I import from China under my own brand – what do I need to do?

As an importer bringing packaging into the EU under your own brand, you are automatically considered a 'person responsible for placing on the market' under Regulation (EU) 2025/40 – regardless of who physically manufactured the packaging. Your Chinese supplier cannot assume this responsibility, as they are located outside the EU.

From the deadline of 12 August 2026, you must ensure the following before your first import:

Product level: Each packaging unit requires a machine-readable QR code (GS1 Digital Link) pointing to a digital product passport. Also verify that your packaging meets the minimum recycled content requirements – these vary depending on material type and packaging category.

Labelling: Your company's name and EU address must appear directly on the packaging or on a permanently affixed label. A foreign address of the supplier alone is not sufficient.

Documentation: You need technical documentation demonstrating that the packaging is compliant – material composition, recyclability, weight optimisation. This must be made available to a market surveillance authority upon request.

Practical note: Clarify with your supplier at an early stage who will provide the data points for the digital product passport. If material data from production is missing, you as the importer remain responsible for obtaining it.

For a binding assessment of your specific product categories and supply chain, please contact your local Chamber of Commerce.