PPWR for Non-EU Exporters: Packaging Obligations Since 12 August 2026

What is the PPWR and why does it matter outside the EU?

The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It applies to all packaging placed on the EU market, wherever that packaging was made or filled.

The Regulation was published in the Official Journal on 22 January 2025 and entered into force on 11 February 2025. It has applied since 12 August 2026, when Directive 94/62/EC was largely repealed. Because it is a regulation rather than a directive, the same rules apply in all 27 Member States. For a supplier outside Europe, that is good news: one set of rules on packaging design and composition instead of 27 national variants.

Three types of non-EU business are affected:

• exporters of packaged goods: a fish cannery in Morocco or Côte d’Ivoire shipping cans, an olive oil producer in Tunisia selling bottles to Spain, a fresh produce packhouse in Egypt or Kenya delivering punnets to European retailers;
• packaging manufacturers supplying those exporters: flexible film printers, metal can makers, corrugated board plants;
• makers of empty packaging sold directly to EU fillers.

The Regulation aims to reduce packaging, make all packaging recyclable, require recycled content in plastics, expand reuse and limit substances of concern. The European Commission publishes a regularly updated PPWR FAQ and a guidance document. Together with the Regulation on EUR-Lex, they are the documents to read first.

What has applied since 12 August 2026?

Since 12 August 2026, the obligations of manufacturers, importers and suppliers apply, together with every requirement that does not carry a later date. Other substantive requirements have their own dates, often tied to a Commission implementing or delegated act.

Here is what can already be checked by your customer or by a market surveillance authority.

Manufacturer obligations (Article 15)

The manufacturer may only place on the market packaging that complies with Articles 5 to 12. Before doing so, it must:

1. carry out the conformity assessment procedure (Article 38 and Annex VII), itself or through a third party such as a laboratory;
2. draw up the technical documentation set out in Annex VII, which includes at least the conceptual design, manufacturing drawings and materials of components. The Commission FAQ is clear that this task cannot be delegated;
3. draw up the EU declaration of conformity (Article 39), possibly through an authorised representative appointed by written mandate (Article 17);
4. keep the technical documentation and the declaration for 5 years for single-use packaging and 10 years for reusable packaging;
5. identify the packaging with a type, batch or serial number (Article 15(5));
6. give its name, registered trade name or trademark, postal address and, where available, an electronic contact (Article 15(6)), on the packaging, through a QR code or, failing that, in an accompanying document.

The Commission stresses that the manufacturer remains the only operator legally responsible for compliance, whoever does the actual work.

Substances: PFAS and heavy metals (Article 5)

Since 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS at or above these limits:

According to the Commission, the limits apply to the whole packaging unit, including inks, varnishes, glues and adhesives, and to both intentionally added and unintentionally present PFAS. No list of PFAS will be published; the definition in the Regulation is enough.

The 100 mg/kg limit for the sum of lead, cadmium, mercury and hexavalent chromium already existed under the Directive. The obligation to minimise substances of concern (Article 5(1)) has also applied since 12 August 2026.

Stock and transit

Packaging placed on the market before 12 August 2026 can stay there. Packaging produced before that date but not yet placed on the market does not have to be destroyed: the identification and manufacturer details can be given in an accompanying document. Goods that only transit the EU towards a third country are not covered.

What will an EU importer expect from you?

Proof that the manufacturer has done its job. Before placing packaging or packaged goods on the market, the importer must make sure that the manufacturer established outside the EU has carried out the conformity assessment, drawn up the EU declaration of conformity, identified the packaging and given its contact details, and that the required documents accompany the packaging (Article 18).

The importer must also put its own name and address on the packaging or an accompanying document, and keep the technical documentation for the same periods as the manufacturer. It cannot import blind: expect a supplier questionnaire and a document checklist from your EU customer.

Who is the “manufacturer” in your supply chain?

Settle this first, because everything else follows from it. The definition is in Article 3 of the Regulation; the Commission explains it in its FAQ and guidance:

• packaging bearing a name or trademark: the manufacturer is the operator under whose name or trademark the packaging or packaged product is placed on the market, even if someone else physically makes or fills it. A cannery exporting under its own brand is therefore, in principle, the manufacturer of its sales packaging;
• private label: if an EU retailer has a product made under its own brand, the retailer is in principle the manufacturer, and the non-EU exporter supplies the information it needs;
• packaging without a name or trademark: the manufacturer is whoever orders the packaging and sets its specifications. For standard generic packaging, it is usually the company that physically makes it;
• sales or grouped packaging: the manufacturer is normally the operator that performs the final steps (cutting, filling, sealing), often the brand owner.

An importer or distributor becomes the manufacturer if it places packaging on the market under its own name or trademark, or modifies it in a way that may affect compliance (Article 21). For mixed cases (licensed trademarks, co-branding), the Commission calls for a case-by-case review based on the contract. The test in the text is the same in every set-up: the manufacturer is the person that has the packaging or packaged product designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible on the packaging (Article 3(1), point 13). A second logo therefore does not change the manufacturer. The only exception concerns a brand owner that is a micro-enterprise: its packaging supplier becomes the manufacturer if located in the same Member State, which rules out a supplier established in Morocco. Write down the allocation of roles in the supply contract, for each item.

And if you make the packaging?

When you are not the PPWR manufacturer, you are a supplier (Article 16). You must give the manufacturer all the information and documentation it needs to demonstrate conformity, and the Commission states that suppliers cannot refuse. A packaging plant that wants to keep its exporting customers needs one compliance file per packaging reference: composition, inks and adhesives, PFAS and heavy-metal test results, recyclability evidence.

What about extended producer responsibility?

Extended producer responsibility (EPR) obligations fall on the “producer” that first makes packaging available on the territory of a Member State (Article 3(1), point 15). A Moroccan exporter faces one of two cases:

• it sells to an importer or distributor established in the EU: that customer, as the first operator making the packaging available on its territory, is in principle the producer, registers and pays the fees;
• it sells directly to end users in a Member State, through an online shop for example: it becomes the producer itself and must appoint, by written mandate, an authorised representative for EPR in each Member State where it makes packaging available in this way (Article 45(3)).

In late 2025 the Commission proposed suspending the application of the rules on this authorised representative (COM(2025) 982): check the status of that text before appointing one. Practical arrangements (register, producer responsibility organisation, fee scale) remain set by each Member State; your customer or the producer responsibility organisation of the destination country will tell you what they are.

Which deadlines come next?

The PPWR applies in stages; there is no single date. Several deadlines depend on a Commission delegated or implementing act, and the later of the two dates then applies.

Recycled-content percentages vary by type of plastic packaging and by whether it is contact-sensitive. The first Article 7 step, on 1 January 2030 or three years after the implementing act on the calculation method, is 30% for contact-sensitive packaging with PET as the major component, 10% for contact-sensitive packaging in other plastics, 30% for single-use beverage bottles and 35% for other plastic packaging, as an average per manufacturing plant and year. On the same date, at least 40% of the transport packaging covered by Article 29 must be reusable, within the EU.

For exporters, 2030 is the key date. Switching material, for example from a multilayer laminate to a mono-material structure, has to be tested, approved by the customer and validated for shelf life. That takes several seasons. Starting in 2028, when the criteria are published, leaves little margin.

How does the PPWR relate to BRCGS Packaging Materials Issue 7?

BRCGS Packaging Materials and the PPWR answer different questions. The BRCGS standard, at Issue 7 and audited since April 2025, shows that packaging is produced safely, hygienically and legally; the PPWR sets the regulatory sustainability and information requirements packaging must meet to enter the EU market.

The two files still support each other:

• legal compliance of materials required by BRCGS (food-contact declarations, specifications, raw material supplier approval) provides part of the PPWR evidence;
• traceability under BRCGS makes the batch or serial identification of Article 15(5) possible;
• control of inks, varnishes and adhesives feeds directly into the PFAS demonstration, since the limits apply to the whole packaging unit;
• the review of legal requirements in destination markets must now include the PPWR.

A BRCGS-certified packaging plant is therefore ahead, provided it does not confuse the two: a BRCGS auditor does not issue an EU declaration of conformity. The BRCGS route is set out in our BRCGS Packaging Materials Issue 7 guide.

For food exporters, the same logic applies to IFS Food or BRCGS Food: requirements on food-contact packaging materials already exist, and the PPWR adds regulatory documentation. Our article on supplier audits in Morocco and Africa shows how EU and UK buyers fold this kind of check into their audits.

What should you do now? A six-step action plan

Start by mapping roles and packaging references, then build the files in the order of your export volumes. This is the approach we use with exporters and packaging plants.

1. Map the packaging shipped to the EU. One line per reference: product, market, material, components (body, lid, label, closure), supplier, brand shown.
2. Assign the roles. For each reference: who is the manufacturer, who is the importer, who is the supplier. That decides who signs the EU declaration of conformity.
3. Collect supplier evidence. Composition, inks and adhesives, PFAS tests (starting with a total fluorine screen), heavy metals, recyclability evidence.
4. Build the technical documentation and EU declaration of conformity for the whole packaging unit, in the languages required by destination countries.
5. Update the marking: type, batch or serial number, manufacturer name and address, possibly a QR code; check what your food label already shows.
6. Prepare for 2028 and 2030: follow the Commission’s delegated and implementing acts, assess the recyclability of each reference and plan material changes with your customers.

Before your next call with an EU importer, check these points:

• The list of packaged references exported to the EU is up to date.
  
• The PPWR manufacturer is identified for each reference, with the contract to back it.
  
• Each packaging supplier has delivered a compliance file per reference.
  
• Food-contact packaging has a PFAS test result or a documented justification.
  
• The Annex VII technical documentation exists and will be kept for 5 or 10 years.
  
• The EU declaration of conformity is signed and translated into the languages of the countries supplied.
  
• The packaging carries an identifier (type, batch or serial) and the manufacturer’s name and address.
  
• Someone tracks Commission acts and the 2028–2035 timeline.