PPWR for Importers & International Traders: Your Obligations as a Placing-on-Market Operator from 12.08.2026
Anyone who imports goods from third countries – such as China, India or Turkey – into the EU and places them on the market for the first time bears full manufacturer responsibility under Packaging Regulation (EU) 2025/40 (PPWR). For direct importers, the principle is clear: PPWR obligations cannot be transferred to a foreign supplier – neither contractually nor in practice. Anyone who, for example, has goods produced via Alibaba and sells them in the EU under their own name is the placing-on-market operator and must fulfil all requirements independently.
Direct Importer = Placing-on-Market Operator: What This Means in Practice
Under Art. 3 PPWR, the placing-on-market operator is any natural or legal person who makes a packaged product available on the EU internal market for the first time. If you import goods from China, Hong Kong or another third country and distribute them in Germany or another EU member state, you are automatically the responsible economic operator – regardless of whether your Chinese supplier provides their own conformity documentation. Such documentation is irrelevant for the EU market unless it is based on an EU-authorised representative registration and PPWR-compliant packaging design.
Four Core Obligations You Must Fulfil by 12.08.2026
1. Packaging minimisation and recyclability (Art. 6–10 PPWR): All packaging you place on the market must meet the new design requirements. These include minimum recycled content shares, maximum void space in secondary packaging, and the complete elimination of certain substances (e.g. PFAS above threshold values). Assess every import packaging during the product development phase, before the production mould is finalised in the Far East.
2. Labelling obligations (Art. 11 PPWR): From the deadline, packaging requires harmonised labels identifying the recyclable material fraction as well as QR code-based consumer information. As the importer, you are responsible for ensuring these labels are present on the packaging – even if the product is physically printed in China. Allow lead times of at least 6–8 weeks for artwork changes.
3. Registration and EU authorised representative (Art. 13 PPWR): Companies based outside the EU must appoint an EU authorised representative. If your company is based in Germany, you yourself are the EU authorised representative – a separate appointment is not required. However, you must register correctly in the national registers (in Germany: LUCID with the Stiftung Zentrale Stelle Verpackungsregister).
4. Due diligence towards suppliers: Do not rely on your Alibaba supplier to automatically guarantee PPWR compliance. Request technical documentation, conduct material testing and retain declarations of conformity. In the event of market surveillance checks by customs authorities or regional authorities, you are required to provide information.
Amazon FBA from China: No Free Pass
A particularly relevant borderline case concerns Amazon sellers who store and sell Chinese goods via FBA warehouses in Germany. Here too, the rule applies: the seller registered in the EU reporting system is the placing-on-market operator. Insist on PPWR-compliant packaging before the goods leave the Chinese port – retrospective repackaging in EU warehouses is expensive and logistically demanding.
Compliance Starts Before the Customs Border
Integrate PPWR assessment into your procurement process. Add a PPWR compliance clause to your standard supplier contract, request material data sheets (e.g. in accordance with ISO 14021) and set remediation deadlines. The customs clearance process is not the right moment to discover that packaging does not meet EU requirements.
For legally sound advice on your specific import constellation, please contact your responsible Chamber of Commerce and Industry (IHK).
Häufige Fragen
- Can I contractually oblige my Chinese supplier to guarantee PPWR compliance and thereby be released from liability?
- No. Contractual clauses with foreign suppliers do not release you from EU placing-on-market responsibility. You may grant your supplier recourse claims for remediation costs, but you remain the responsible economic operator vis-à-vis EU authorities and consumers at all times. Compliance is your obligation, not your supplier's.
- I order via Alibaba and have goods delivered directly to my German warehouse. Do I still need an EU authorised representative?
- Since your company as a German entity is based in the EU, you yourself are the EU authorised representative within the meaning of the PPWR. Appointing a separate external party is not required. However, you must register correctly as a placing-on-market operator in the LUCID register of the Stiftung Zentrale Stelle Verpackungsregister and report your packaging volumes there.
- From when must my import packaging carry the new labelling under Art. 11 PPWR?
- The binding deadline is 12.08.2026. Transitional provisions apply to packaging already placed on the market before this date that is still in commercial circulation. For new orders from your supplier, however, you should act now: artwork changes and new editions of packaging formats have lead times of several months in manufacturing practice.
- What happens if my imported goods are objected to at customs due to non-PPWR-compliant packaging?
- Market surveillance is the responsibility of national authorities, but customs can act as an enforcement arm. Possible consequences range from warnings and fines to a marketing ban on the packaging in question. Since you are liable as the placing-on-market operator, it is advisable to maintain PPWR conformity documentation already at the supplier selection stage and at the latest during incoming goods inspection.
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