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Under the Packaging and Packaging Waste Regulation (PPWR), importers are the legally accountable party inside the EU for every piece of non-EU packaging that enters the market. They act as the gatekeeper between a non-EU manufacturer and the EU market, and the regulation holds them accountable accordingly.
But importer status isn’t fixed, it depends on the specific packaging and transaction. This post breaks down who qualifies as an importer, what obligations that role carries, and what it takes to stay compliant, from the initial border crossing to the years of mandatory document retention that follow.
Am I an Importer Under PPWR?
You are an importer if you place packaging from outside the EU onto the EU market, whether that packaging is empty or already contains a product. But here’s the key: importer status is determined per packaging, not per company.
A manufacturer may produce their own packaging for their own products. The same company may also source packaging from a supplier outside the EU and place it on the market. In that transaction, they act as an importer, subject to importer obligations, even though they are also a manufacturer elsewhere in their supply chain.
Similarly, a distributor that typically sources packaging from EU suppliers may occasionally import a specialty packaging type from Asia. For that specific shipment, they step into the shoes of an importer and must comply with Article 18 (as well as Article 21 if they place that imported packaging on the market under their own brand or trademark).
The takeaway: PPWR does not assign roles to companies; it assigns roles to transactions. If you source any packaging from outside the EU and place it on the EU market, you need to read this post and ensure those specific packagings meet the requirements below.
Verification Obligations Before Placing on the Market
Under Article 18 PPWR, the obligation to place on the market only packaging that complies with Articles 5 to 12 does not fall on the manufacturer alone. It extends explicitly to importers.
Conformity assessment. The importer must ensure that the manufacturer in the third country has carried out the conformity assessment procedure under Article 38 and compiled the technical documentation required under Annex VII.
Declaration of Conformity. Article 18(7) legally obligates the importer to keep a copy of the manufacturer’s EU Declaration of Conformity, retaining it for 5 years for single-use packaging and 10 years for reusable packaging.
Labelling compliance. The importer must ensure the packaging carries the harmonised sorting labels required by Article 12. These labels become mandatory from 2028 on, so this obligation phases in rather than applying immediately, but the verification duty sits with the importer once it does.
Manufacturer identification. The importer must verify that the manufacturer has complied with their identification obligations: placing a type, batch, or serial number on the packaging under Article 15(5), and indicating their name, registered trade name or trademark, and contact address under Article 15(6).
Accompanying documents. The importer must ensure the packaging is accompanied by any legally required documents.
If the importer has reason to believe the packaging does not comply with PPWR requirements, they must not place it on the market.
Traceability and Importer Identification
Once the importer places the packaging on the market, they must make themselves identifiable to market surveillance authorities, separately from the manufacturer.
Contact information. The importer must indicate their own name, registered trade name or trademark, and postal address, plus electronic means of communication where available, on the packaging.
The accompanying document exception. Where it is not possible to display this information on the packaging, the importer may provide it via a standardised, open, digital data carrier (such as a QR code) or on a document accompanying the packaged product. If the manufacturer is already integrating a QR code into the packaging to meet their own identification and contact-detail obligations under Article 15, the importer’s contact details can typically sit on that same digital carrier rather than requiring a separate one.
Storage and transport care. While the packaging is under the importer’s responsibility (whether empty or already containing a product), they must ensure that storage or transport conditions do not jeopardise its compliance with the core sustainability and labelling requirements of Articles 5 to 12.
Record Keeping and Cooperation with Authorities
The importer’s compliance duties continue long after the packaging has entered the EU supply chain.
Document retention: the 5/10-year rule. The importer must keep a copy of the EU Declaration of Conformity at the disposal of market surveillance authorities and ensure the manufacturer’s technical documentation can be made available on request. This retention period is 5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.
The 10-day response limit. If a national authority submits a reasoned request for the technical documentation or proof of conformity, the importer must provide it electronically, and in paper if requested, in a language easily understood by that authority, within 10 days.
Corrective measures. If the importer has reason to believe that packaging they already placed on the market is non-compliant, they must immediately take corrective measures to bring it into conformity, withdraw it, or recall it, and must notify the relevant national market surveillance authorities of the suspected non-compliance and the corrective actions taken. We cover what happens across every role when this goes wrong, including the fines involved, in our post on PPWR non-compliance.
Special Structural Considerations: Branches and EPR
Branch offices cannot be importers. An EU branch office of a non-EU company typically lacks a separate legal personality, meaning it cannot legally take on the importer role under the PPWR. To handle these responsibilities directly, rather than forcing your European distributors or customers to inherit heavy importer liabilities, your non-EU company must incorporate a separate, legally distinct subsidiary within the EU to act as the importer of record.
EPR obligations. Under PPWR, an importer is legally classified as a producer if they are the first to make a packaged product, or empty transport or service packaging, available on a specific Member State’s territory. This means registering in that Member State’s producer register, reporting packaging weights annually, and paying EPR waste management fees. We cover this status in full in our post on the PPWR producer, since importer and producer status frequently apply to the same company at once.
PPWR Importer Obligations at a Glance
| Obligation | Legal Basis | When It Applies |
| Verify conformity assessment & technical documentation drawn up by manufacturer | Article 18(2)(a) (ref. Article 38 & Annex VII) | From August 12, 2026 |
| Verify manufacturer identification & contact details are printed on the packaging or accessible via digital identifier | Article 18(2)(d) (ref. Article 15(5) & 15(6)) | From August 12, 2026 |
| Indicate own importer name, trade name, and postal address on the packaging or through a digital identifier | Article 18(3) | From August 12, 2026 |
| Retain the DoC & make technical documentation available if requested | Article 18(7) | 5 years for single-use, 10 years for reusable (from August 12, 2026) |
| Respond to reasoned national authority requests within 10 days | Article 18(8) | Within 10 days of request (from August 12, 2026) |
| Verify harmonised material composition sorting labels | Article 18(2)(b) (ref. Article 12) | Mandatory from August 12, 2028 (or 24 months from implementing acts) |
| Register and report as a “producer,” if unpacking or distance-selling | Articles 44 & 45 | Per Member State once national registers launch (Transition rules apply) |
Frequently Asked Questions
What is an importer under PPWR?
An importer is any natural or legal person established within the EU that places packaging from a third country, empty or containing a product, on the Union market. A branch office without separate legal personality cannot hold this role.
Does an importer need to create the Declaration of Conformity?
No. The manufacturer is solely responsible for drawing up and signing the EU Declaration of Conformity. The importer’s obligation is to keep a copy of this completed DoC at the disposal of market surveillance authorities once the packaging is on the market, and to ensure the manufacturer’s supporting technical documentation can be provided upon request.
How long must an importer keep packaging documentation?
5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.
How quickly must an importer respond to an authority request?
Within 10 days of a reasoned request, providing the information electronically and, if requested, in paper, in a language the authority easily understands.
Is an importer automatically an EPR producer?
Often, but not automatically. An importer becomes a producer under Extended Producer Responsibility specifically when they are the first to make packaging or a packaged product available in a given Member State’s territory.
How PAQR Can Help
Verifying a non-EU manufacturer’s conformity assessment, holding their Declaration of Conformity, and being ready to produce technical documentation within 10 days of a request are three separate obligations that all depend on the same underlying data being organised and current. PAQR gives you a central workspace to collect and store this documentation by supplier and packaging format, so a request from a market surveillance authority is a retrieval, not a scramble.
Click “Try now for free” on paqr.com to start a free trial.
