You sell products from the UK, the USA or Asia in Germany - or are planning to? From 12 August 2026 there is a clear message: No packaging without PPWR compliance. This applies to you as an importer just as much as to any European manufacturer - regardless of where your factory is located or where your company is registered.
Many international brands and trading companies underestimate how early and how deeply they are involved in the regulatory requirements of EU packaging law. This guide explains which roles and obligations you have as an importer, which particular challenges non-EU businesses face, and how to prepare your market entry in a structured and legally compliant way.
Note: This article provides a practical overview of PPWR obligations for importers. It does not replace individual legal advice.
Who counts as an importer under the PPWR - and what does that mean?
The PPWR (Packaging and Packaging Waste Regulation, EU 2025/40) defines four key roles along the supply chain: Manufacturer, Importer, Distributor and Producer (for EPR purposes). Each of these roles carries specific obligations.
You are considered an importer if you bring complete packaging or packaged products from a third country (outside the EU) into Germany. Goods from another EU Member State are not considered imports within the meaning of the PPWR.
When are you a manufacturer - and not just an importer?
This is one of the most common sources of confusion: Under Article 3(1)(13) and Article 21 of the PPWR, the manufacturer is the party that places packaging on the EU market under its own name or brand - not necessarily the company that physically produced the packaging. A practical example: Company A produces the packaging without its own brand. It is a supplier - not the manufacturer. Company B (you) puts its brand on the packaging and places the product on the EU market. Company B is the manufacturer and signs the DoC.
If your brand name appears on the packaging, you are, in most cases, the manufacturer under the PPWR - and you must issue the declaration of conformity yourself. This applies even if your factory is in China, the USA or any other third country.
The following overview shows which obligations each role carries:
| Requirement / Criterion | Manufacturer (Manufacturer) | Importer (Importer) | Producer (Producer / EPR) |
|---|---|---|---|
| Definition | Brings packaging to the EU market under its own name / own brand | Brings packaged goods from third countries (outside the EU) into the EU | First-time responsibility for an EU market - may be the manufacturer, importer, or trader |
| Declaration of Conformity (DoC) | ✅ Must issue and sign the DoC themselves | ✅ Must obtain and verify the DoC from the manufacturer - for own-brand: issue it yourself | ➖ Not directly responsible, but dependent on the manufacturer/importer |
| Technical Documentation | ✅ Must create complete technical documentation and retain it for 5-10 years | ✅ Must retain the DoC and technical documentation for 5-10 years and present on request | ➖ Not directly responsible |
| EPR Registration (e.g., LUCID) | ✅ Mandatory as a producer | ✅ Mandatory as a producer (first market entrant) | ✅ Core obligation: registration in every EU country where products are distributed |
| System participation (Dual System) | ✅ Mandatory for B2C packaging | ✅ Mandatory for B2C packaging | ✅ Core obligation |
| PFAS Testing (food contact) | ✅ Must obtain test evidence and issue the DoC accordingly | ✅ Must request and verify test evidence from non-EU suppliers | ➖ Not directly responsible |
| Labeling | ✅ Responsible for compliant labeling | ✅ Must ensure labeling is compliant; add own contact details if applicable | ➖ Not directly responsible |
| EU Authorized Representative required? | If based outside the EU: Yes | If based outside the EU: Yes (before market access) | If based outside the EU: Yes |
The specific challenges for non-EU brands
International importers face specific hurdles that domestic FMCG companies typically do not encounter:
1. No direct access to EU supplier data
Your packaging suppliers are based in third countries and are often unfamiliar with EU-specific requirements such as the PPWR, PFAS limits or proof of recyclability. You must proactively request the necessary technical data and test reports - in a format that can be audited by EU authorities.
2. Different material standards and classification systems
Packaging standards in the USA, China or the UK differ significantly from EU norms. Material designations, layer structures and recycling categories cannot be transferred one-to-one. Careful harmonisation of your packaging specifications is essential.
3. Language and administrative barriers
LUCID registration, dual systems, communication with German authorities: Many forms and requirements exist primarily in German. Without local support, your compliance preparations will be significantly delayed.
4. No EU entity - and therefore no direct registration option
An authorised representative is a natural or legal person established in the EU country where packaged products are first placed on the market. This person assumes full responsibility, on behalf of foreign manufacturers or distributors, for all EPR obligations - from registration and reporting to fee management. Without such an authorised representative, registration in Germany is practically not feasible.
Your core obligations at a glance
From August 12, 2026, the rule applies: Every packaging placed on the EU market must be covered by a valid Declaration of Conformity (DoC) - no transitional period for new stock. Packaging already produced that is first introduced into the EU after this date also falls under the new PPWR obligations.
1. LUCID registration: Mandatory for everyone - regardless of where your company is based
Every company that sells packaged goods on the German market or imports them into Germany must register with the LUCID Packaging Register - regardless of where the business is established.
There is no de minimis threshold: obligations apply from the very first imported package. Registration is free of charge and is carried out online on the website of the Central Packaging Register Office (ZSVR). You receive a unique LUCID registration number, which is required for all subsequent steps.
The LUCID register is publicly accessible. Competitors and authorities can check at any time whether you are fulfilling your obligations. Violations quickly lead to warning letters, which in turn can cause additional costs and legal disputes.
Sanctions: If you fail to meet the three core obligations - registration in the LUCID register, participation in a compliance scheme and regular data reporting - you risk fines of up to €200,000, sales bans and competition law warnings.
2. EPR registration: Separately in every EU market
The rule that surprises most companies: You must register in the EPR system of every EU country in which you sell goods. For Germany, this is LUCID. France uses CITEO, Italy uses CONAI. Each registration has its own requirements, deadlines and fee structures - see also our article on EPR fees in Europe.
3. Declaration of Conformity (DoC)
From 12 August 2026, every type of packaging placed on the EU market must be backed up by an EU declaration of conformity - a document confirming compliance with the PPWR requirements.
For importers whose own brand appears on the packaging, this means: From 12 August 2026, the PPWR legally obliges you to ensure packaging compliance, even if you did not design the packaging yourself. Article 18 requires importers to review the supplier's DoC, store it for 5 to 10 years and respond to authority requests within 10 days.
The documentation requirement is strict: you must keep the technical documentation for single-use packaging for 5 years and for reusable packaging for 10 years.
You can find a template for your PPWR declaration of conformity in our comprehensive guide to the PPWR DoC.
4. PFAS compliance: Particularly critical for food contact packaging
For food contact packaging, PFAS limits will apply from 12 August 2026: a maximum of 25 ppb for an individual PFAS substance and 250 ppb for the total sum of all PFAS. In addition, there is a limit of 50 ppm for total fluorine.
This is particularly challenging for non-EU importers: food contact packaging placed on the market after 12 August 2026 must comply with PFAS limits - even if it was produced before that date. "Placing on the market" means making packaging available on the EU market for the first time. This point in time is especially relevant for importers who manage cross-border inventory.
Request PFAS test certificates from your suppliers now - not shortly before August 2026. For a more in-depth overview of documentation requirements and limits, see our article on PFAS compliance documentation.
Step by step: How to prepare your market entry in line with the PPWR
Clarify whether your company qualifies as an Importer, Manufacturer or Producer — or in multiple roles at once. The key question: Is your brand on the packaging? If so, under PPWR you are most likely the Manufacturer and must issue the Declaration of Conformity yourself.
Non-EU companies without their own EU establishment require an EU Authorized Representative in the member state where they first place goods on the market. This person handles EPR obligations and regulatory communications. In Germany this is mandatory — registration cannot proceed without an EU-based entity.
Any company that commercially distributes packaged goods in Germany must register in the LUCID Packaging Register of the ZSVR, regardless of headquarters. The registration is free and online. You will receive a personal LUCID number, without which you may not sell packaging subject to system participation. Penalties for violations: up to €200,000.
For B2C packaging (packaging that ends up as waste for the end consumer), you must join a Dual System and license your packaging quantities by material and weight. In addition, you must submit regular quantity reports to LUCID and the dual system.
Create a complete inventory of all packaging types: material, weight, layers, suppliers, PFAS status. For non-EU suppliers this is particularly labor-intensive — data often exist in different formats (Excel, PDF, ERP) or are missing entirely. Digital packaging management systems like Packa support structured capture even from common import formats.
From 12 August 2026 a valid Declaration of Conformity (DoC) must exist for each packaging type. If your brand is on the packaging, you must issue the DoC yourself — even if your supplier is outside the EU. Technical documentation must be kept for 5 years (single-use packaging) or 10 years (reusable packaging).
If you import food contact packaging, you must meet PFAS limits: max 25 ppb for individual PFAS substances, max 250 ppb for the sum of all PFAS (per targeted analysis). Request PFAS laboratory analyses from your non-EU suppliers — and note: there is no transition period for existing stock placed on the market after August 12, 2026.
PPWR is not a one-time task — regular quantity reporting, updates to packaging data and preparation for further requirements (recyclability attestations from 2027, digital labeling from 2029, recycled content quotas) must be managed on an ongoing basis. Automated compliance checks and centralized data storage significantly reduce the effort.
Your personal PPWR readiness check
Use the interactive tool below to quickly assess where you still need to take action as an importer:
How Packa supports international importers in practice
The central challenge for non-EU importers is not understanding the regulation - it is the data foundation. Without complete, structured packaging data, you can neither issue DoCs nor submit EPR reports correctly. This is precisely where the problem lies: according to internal assessments by Packa, initial reviews typically show that 30-70% of the required packaging data is missing.
The Packa platform for digital packaging management addresses exactly the pain points importers struggle with:
AI-supported specification digitisation
Packaging data often exists in a wide variety of formats: Excel spreadsheets from Asian suppliers, PDFs from ERP systems, manually created material lists. Packa imports and structures this data automatically - including expert validation and data gap analysis.
Automated supplier communication
Packa supports multilingual communication with suppliers outside the EU and helps you systematically request missing information - structured, traceable and documented in an audit-ready way.
Automated compliance checks
Once packaging data has been captured, Packa automatically checks it against PPWR requirements: PFAS limits, recyclability, substance restrictions and EPR registration status. This allows you to identify gaps before the authorities do.
Centralised packaging data management and DoC creation
All specifications, supplier evidence, PFAS test certificates and declarations of conformity are brought together on a single platform. This creates the foundation for PPWR-compliant documentation that is audit-ready at any time.
Cross-country EPR analysis
For importers supplying multiple EU markets, Packa provides an aggregated view of EPR obligations, fee structures and reporting deadlines - by country and based on real packaging data.
Conclusion: Compliance is a market access requirement - also for importers
Packaging is no longer just a commercial or design topic for brands, importers and online retailers. It is a legal and operational issue that affects labelling, recyclability, packaging design, reporting and market access across the EU.
For non-EU brands that sell, or plan to sell, in Germany or other EU markets, the rule is clear: compliance is not optional - it is a strict prerequisite for market access. Preparation requires structured packaging data, clear role responsibilities and digital tools that can keep pace with regulatory complexity.
Start now - so that your entry into the EU market does not fail because of missing data or an incomplete declaration of conformity.
Frequently asked questions (FAQ)
Do I have to register myself in LUCID as a non-EU company?
Yes. The registration obligation in the LUCID Packaging Register applies to all companies that commercially place packaged goods on the market in Germany—regardless of whether their registered office is in Germany, the EU, or a third country (UK, USA, Asia, etc.). If you do not have your own EU subsidiary, you must first appoint an EU Authorized Representative (Authorized Representative) who will handle the registration and communications with authorities in Germany.
Who must issue the Declaration of Conformity (DoC) if my supplier is located in China or the USA?
If your brand name or trade name appears on the packaging, you are considered a Manufacturer under the PPWR definition—regardless of where the packaging was physically produced. This means you must issue the DoC yourself. For this, you will need the technical specifications and evidence from your supplier (e.g., PFAS laboratory analyses, material composition), on the basis of which you create and sign the DoC.
Which PFAS limits apply to imported food-contact packaging?
From August 12, 2026, the following limits apply to food-contact packaging: a maximum of 25 ppb for a single PFAS substance (target analysis), a maximum of 250 ppb for the sum of all PFAS (target analysis) and a maximum of 50 ppm total fluorine. There is no transition period: packaging placed on the EU market for the first time after August 12, 2026 must meet these limits—even if produced before that date.
Muss ich mich in jedem EU-Land separat für EPR registrieren?
Yes. The EPR registration (Extended Producer Responsibility) must be carried out in each EU member state separately in which you place packaged goods on the market. For Germany, the LUCID register of the ZSVR is the central contact point. Other countries have their own registers (e.g., France: CITEO, Italy: CONAI). Each registration has its own deadlines, requirements, and possibly different fee structures.
Was passiert, wenn ich meine Verpackungen vor August 2026 nicht PPWR-konform mache?
Verpackungen, die nach dem 12. August 2026 ohne gültige DoC, ohne LUCID-Registrierung oder ohne Erfüllung der PFAS-Grenzwerte auf den EU-Markt gebracht werden, dürfen nicht vertrieben werden. In Deutschland drohen Bußgelder bis zu 200.000 €, Vertriebsverbote und wettbewerbsrechtliche Abmahnungen. Das öffentlich einsehbare LUCID-Register ermöglicht es Behörden und Wettbewerbern, Verstöße leicht zu identifizieren.
Mein nicht-EU-Lieferant hat mir bereits eine DoC geschickt - reicht das?
Das hängt von der Situation ab. Steht der Name oder die Marke Ihres Lieferanten auf der Verpackung (und nicht Ihrer), kann die DoC des Lieferanten ausreichen. Steht jedoch Ihr Markenname auf der Verpackung, sind Sie der PPWR-Manufacturer und müssen die DoC selbst ausstellen - auf Basis der Daten und Nachweise, die Ihr Lieferant Ihnen bereitstellt. Klären Sie diese Zuordnung unmittelbar mit Ihrem Importrechtsberater.
