New PPWR: Requirements for Importers Starting in August 2026

As of August 12, 2026, the new Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) has been generally applicable since August 12, 2026; it replaces the previous Directive 94/62/EC and establishes a harmonized framework for packaging placed on the market in the European Union.

This regulatory change is particularly significant for importers, as it affects not only those who import empty packaging but also goods that arrive in the EU pre-packaged from third countries.

What will change for importers?

The PPWR establishes new requirements regarding compliance, documentation, traceability, and control for packaging placed on the European market.

For imports, the packaging is considered to have been placed on the market at the time of release for free circulation. However, the Regulation does not establish a new, specific customs control nor does it require the automatic submission of additional certificates to Customs.

The responsibility lies primarily with economic operators, who must be able to demonstrate compliance with the regulations when requested to do so by the competent authorities.

Key Requirements Effective August 12

Among the most significant measures are:

• PFAS Restrictions: Certain food-contact packaging must not exceed the established limits for these substances. There is no transition period to allow for the sale of inventory that had not yet been placed on the market as of August 12.
• Heavy metals: The total amount of lead, cadmium, mercury, and hexavalent chromium present in the packaging must not exceed 100 mg/kg.
• EU Declaration of Conformity: The corresponding declaration must be available when applicable, in addition to the technical documentation and mandatory labeling required by the Regulation.
• Record retention: Records must be retained for 5 years for single-use containers and 10 years for reusable containers.

Greater Responsibility for Importers
Before placing a packaged product originating from a third country on the European market, the importer must verify that the manufacturer has conducted the corresponding conformity assessment, has the required technical documentation, and has issued the EU Declaration of Conformity where applicable.
The importer must also ensure compliance with identification and traceability requirements and be able to provide the documentation to the authorities.

A change that will continue through 2030
August 12 marks the beginning of a gradual transformation. Over the next few years, new measures will be implemented regarding labeling, recyclability, reduction of excess packaging, reuse, and restrictions on certain packaging formats.

For importing companies, packaging is thus no longer merely an accessory to the merchandise but becomes a fundamental part of ensuring conformity and regulatory compliance in their import operations.

In light of this new regulatory framework, Vicasso Internacional, S.L. offers our clients advice and support in customs and logistics matters, helping them identify the new obligations that may affect their import operations. Our team can guide you through the applicable requirements and the necessary documentation to facilitate your adaptation to the new regulation and minimize any potential disruptions to your operations.