PPWR importer obligations: what changes when your manufacturer is outside the EU

Who counts as an importer under PPWR

An importer is any natural or legal person established in the EU that places packaging or packaged product from a third country on the EU market for the first time. It does not matter whether packaging is your core business — if you import shampoo in bottles, the bottles, caps, labels, cartons and pallet wrap are all your packaging.

• Brands sourcing finished goods from Asia and selling them under their own name
• Distributors and wholesalers importing directly from non-EU suppliers
• Online sellers importing stock into an EU fulfilment centre
• Companies importing components that arrive in transport packaging

Your core obligations

Before placing packaging on the market, the importer must verify that the non-EU manufacturer has done its homework — and be able to prove it.

• Verify the conformity assessment was carried out and a Declaration of Conformity (Annex VII) exists
• Check that the packaging carries correct material identification and sorting labelling
• Ensure identification of the manufacturer and of the importer appears on the packaging or accompanying documents
• Keep the Declaration of Conformity and technical documentation for 5 years and provide it on request
• Ensure storage and transport do not compromise compliance
• Take corrective action, withdraw or recall non-compliant packaging and inform authorities

When you become the manufacturer

PPWR contains a role-shift rule familiar from other EU product law: if you place packaging on the market under your own name or trademark, or modify already-placed packaging so that its conformity is affected, you assume the full obligations of the manufacturer. Private-label importers are almost always in this position.

That means you — not your supplier in Shenzhen — own the technical documentation, the conformity assessment, the recyclability performance grade and the recycled-content evidence.

EPR on top: Articles 44 and 45

Product conformity is only half the story. As the first entity placing packaging on a national market, the importer is also the EPR producer in that country: registration in the national producer register, an authorised representative where required, annual reporting of packaging placed on the market by material and weight, and payment of eco-modulated fees.

This is a per-country obligation. Selling into 8 EU markets means 8 registrations, 8 fee schedules and 8 reporting calendars — with different deadlines, units and material categories.

The 10-day request you should expect

In practice the first PPWR pressure will not come from an inspector — it will come from your customer. Retailers and B2B buyers are already adding contractual clauses requiring a Declaration of Conformity within short deadlines, often 10 working days. If your supplier data is spread across e-mail threads and spreadsheets, that deadline is very hard to meet.

A practical readiness checklist

• Map every SKU to its packaging components, materials and weights
• Collect supplier declarations, recycled-content evidence and recyclability data
• Identify which entity in your group is the legal importer per market
• Confirm EPR registrations in every country you sell to
• Set up a repository where a Declaration of Conformity can be produced in days, not weeks
• Add PPWR clauses to purchase contracts with non-EU suppliers

How EPRPilot helps

EPRPilot keeps packaging data at component level, links it to each SKU and market, tracks registrations and deadlines across all 27 member states, and generates audit-ready documentation — so an importer can answer a customer request or an inspection from one place.