What China Export Suppliers Must Do Under PPWR Compliance

What Every China Export Supplier Should Do Right Now

 

If an EU customer has asked you to follow PPWR regulations, here is your action plan:

 

Step 1 - Clarify the Scope Immediately

Ask your customer which packaging elements are in scope. PPWR covers virtually all packaging types:

Primary packaging (product contact layer)

Secondary packaging (boxes, wrappers around the primary)

Transit/shipping packaging (cartons, pallets, stretch film)

Printed inserts, leaflets, labels, adhesives

Different categories may have different requirements. Get clarity before you invest time in compliance work.

 

Step 2 - Compile a Full Packaging Material Declaration

Prepare a detailed document listing every packaging component used for shipments to this customer, including:

Material type (e.g., corrugated board, PET, PE film, paper)

Layer structure - especially for multi-layer laminates or composite materials

Weight and volume per unit

Ink, coating, adhesive, and additive compositions

Any recycled content already present

This single document becomes the foundation for everything else.

 

Step 3 - Obtain Heavy Metal and Substance Test Reports

Commission testing from an accredited laboratory (ISO 17025) for heavy metals and restricted substances in your packaging materials. Reports from recognized testing houses such as SGS, TÜV, Bureau Veritas, or CTi carry significant weight with EU importers and authorities. A self-declaration without supporting test data is weak protection for both parties.

 

Step 4 - Verify and Document Recycled Content

If your packaging contains recycled materials - particularly recycled plastic - obtain certificates from your material suppliers confirming the recycled content percentage. PPWR's upcoming recycled content targets mean these figures will need to increase over time. Building a traceable chain of custody now positions you well for future requirements.

 

5 - Assess Recyclability of Current Packaging

Review whether your current packaging designs meet EU design-for-recycling criteria. Complex multi-material constructions that cannot be easily separated often score poorly under recyclability assessments. If you identify problematic packaging, discuss alternatives with your customer rather than waiting for them to reject shipments.

 

6 - Prepare a Declaration of Conformity

Work with your customer to prepare a formal Declaration of Conformity stating that your packaging meets the relevant PPWR requirements. While the legal declaration ultimately comes from the EU importer, your technical data supports and validates it.

 

7 - Establish Record-Keeping Processes

PPWR requires documentation to be retained for:

5 years for single-use packaging

10 years for reusable packaging

Set up a filing system - digital is fine - that allows you to retrieve material declarations, test reports, and supplier certificates within days, not weeks, when requested.

 

8 - Engage Your Own Packaging Supply Chain

Your own suppliers of cardboard, films, inks, and adhesives are your compliance partners. Require them to:

Confirm substance compliance

Provide recycled content evidence

Support recyclability claims with technical data

Notify you promptly of any formulation changes

Documented due diligence from your side strengthens your position significantly.

 

9 - Consider Independent Certification for Strategic Accounts

For high-volume or long-term EU relationships, investing in third-party packaging compliance certification builds trust and reduces commercial disputes. It also signals to the market that you treat regulatory compliance as a core capability, not a reactive burden.

 

10 - Communicate Proactively with Your EU Customer

Do not wait for the customer to chase you for information. Send a structured response that outlines exactly what you will provide and your timeline. A professional, proactive approach turns a regulatory challenge into a competitive advantage.

 

 

What Happens If You Ignore the Request?

 

The consequences of non-compliance are real and escalating:

Shipment delays at EU ports and border checkpoints

Customs holds pending documentation verification

Product withdrawals from retail shelves

Fines and administrative penalties imposed on the EU importer (which will ultimately affect your commercial relationship)

Loss of market access if the customer switches to a supplier who complies more readily

Reputational damage in an increasingly sustainability-conscious European market

 

Packaging compliance is no longer optional for businesses serving Europe. It is becoming a baseline requirement alongside CE marking, REACH, and other EU regulatory frameworks.