PPWR for importers from China – which documents should you request?

When importing products from China, are you an importer within the meaning of the PPWR?

As a rule, yes, if you are an entity established in the Union and place on the market packaging or a packaged product originating in a third country.

The Commission’s 2026 guidance has a separate section on the definition of an importer and emphasises the importance of the actual entity established in the Union.

The mere fact that the Chinese counterparty:

• manufactured the product,
• packaged it,
• issued the invoice,
• arranged transport,

does not remove the importer’s obligations under Article 18.

Importer from China and manufacturer – first establish who draws up the declaration

The importer and the manufacturer are two different roles.

If a Chinese entity manufactures and sells packaging or a packaged product under its own brand, it may be the relevant manufacturer, while the importer performs the verification obligations under Article 18.

The situation changes where the importer:

• orders a product or packaging under its own name or trade mark,
• decides on its design and specification in a manner corresponding to the definition of a manufacturer, or
• modifies the packaging in a manner that may affect conformity.

In that case, Article 3 and Article 21 must be analysed from the perspective of the manufacturer’s obligations.

Private label from China – your own brand may change your role

Your own brand is one of the most important risk points for an importer.

In guidance C/2026/3084, the Commission explains that the manufacturer does not have to be the entity that physically operates the production line. What also matters is who commissions the design or manufacture of a product under its own name or trade mark.

Therefore, the statement:

“The factory is the manufacturer, so it is responsible for PPWR”

may be incorrect for private label.

The specific exemption provided for certain microenterprises requires, among other things, that the supplier be located in the same Member State. In direct cooperation with a factory in China, this condition is not met.

What must an importer check before placing packaging on the market?

Article 18 requires an importer to place only compliant packaging on the market.

Before importing, you must verify in particular whether the manufacturer has:

• carried out the appropriate conformity assessment procedure,
• drawn up the technical documentation,
• drawn up the EU declaration of conformity,
• correctly marked the packaging in accordance with the applicable requirements,
• included the required identification information.

The importer should also ensure that its own identification details are provided in the form required by Article 18 and that storage and transport conditions do not compromise compliance.

PPWR supplier document pack – which documents should you request from a factory in China?

It is best not to send the supplier a single question: “Do you comply with PPWR?”. Send a list of specific data and documents.

1. Request a correct EU declaration of conformity, not a “PPWR Certificate”

The EU declaration of conformity should comply with Article 39 and the structure set out in Annex VIII.

It should make it possible to determine, among other things:

• which packaging it concerns,
• who the manufacturer is,
• what the subject matter of the declaration is,
• which relevant provisions it concerns,
• which standards or specifications are referenced, where applicable,
• who signed the document and when.

File name:

PPWR_Certificate_Final.pdf

is irrelevant if its content does not correspond to an actual declaration of conformity.

How do you verify a PPWR declaration received from China?

It is not enough to check whether the document has a stamp.

Verify the following in sequence:

1. Is the indicated entity actually the relevant manufacturer?
2. Does the document concern exactly the version ordered?
3. Does the code on the declaration match the specification?
4. Does the material description correspond to the actual packaging?
5. Are the cited provisions up to date?
6. Were the standards or specifications actually used?
7. Is the declaration signed?
8. Does the document have a date and a controlled version?

Particularly hazardous is a declaration concerning “all packaging supplied by our company” where the supplier produces dozens of different materials and designs.

2. Technical documentation – what should you require from a Chinese manufacturer?

Technical documentation forms the basis for conformity assessment and should comply with Annex VII.

It should include, as appropriate:

• a description of the packaging and its intended use,
• design data and drawings,
• materials of the constituent parts,
• explanations of the design,
• applied standards and specifications,
• an analysis and assessment of the risk of non-compliance,
• relevant technical assessments,
• test reports used as evidence.

Before starting sales, the importer should already know where this documentation is held and how it will be made available if requested by the competent authority.

Must the importer hold the full technical documentation itself?

PPWR distinguishes between the obligation to retain a copy of the declaration and the obligation to ensure the availability of technical documentation.

The importer should retain a copy of the EU declaration of conformity.

With regard to technical documentation, the provisions require that it can be made available to the competent authority.

Therefore, the following should not be presented as a literal PPWR requirement:

“every importer must have a full copy of the entire dossier locally on its server”.

Operationally, however, holding the most important parts of the documentation can significantly reduce risk, particularly where cooperation with a supplier outside the EU is unstable.

3. Request an unambiguous packaging specification

Without a specification, it is not possible to reliably determine what the reports and declaration relate to.

Depending on the packaging, the specification should include:

• material code,
• packaging code,
• dimensions,
• weight or grammage,
• layer structure,
• main components,
• material types,
• coatings,
• adhesives,
• labels,
• closures,
• revision number.

It is worth requiring the revision number to also appear on other supplier documents.

4. Request a BOM – a list of all packaging components

For multi-component packaging, a BOM table is highly useful.

The data are illustrative.

Such a document subsequently makes it possible to determine whether a change to one component may affect the earlier assessment.

5. Documents relating to substances – “eco material” is not enough

Article 5 contains requirements concerning substances present in packaging.

The supplier should provide data enabling the requirements applicable to the given material to be assessed.

Depending on the packaging, the following may be needed:

• composition declarations,
• coating and ink specifications,
• information on adhesives,
• substance test reports,
• data on recycled raw materials.

Marketing terms:

“green”, “eco”, “environmental material”, “EU standard”

are not, in themselves, evidence of compliance with a specific requirement.

6. Heavy metals – check the evidence for the specific material

PPWR maintains the restriction on the total concentration of:

• lead,
• cadmium,
• mercury,
• hexavalent chromium.

If you rely on a supplier report, check whether the tested sample corresponds to the current material and version.

A report issued five years earlier for “plastic material” without a specification number may have little evidential value for the current packaging.

7. PFAS – particular caution for food contact packaging

From 12 August 2026, the PFAS limits set out in Article 5(5) apply to packaging intended to come into contact with food.

If you import such packaging or products packed in it, it is worth requesting the following from the supplier:

• information on the composition of the material and coatings,
• information on the use of fluorinated technologies,
• reports of relevant analyses, where needed,
• identification of the tested sample,
• the test method and limits of determination.

The statement alone:

“No intentionally added PFAS”

may not be sufficient to demonstrate compliance with all PPWR criteria, because the restriction is not limited solely to intentionally added PFAS.

PPWR does not replace food contact documentation

If the packaging comes into contact with food, the relevant rules on materials intended to come into contact with food must also be taken into account.

A food contact document is not automatically a PPWR declaration, and vice versa.

When qualifying a supplier, it is therefore worth separating two sets of documentation:

• PPWR documentation relating to the packaging,
• documentation required under the relevant FCM rules.

8. Recycled content data – start collecting it at material level

Article 7 introduces future minimum levels of recycled content from post-consumer plastic waste for certain plastic packaging.

However, in 2026, you should not require every supplier to obtain final certification under all future methods merely because the target is included in PPWR.

However, it is already worth collecting:

• the proportion of virgin material and recycled material,
• the type of recycled material,
• information on whether it is PCR,
• identification of the raw material supplier,
• origin traceability documents, where used.

9. Recyclability – request design data, not a fictitious PPWR class

Design for Recycling requirements are being implemented in stages and also depend on subsequent Commission acts.

Therefore, at present, collecting data that will enable a proper assessment under the official methodology is more important than an arbitrary “Recyclability Certificate A”.

It is worth obtaining the following from the supplier:

• the exact material of each component,
• the mass of the components,
• the type of label,
• the adhesive,
• the closure,
• coatings,
• colourants,
• other elements that may affect sorting and recycling.

10. Minimisation – require weight, dimensions and design justification

Article 10 introduces requirements to reduce the weight and volume of packaging to the minimum necessary for its functionality, with the main requirements being phased in.

As early as at the procurement stage, it is worth requiring:

• packaging weight,
• dimensions,
• production tolerances,
• strength data,
• test results, where the design is justified by functional properties.

This is much easier than attempting to reconstruct the data after several years of cooperation.

11. Which test reports should you request from a Chinese supplier?

There is no single mandatory ‘PPWR test report’ for every package.

A report should be ordered for a specific evidence gap.

Depending on the packaging, the following may be needed, among others:

• substance testing,
• PFAS analyses,
• material testing,
• mechanical tests,
• barrier tests,
• other tests substantiating a specific criterion.

You should not purchase a full test package just because the laboratory has called it an ‘EU PPWR Package’.

How do you verify a laboratory report from China?

The most important question is not ‘does the report look professional?’, but ‘does this result concern exactly what I am importing?’

Must an importer request testing of every batch from China?

The PPWR does not establish a single general rule requiring laboratory testing of every batch of every package.

However, you must ensure that production remains compliant with the assessed specification.

The frequency of checks may depend on:

• material risk,
• supplier stability,
• process variability,
• results of previous checks,
• changes to raw materials,
• other applicable legislation.

A good procedure may therefore provide for an initial test, a test after a significant change and periodic verification, instead of unreflectively testing every container.

12. Importer details on packaging – check the artwork before dispatch

Article 18 also imposes identification obligations on the importer.

The importer should indicate their name, registered trade name or trade mark, and the contact details required by the PPWR.

It is safest to check this element before approving the artwork or print run.

If the relevant data are to be provided in a permitted alternative form, it must be ensured that it actually meets the conditions of Article 18.

Adding data only after the container has arrived can be considerably more expensive than preparing production correctly.

Do not request future PPWR marking from the supplier too early

The requirements for harmonised PPWR marking are being implemented in stages.

Therefore, a Chinese factory should not be given the instruction:

“print all future PPWR symbols now”

without checking whether the relevant design and date of application are already in force.

Otherwise, the importer may order a huge batch of packaging with outdated or incorrect artwork.

13. The most important long-term document: change notification procedure

Even perfect documentation loses its value if the factory later changes the material without informing the importer.

Therefore, the purchasing terms should include an obligation to notify in advance of changes concerning:

• the raw-material supplier,
• the material,
• the formulation,
• the colourant,
• the adhesive,
• the coating,
• the recycled content,
• the basis weight,
• the construction,
• the manufacturing process, if it may affect the assessed property.

This is a contractual and quality tool, not a separate form imposed by the PPWR.

Sample “no change without notification” clause

For example, the following rule may be used in purchasing documentation:

The wording is an organisational example, not a ready-made legal clause for every contract. It should be adapted to the cooperation model and the law governing the contract.

Which documents should be requested before placing a Purchase Order?

The most expensive time to discover a PPWR issue is when 40,000 units of packaging have already been manufactured.

Before the PO, it is advisable to obtain:

1. identification of the manufacturer,
2. a preliminary packaging specification,
3. a BOM or material composition,
4. data on substances,
5. available test reports,
6. information on the coatings, adhesives and inks used,
7. recycled-content data, where relevant,
8. confirmation that the technical documentation can be provided,
9. an approved change notification procedure.

At this stage, the objective is to establish whether the supplier will be able to meet the requirements of the EU market at all.

Which documents should be requested before goods are shipped from China?

Before shipment, it is necessary to move from “design” documents to documents corresponding to final production.

1. Final packaging specification with revision number.
2. Final BOM.
3. Current reports used in the assessment.
4. Confirmation that no unnotified changes have been made.
5. Final artwork and marking.
6. EU declaration of conformity, if the relevant manufacturer has completed the assessment.
7. Confirmation of the availability of the technical documentation.
8. Batch or production identification enabling the delivery to be linked to the specification.

This ensures that the documents concern the product actually being shipped, rather than a sample from six months ago.

Ready-to-send list for a supplier in China

A brief request may be worded as follows:

The list should be tailored to the specific packaging. Not every item requires the same report, and not every future PPWR requirement already applies today.

What should not be accepted as sufficient PPWR documentation?

The most common red flags when importing from China are:

• a one-page ‘PPWR Certificate’ without a legal basis stated;
• a declaration without packaging identification;
• a document signed by a company whose role no one can explain;
• a report relating to a different material code;
• a test without a sample number;
• a report issued before a formulation change;
• a statement of ‘EU compliant’ without specific parameters;
• no information on adhesives and coatings;
• ‘PFAS free’ without a definition and test scope;
• a private recyclability class presented as the official final PPWR class;
• refusal to provide any material composition information;
• no agreement to notify the importer of changes.

What should you do if a Chinese supplier refuses to provide documentation?

If the importer cannot verify that the required obligations have been fulfilled, the issue is not resolved merely by the supplier signing a statement.

Possible actions include:

1. determining which information is genuinely confidential,
2. signing an NDA,
3. submitting some documents directly to an independent laboratory or adviser,
4. obtaining a report for a sample controlled by the importer,
5. agreeing access to documentation at the request of an authority,
6. changing supplier if the lack of data makes it impossible to demonstrate compliance.

The argument:

‘this is secret, trust us’

does not automatically create an exemption from PPWR obligations.

Product manufactured in China before 12 August 2026 – is it automatically exempt?

The date of manufacture in China should not be equated with the date of placing on the market in the Union.

PPWR and Commission guidance link transitional provisions to the point at which packaging is placed on the market and to the dates from which the relevant requirements apply.

The fact that a container was manufactured or even shipped from China before a given date should not be treated as automatic evidence that the packaging has already been placed on the EU market.

For existing stock, the actual status of the specific batch must therefore be determined.

How long must an importer retain the PPWR declaration?

The importer retains a copy of the EU declaration of conformity for 5 years for single-use packaging and 10 years for reusable packaging.

They should also ensure that the technical documentation can be made available to the competent authority.

Does the importer always have 10 days to provide the documentation?

The 10 days should not be presented as a universal deadline for every request addressed to the importer.

PPWR requires the importer to cooperate with competent authorities and provide the information and documentation necessary to demonstrate compliance.

However, the specific provision on 10 days from receipt of the request is set out in Article 17 in relation to one of the tasks that an authorised representative may perform.

In practice, however, the importer should organise the documentation so that it can be provided very quickly.

Traceability – record not only documents, but also deliveries

Article 22 requires the ability to identify the relevant economic operators in the supply chain.

The importer should therefore be able to link:

supplier → PO → batch → material version → packaging type → reports → declaration → customers.

This is particularly important if an issue emerges only after several months and it is necessary to determine which deliveries were affected.

How can PPWR be integrated into the purchasing procedure from China?

The safest model consists of several gates.

It is worth assessing a supplier not only by price, but also by the quality of documentation

A factory able to provide controlled documentation may be significantly safer for the importer than a supplier that is a few per cent cheaper but lacks a change-management system.

The supplier scorecard can include:

• completeness of specifications,
• traceability of reports,
• response time to document requests,
• quality of change notifications,
• consistency of samples with serial production,
• history of unreported changes.

The most common PPWR mistakes made by importers from China

• requesting only a “PPWR Certificate”;
• failure to identify the correct manufacturer;
• assuming that the importer must always issue the declaration themselves;
• considering one general factory declaration sufficient for all packaging;
• no specification revision number;
• reports relating to materials other than serial production;
• no BOM;
• no data on adhesives, coatings or labels;
• no change notification procedure;
• ordering production before closing documentation gaps;
• testing a random set of parameters rather than specific requirements;
• requesting final future PPWR classes before applying the appropriate methodology;
• no verification of importer details on the artwork;
• relying on obtaining documentation only after receiving a letter from an authority;
• confusing importer obligations with those of the EPR producer.

PPWR for importers from China – complete document checklist

1. Determine whether you are a PPWR importer.
2. Identify the correct manufacturer.
3. Check whether you operate under your own brand.
4. Obtain manufacturer identification.
5. Obtain the final packaging specification.
6. Obtain the BOM.
7. Collect data on all materials.
8. Collect data on coatings, adhesives, labels and closures.
9. Verify evidence relating to substances.
10. For food contact materials, check PFAS and other relevant requirements.
11. Verify test reports.
12. Check sample identification.
13. Collect recycled content data, where relevant.
14. Collect data needed for the future assessment of recyclability.
15. Determine the packaging weight and dimensions.
16. Obtain the EU declaration of conformity.
17. Check its compliance with Annex VIII.
18. Ensure the availability of the technical documentation.
19. Check importer details on the packaging.
20. Implement change notification.
21. Link documents to the version number.
22. Before shipment, confirm that there have been no unnotified changes.
23. Keep a copy of the declaration for the relevant period.
24. Keep traceability data.
25. Establish a reassessment procedure following a change.

How do you manage PPWR documents with multiple suppliers from China?

With a few products, the checklist can be managed manually.

With several dozen factories, the issue is that one supplier may have:

• several dozen materials,
• multiple revisions,
• different reports,
• multiple declarations,
• different update dates.

The key is therefore not merely storing PDFs, but maintaining the relationship between a document and a specific specification.

The system should allow you to follow:

supplier → material → revision → report → requirement → packaging type → documentation → declaration → delivery.

What documents to request from a supplier in China – key conclusions

An importer should not look for a single “PPWR certificate”. They should build a controlled evidence package for a specific packaging type and version.

The basis is the EU declaration of conformity, ensured availability of the technical documentation, the packaging specification, BOM, material data and reports needed to demonstrate specific requirements.

As important as the initial documents is the supplier’s commitment to notify you of subsequent changes.

The safest process is as follows:

supplier qualification → material data → sample → documentation assessment → PO → production → final verification → shipment → import → change monitoring.

FAQ – PPWR for importers from China

Sources

Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex

European Commission guidelines: Commission Notice C/2026/3084 – Guidelines on PPWR

European Commission FAQ: Packaging and Packaging Waste Regulation – Frequently Asked Questions

Food contact materials: Regulation (EC) No 1935/2004 – EUR-Lex

The article draws in particular on:

• Article 3 – definitions of manufacturer, importer and producer,
• Article 15 – obligations of the manufacturer,
• Article 16 – supplier information and documentation,
• Article 18 – obligations of the importer,
• Article 21 – cases of assumption of the manufacturer’s obligations,
• Article 22 – traceability of economic operators,
• Articles 35–39 – assessment methods, conformity assessment procedure and EU declaration of conformity,
• Annex VII – technical documentation and internal production control,
• Annex VIII – structure of the EU declaration of conformity.