EU PPWR FAQs Updated August 2026 - Flipbook - Page 42
Article 18 requires importers to indicate their name, registered trade name or registered trademark,
and their postal address and electronic means of communication, where available, on the packaging
or, where this is not possible, on an accompanying document. This also applies to imported generic
or unbranded packaging materials (e.g. paper sheets) that the importer intends to place on the
market, as the absence of information on the packaging does not remove the obligation
to demonstrate compliance. The importer placing such packaging on the market will need to
assume responsibility for the documentation and compliance requirements.
As a general principle, importers should engage in dialogue and make necessary contractual
arrangements with suppliers or manufactures in third countries to ensure that the products they
import are in compliance with the relevant rules under PPWR. In the case of generic and/or
unbranded imported packaging, a document that accompanies the packaging upon import, such as
a shipping document, may be used to meet the requirements under Article 18(2)(d), provided that
all information required is included in it.
12) Does packaging transiting the EU towards non-EU destinations need to comply with
PPWR rules? NEW!
Transit through the EU must be handled in accordance with general EU product rules and customs
legislation. As specified in the Commission Guidance, point 19, packaging or packaged products
intended to be placed on the EU market need to comply with the PPWR rules.
If the packaging or packaged products will not be 8declared for the release for free circulation9 but
remain in transit in the EU on the way to a non-EU destination, compliance with PPWR
requirements is not required as it is not considered placed on the market.
For imported products, placing on the market is generally considered to occur when the products
are 8declared for the release for free circulation9 23. The purpose of release for free circulation is to
fulfil all import formalities so that the goods can be made available on and circulate freely in the
EU market. Products declared as such thus need to be compliant with the applicable Union
harmonisation legislation. In practice, however, the release for free circulation and the placing on
the market may not take place at the same time, e.g. in the case of distance sales, when placement
on the market occurs before release for free circulation.
If a company imports packaged products to the EU and subsequently exports them to a third
country, the packaged products will only have to comply with the PPWR requirements if they are
placed on the market in the EU. Placing on the market requires an offer or an agreement between
two or more legal or natural persons for the transfer of ownership, possession or any other property
right concerning the product in question. Therefore, if goods only transit the EU, without being
released for free circulation or placed on the market, they are not required to comply with PPWR
rules.
13) Can information already required e.g. under food legislation be considered sufficient
to fulfil the requirements set out in Article 15(5) and 15(6) of the PPWR? NEW!
Please consult the Commission9s 8Blue Guide on the implementation of EU product rules9, section 2.3 and 2.5), as
well as the Commission Notice for the PPWR, point 19.
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