Last updated: 28 July 2026. This page is sourcing and quality guidance from a trading company — it is not legal advice, and it is not a substitute for a qualified adviser in your market.
PPWR applies from 12 August 2026, GPSR is already live, and EUDR follows in December. Below is what each one puts on the importer, which August date genuinely bites, and one widely repeated packaging deadline that does not exist. Then an offer to run your own SKU list, because a general explainer cannot tell you what your products need.
Who is actually liable
The factory is not on the hook. You are.
Every one of these regulations attaches to the economic operator who places the product on the EU market. If you import from China and sell in the EU, that operator is you — regardless of what your supplier's declaration says, and regardless of whether they have heard of the regulation at all.
That has three consequences worth internalising.
A supplier's assurance is not a defence. It has no legal weight if the documentation behind it does not exist or does not meet the standard. A PDF with a logo on it is not a conformity assessment.
Enforcement runs through market access, not just fines. If you cannot demonstrate conformity, the goods cannot legally be placed on the market. The practical outcome is blocked launches and stock you cannot sell — not a penalty you can budget for.
The documentation has to exist before the goods arrive. Retro-fitting a technical file to a container already on the water is the most expensive way to do this, and sometimes it is not possible at all — some failures require a design or material change, which means scrapped inventory.
PPWR — Regulation (EU) 2025/40
Packaging: what actually starts in August.
The Packaging and Packaging Waste Regulation replaces the old directive with a single EU-wide framework covering all packaging materials — plastic, paper, metal, glass — across both B2C and B2B, including packaging used in manufacturing and distribution.
It applies from 12 August 2026. That date is real, but it marks the start of the regime rather than the end of your runway: the substantive design obligations phase in through 2028, 2029 and 2030, and several of them depend on implementing acts the Commission has not adopted yet.
What importers carry
Article 18 is headed "Obligations of importers" and Article 19 "Obligations of distributors". Importers must verify that the required conformity assessment has been carried out, hold the declaration of conformity for each packaging type, and produce the documentation to a national authority within 10 days of a request. Distributors must check that the upstream obligations have been met, including the producer's EPR registration, before making packaging available.
The one that genuinely bites in August
From 12 August 2026, food-contact packaging containing PFAS above the regulation's thresholds may not be placed on the EU market. If your product ships in coated paper, moulded fibre, greaseproof liners or fluorinated films made in China, that is the question to put to your supplier this month — with a test report behind the answer, not an email.
About that "40% empty space by August" rule
You will see agencies selling an urgent pre-August packaging redesign on the strength of an empty-space cap. Read Article 24 before you pay for one.
Article 24 is headed "Obligation related to excessive packaging". It requires economic operators who fill grouped packaging, transport packaging or e-commerce packaging to ensure the maximum empty space ratio is 50% — not 40%. And it does not apply in August. The text ties it to "1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest", and the Commission is required to adopt the calculation methodology by 12 February 2028. So the earliest possible date is 1 January 2030, and if that methodology slips the obligation moves with it, into 2031.
Two details in the same article do deserve your attention now. Filling materials count as empty space — air cushions, bubble wrap, foam and paper cuttings are measured as void, not as content. And Article 24(4) puts a separate, earlier duty on those filling sales packaging: minimise empty space, by 12 February 2028.
The honest read. The rule is real, the number is 50%, and the deadline is 2030 at the earliest. Anyone quoting you for an urgent August carton redesign on empty-space grounds has misread Article 24 — or is hoping you will not read it.
What is worth doing before 2028 is measuring your current void ratio, including filler, on your top-moving cartons. You cannot design against a number you have never calculated, and the measurement costs you nothing but an afternoon.
Selling direct into the EU, and the micro-enterprise question
If you sell direct to EU consumers from outside the EU, you must appoint an authorised representative inside the EU. PPWR does contain a micro-enterprise derogation, but read what it actually does: it re-assigns the manufacturer obligations to the packaging supplier, and only where that supplier is established in the Union. If your packaging is made in China, there is no EU-established supplier to hand those obligations to, so the derogation does nothing for you. Company size is not an exit from this regulation for anyone importing from Asia.
What comes later
Harmonised labelling under Article 12 — material composition and sorting information carried on the packaging, with digital carriers such as QR codes where the implementing acts provide for them — applies from 12 August 2028 at the earliest, and moves if those acts slip. Minimum recycled content thresholds for plastic packaging follow from 2030. Producer registration stays national: Article 44 requires each member state to keep its own register, so there is no single EU database coming to replace Germany's LUCID and its equivalents. Plan for per-country registration indefinitely.
The honest caveat
A number of delegated and implementing acts are still outstanding, which means some technical criteria — recyclability grading in particular — are not yet fully defined. That is not a reason to wait. It is a reason to build flexibility into the decisions you are making now, and to work with someone tracking the pipeline rather than reacting to headlines about it.
EPR
Registration is per country. There is no EU-wide shortcut.
Extended Producer Responsibility makes the party that first places packaged goods on a national market financially responsible for their collection and recycling. In practice: register in the national producer registry of every member state where you sell, join a producer responsibility organisation, report volumes and materials, and pay the fees.
If you sell online into countries where you have no legal entity, you must appoint an authorised representative in each of them. Without one, products risk being blocked and marketplace listings suspended.
EPR now extends well beyond packaging — electricals, batteries, textiles, tyres and furniture, with categories and fee structures set member state by member state. The same product can carry different obligations in France and in Germany.
Two different regimes, two different failures
GPSR is product safety. EPR is environmental financing. They are different things and you can fail one while passing the other.
A product with an immaculate technical file and no EPR registration is as unsellable as a registered product with no safety file. Both get checked, and increasingly they get checked by different people.
EUDR
Wood and paper — 30 December 2026.
The EU Deforestation Regulation requires due diligence statements for regulated commodities, including wood and paper products. Enforcement was delayed by twelve months and now begins 30 December 2026 for large and medium operators, and 30 June 2027 for small and micro operators, with simplified obligations depending on company size and supply chain role.
If you import wooden goods, wooden packaging, paper products or printed materials from China, this applies to you, and it requires traceability information your factory may never have been asked for before. Getting it from a Chinese supplier after the fact is considerably harder than specifying it at the order stage.
This is where we are strongest. Wood products and paper goods are two of the categories we have traded longest. We know which factories can produce the chain-of-custody information and which cannot — and that distinction is worth more than any certificate.
The process
Compliance runs alongside production, not after it.
- Gap list per SKU. Send us your product list and your destination markets. We map which regulations bite, what documentation each one requires, and where you currently have nothing. Free, returned in 5 business days.
- Specification. Requirements go into the purchase order as spec, not as a request. Factories treat spec differently from requests.
- Testing. We coordinate with CNAS-accredited and internationally accredited laboratories in China. Whether a given report is accepted depends on the scheme it was issued under and, for some categories, on the destination market's own requirements — so we confirm which route your product actually needs before booking the test.
- Documentation. Technical files, declarations of conformity and chain-of-custody records, assembled and held so you can produce them inside a 10-day window.
- Verification at inspection. Our AQL inspection checks labelling, markings and packaging conformity alongside product quality, before anything loads.
Engagement model
How this is priced.
- SKU compliance review Part of a sourcing, testing or procurement engagement — not sold as a standalone product.
- Certification project Quoted per certification. Timeline depends on the scheme and the product.
- Ongoing compliance management Included in procurement retainers.
For formal legal opinions, use a qualified adviser in your market — and we will work alongside them. Our part is the sourcing, testing and documentation side, and knowing which factories can actually produce what the file needs.