New PPWR Requirements for Importers: What Changes from 12 August 2026?

From 12 August 2026, the first set of provisions of Regulation (EU) 2025/40 of the European Parliament and of the Council (PPWR) will come into force. The new regulation changes the rules governing the placing of packaging on the European Union market.

The new requirements also apply to importers bringing goods into the EU from outside the European Union, who will be required to verify that packaging complies with the requirements of the regulation.

Here’s an overview of the changes coming into force and how businesses can prepare for their new obligations.

What is the PPWR?

The PPWR (Packaging and Packaging Waste Regulation) is a new EU regulation governing the design, labelling and placing on the market of packaging, as well as the management of packaging waste.

The regulations apply to all entities involved in the circulation of packaging on the EU market, including manufacturers, importers, distributors and producers.

What provisions will apply from 12 August 2026?

The first stage of PPWR implementation includes, among other things:

• Restrictions on the use of PFAS substances in packaging intended to come into contact with food.
• A limit on the content of heavy metals (lead, cadmium, mercury and hexavalent chromium) in all packaging — a maximum of 100 mg/kg.
• New obligations for importers related to confirming that packaging complies with PPWR requirements.

What obligations will importers have?

Importers will only be permitted to place packaging on the market if it complies with the requirements set out in the PPWR.

This means that importers will need to ensure that the manufacturer has:

• carried out a conformity assessment;
• prepared the required technical documentation;
• drawn up an EU Declaration of Conformity;
• applied the required labelling;
• provided all information necessary to demonstrate the packaging’s compliance.

In addition, importers will be required to retain the relevant documentation for 5 or 10 years, depending on the type of packaging, and make it available at the request of the competent authorities.

When does an importer become a manufacturer?

The PPWR sets out situations in which an importer assumes the obligations of a manufacturer — Article 21 of the PPWR.

This applies when the importer:

• places packaging on the market under its own name;
• uses its own trademark;
• modifies the packaging in a way that may affect its compliance with the applicable requirements.

In such cases, the importer becomes responsible, among other things, for carrying out the conformity assessment, preparing the technical documentation and issuing the EU Declaration of Conformity.

Will the documentation be required for customs clearance?

The new regulations do not require technical documentation or the EU Declaration of Conformity to be attached to the customs declaration.

This does not mean, however, that these documents will not be needed.

Market surveillance authorities or customs authorities may request access to the documentation both before and after the packaging is placed on the market.

The PPWR also expands the possibility of conducting packaging compliance checks at the EU’s external borders.

How can companies prepare for the new regulations?

Businesses importing goods from outside the EU should already be taking steps to:

• identify which goods and packaging fall under the scope of the PPWR;
• verify packaging compliance with the applicable PFAS and heavy-metal limits;
• obtain technical documentation and EU Declarations of Conformity from manufacturers;
• verify that all required importer identification details are complete and correct;
• implement procedures for retaining the required documentation;
• assess whether the way packaging is labelled or modified could result in the importer assuming the obligations of a manufacturer.

How does ATC Cargo support importers?

The changing regulatory landscape demonstrates how important it is to properly prepare the import process before goods enter the European Union.

At ATC Cargo, we support importers not only with the organisation of international transport and customs clearance, but also with documentation preparation and coordination of the import process.

By working with experienced partners, we help reduce the risk of delays and issues resulting from failure to meet new formal requirements.

Need support with imports from outside the EU?

The new PPWR requirements place additional obligations on importers regarding the verification of packaging compliance and documentation.

Preparing for these changes in advance can help businesses avoid problems during the import process and subsequent inspections.

Our specialists help importers and exporters select optimal logistics solutions, reduce risk and optimise the costs of international transport.

Phone: +48 518 283 876
Email: kontakt@atc-cargo.pl

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