS there is currently no single harmonised test method - the Commission's guidance proposes a staged approach).

The importer's specific obligations

An importer may place on the market only packaging that complies with PPWR. The most important obligations (Article 18) include:

1. verifying that the manufacturer carried out the conformity assessment and drew up the technical documentation (TD) and the declaration of conformity (DoC)
2. checking the required labelling, documents and the data identifying the manufacturer
3. placing your own importer details on the packaging or in an acceptable alternative form (see below)
4. not placing packaging on the market if you have reason to believe it is non-compliant
5. retaining a copy of the DoC and ensuring the availability of the TD for 5 years (single-use packaging) or 10 years (reusable packaging)
6. ensuring that storage and transport conditions do not jeopardise the packaging's compliance
7. taking corrective action and informing the authorities when you detect non-compliance (and, where necessary, withdrawing or recalling the packaging)
8. ensuring traceability - who supplied the packaging to you and to whom you passed it on
9. making the documentation available to the authority within 10 days of a request

What details must the importer place on the packaging?

This is a specific and often overlooked obligation. The importer must indicate its name, registered trade name or trademark, postal address and - where available - electronic means of contact. The details should appear on the packaging; where this is not possible, they may be placed on a data carrier or in a document accompanying the product.

If the importer places packaging on the market under its own name or trademark, or modifies it in a way that may affect compliance, it is treated as the manufacturer. It is then responsible, among other things, for the conformity assessment, the technical documentation and issuing the declaration of conformity. This is a common case with imports under an own brand. (The micro-enterprise exception applies only where the packaging supplier is in the EU - for direct imports from outside the EU it will, as a rule, not apply.)

Importer vs EPR producer - two different things

As with an own brand, you need to separate two concepts that are easy to confuse:

• The importer is responsible for the packaging's compliance (verifying the DoC/TD, documentation, labelling, traceability).
• The producer is a role in the extended producer responsibility (EPR) system - registration, reporting and financing of waste management, determined separately for each Member State in which the packaging is first made available.

In practice, importing from outside the EU very often means you are also a producer for EPR purposes in the country where you first make the goods available. In Poland this is handled, among other things, through entry in the BDO database and annual reports.

For sales to other EU countries the model is key: if you sell imported products directly to end users in other EU countries, you may become an EPR producer in each recipient country - in which case registration and the appointment of an authorised EPR representative will be required. For sales to a foreign distributor the classification may look different - the EPR producer in the destination country may then become that distributor.

Watch out for two different concepts: an authorised representative of the manufacturer (who performs specific tasks regarding the packaging's compliance) is not the same as an authorised EPR representative (who fulfils the producer's obligations in the EPR system in a specific country). These are two separate roles with separate definitions.

Not sure about your situation? Check in 2 minutes

The classification depends on where you source the goods from, who first makes them available on the market, whether you operate under your own brand and which countries you sell to. The quiz asks the right questions and indicates your role (or roles), your EPR status, and the most important obligations and deadlines.

Sample result: "Importer + potentially an EPR producer in Poland. You must verify the DoC and TD, ensure the correct importer details, and put your BDO obligations in order. For direct sales to end users in other EU countries, check the obligation to register and appoint an EPR representative."

Check your role under PPWR ->

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After the quiz you can receive, to your business e-mail, a checklist of obligations matched to an importer's profile - all you need is an address and a company name.

Importing many products? Here's how to organise it

With a wide range of goods sourced from many suppliers, manually verifying documentation per packaging item quickly becomes a bottleneck. Plan Be Eco automates collecting data from suppliers (including foreign ones), validating the applicable PPWR requirements, and gathering and organising declarations of conformity - with a single set of data entered once at component level.

See how to manage PPWR when importing ->

FAQ - imports from outside the EU and PPWR

I source goods from China - am I an importer under PPWR?

As a rule yes, if you are established in the EU and are the first to place on the EU market a packaged product originating from a third country. You are then responsible for the packaging's compliance with PPWR. The exact classification depends on the structure - a mere VAT registration in Poland without an entity established in the EU may not be enough.

Can I shift responsibility onto a non-EU supplier?

No. Responsibility for the packaging's compliance cannot be passed on to a third-country supplier. Its statement does not release you from the obligation to verify compliance, hold a copy of the declaration of conformity and ensure the availability of the complete technical documentation. A general "factory statement" is often insufficient if it does not confirm that the specific requirements applicable to the given packaging have been met.

As an importer, do I have to issue the declaration of conformity (DoC)?

As a rule no - the declaration is issued by the manufacturer. The importer must verify that the DoC and technical documentation exist and are correct, retain a copy of the DoC and ensure the availability of the TD. However, if you place packaging on the market under your own name or trademark, or modify it, you are treated as the manufacturer - and then it is you who issues the declaration (drawn up for each type of packaging).

What is the difference between the importer's role and that of the EPR producer?

The importer is responsible for the packaging's compliance (verifying the DoC/TD, documentation, traceability). The producer is a role in the EPR system (registration, reporting, financing of waste management), determined separately for each Member State. An importer from outside the EU is very often simultaneously the importer and the EPR producer in the country of first making available.

I sell imported products to several EU countries - what about EPR?

In each Member State where you make packaging available, you may be subject to separate EPR registration and reporting. A seller from outside a given country is sometimes required to appoint an authorised EPR representative. It is worth checking this individually for each market, because the rules differ between countries.

I import food or products with food-contact packaging - what to watch out for?

From 12 August 2026, PFAS limits for food-contact packaging will start to apply. Regardless of this, packaging is already subject to a limit of 100 mg/kg for the total content of lead, cadmium, mercury and hexavalent chromium, which PPWR maintains. Particular care is needed especially for grease- and moisture-resistant packaging and for products for which the supplier has not provided reliable documentation or test results.

Update: June 2026. This article reflects the European Commission's guidance C(2026) 3702 final of 5 June 2026 on the application of Regulation (EU) 2025/40 (PPWR), including the definition of the importer and the distinction between roles in the supply chain.

The above content is for educational and informational purposes only. It does not constitute legal advice or a legal opinion and may not be relied upon as the basis for decisions in an individual case. Classifying your role under PPWR depends on the specific facts - if in doubt, consult a legal adviser or a compliance specialist.

Plan Be Eco is a Polish SaaS platform for ESG and EU-regulation compliance, with a PPWR module that guides you through the full compliance path - from supplier data to a signed declaration of conformity.

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