PPWR for Indian exporters: what your packaging supplier must document before the EU deadlines

The EU's new packaging law has applied since 12 August 2026. Most of its duties fall on companies inside the EU. But much of the paperwork it asks for can only come from factories outside it. For an Indian exporter, that means your own packing line and your packaging supplier.

Here is the short answer. Your EU buyer must be able to show that every pack it sells meets the Packaging and Packaging Waste Regulation (PPWR). That needs data on materials, chemicals and weights that only you and your supplier hold. The law already obliges packaging suppliers to hand that data over. So the work today is to collect it, item by item, before the bigger obligations arrive between 2028 and 2030.

We make tapes, films and paper packaging at Jagannath Polymers in Jaipur, and we export to 20+ countries. So we see this law from the supplier's end of the chain.

I am not an EU lawyer, though. I have linked every point below to the Regulation itself or to the European Commission's own FAQ. Before you act on any of it, check your own case with an adviser who works on EU product rules.

How does an EU law reach a factory in India?

Through three roles. The full text of Regulation (EU) 2025/40 on EUR-Lex (Official Journal of the European Union, 22 January 2025) defines them in Article 3.

Let us find your place in this chain first.

1. The manufacturer is whoever makes the packaging or the packed product. But if the pack carries a company's name or trademark, that company is the manufacturer, wherever it is based. So if you export under your own brand, the Regulation treats you as the manufacturer, even from India. If you pack for an EU retailer's private label, the retailer is usually the manufacturer.

2. The importer is the company established in the EU that first places your goods on the EU market. Under Article 18, it must check that the manufacturer has done the conformity assessment and drawn up the technical file. It must also check that the pack carries a batch number and the manufacturer's name and address.

3. The supplier is anyone who supplies packaging or packaging material to a manufacturer. That is your packaging supplier. Article 16 says suppliers must give the manufacturer all the information and documents it needs to show that the packaging conforms.

The manufacturer carries the legal responsibility. The Commission's PPWR FAQ (DG Environment, 2nd edition, 3 August 2026) says this responsibility cannot be moved to anyone else by contract. It also says suppliers cannot refuse to provide the documents.

I like that last line. It settles an argument before it starts.

One detail surprises people. There is a relief for micro-enterprises: when a very small brand buys its packaging from a supplier in its own country, the supplier becomes the manufacturer. That relief works only when the supplier is located in the EU. It never moves the duty onto a supplier in India.

What is the paperwork, in plain words?

Before packaging goes on the market, Article 15 asks the manufacturer for three things.

1. A conformity assessment. Annex VII calls it "internal production control", which means the manufacturer checks its own packaging. No outside body has to certify it.

2. A technical file. At the least, a description of the packaging, drawings, the materials of each component, the standards or methods used, and the test reports.

3. An EU declaration of conformity for each packaging type. Article 39 says it must be written in, or translated into, the languages each EU country requires, and kept up to date.

The file and the declaration must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

Every one of us in Indian business knows how this works with GST. The declaration is the return, and the technical file is the purchase bills behind it. The officer reads the return. He asks for the bills only when he has a doubt. And when an EU authority asks, the manufacturer has 10 days to produce the file (Article 15(10)).

Ten days is not enough to chase a supplier in another country.

So the documents must be in the file before the container leaves.

One more change catches suppliers who worked under the old Packaging Directive. Meeting the old EN 13427 to EN 13432 standards used to be taken as proof of conformity. The Commission's FAQ says these standards now serve only as guidance (the minimisation standard can still be used as proof until the end of 2029). A test against them is still useful evidence. I would not treat it as the whole answer any more.

Which dates apply to what?

I would read "at the earliest" literally. Most of the later dates say "this date, or a set time after the Commission adopts a technical act, whichever is later". If the Commission is late, the date moves.

So the file grows over time. From 2030 it must also cover minimisation, recyclability and recycled content.

The data for those later parts comes from the same supplier, so I would ask for all of it in the same letter. If time is short, I would start with items 1, 2 and 5 below, because those already apply.

What should you ask your packaging supplier for?

This is the list I would send to every packaging supplier, for every item used on goods bound for the EU. It is also the list I expect our own customers to send us.

Include the small items. Tape, labels, poly bags and desiccant sachets are packaging too, and they go into the file of the pack they belong to.

1. A materials list for each item. Every component, its material and its weight: film, paper, adhesive, ink, coating, label. Annex VII asks for the materials of components. The weights matter as well, because a plastic part under 5% of the whole pack's weight falls outside the recycled-content rule (Article 7(5)).

2. A heavy metals test report. It should add up lead, cadmium, mercury and hexavalent chromium against the 100 mg/kg limit. Ask for one per material and per colour, from an accredited laboratory. The limit itself is not new, as the old Directive had it too. Article 5(6) now asks for compliance to be shown in the technical file.

3. PFAS evidence, for food-contact packaging. Article 5(5) caps PFAS in food-contact packaging, at 25 parts per billion for any single PFAS measured by targeted analysis, among other limits. Where total fluorine is above 50 mg/kg, the Regulation expects proof, on request, of how much of it is PFAS. Ask for the food-contact declaration at the same time, because Article 39(3) allows one combined declaration.

4. A statement on substances of concern. There is no final EU list yet. Article 5(2) asks the Commission, with the European Chemicals Agency, to report on these substances by 31 December 2026. Until then, the FAQ names the ECHA Candidate List as one source to check against. A written statement against that list is a sensible start.

5. A batch or lot number you can trace. The manufacturer must identify the packaging by type, batch or serial number. For standard items such as adhesive tape and plain bags, the FAQ says traceability is normally at the level of the production batch. Ask for the lot number on the item or its carton, repeated on the invoice and packing list.

6. Recycled content records, for plastic items. The next section explains why this one needs the most care.

7. Design details for recyclability. The number of layers, the polymer in each layer, coatings, metallising, label and adhesive types. Nobody can give you a PPWR recyclability grade today, because the EU criteria are due only by 1 January 2028 (Article 6(4)). The grade will be worked out from these details, so collect them now.

8. Weight and thickness data for minimisation. From 2030, the file must show which design needs stop the pack from being lighter or smaller, with test results (Article 10(4)). Your spec sheet with micron or GSM, and any drop or compression tests, is the start. Our packaging specification review helps you build that sheet, and our guide on downgauging shows how to trial a thinner option without risk to the product.

9. A promise to tell you before anything changes. If the material, ink, adhesive or recycled source changes in a way that could affect conformity, the manufacturer must reassess (Article 15(4)). I would write a change-notice clause into the purchase order.

10. The supplier's full legal name, address and a named contact for documents. Under Article 22, every business in the chain must be able to tell the authorities who supplied it, for 5 years for single-use packaging.

Recycled content: four points that catch people

Article 7 sets minimum recycled content for the plastic part of packaging from 1 January 2030 at the earliest. For most plastic packaging that is not contact-sensitive, the figure is 35%, rising to 65% from 2040. The FAQ uses pallet wrapping film as its example of the 35% category.

Contact-sensitive packaging covers packs for food, cosmetics, medicines, food supplements and hygiene products, among others. Its targets are lower: 10% for plastics other than PET, and 30% for PET. Adhesives, paints and inks are not counted as plastic for this rule, as per the FAQ.

Now the four points.

1. Only post-consumer waste counts. The targets speak of recycled content recovered from post-consumer plastic waste. Regrind from a factory's own trimmings does not count towards them. In our trade the word "recycled" is used loosely, so when a supplier says "30% recycled", ask what kind.

2. Recycled plastic from outside the EU counts only with proof. Article 7(3) accepts waste collected and recycled in a third country only where the collection and recycling meet standards equivalent to the EU's. The Commission must set the method for checking this, including third-party audits, by 31 December 2026 (Article 7(10)). Until that method is published, nobody can promise that recycled content from India will be accepted. I would keep the paper trail anyway: where the waste was collected, who recycled it, and any chain-of-custody certificate.

3. The target is an average per plant and per year. The FAQ says the manufacturing plant must document that its average supply in a year to each manufacturer meets the target. So your supplier's plant records matter, not a test on one roll.

4. Old stock gets no pass. The FAQ says there is no exhaustion of stocks for packaging supplied before the date but placed on the market after it. A big lot of low-recycled film bought in late 2029 will not help you.

We are an Indian supplier, so point 2 is the one we will watch most closely. It decides whether recycled plastic made in India helps an EU buyer at all.

What about cartons, tape, stretch film and pallets?

They need the same papers. The FAQ says transport packaging has no exemption from conformity assessment. Pallets, pallet collars, wrapping and straps each need their own assessment and declaration.

Tape and film are two of the things we make.

They are cheap, so they get forgotten. Put them on your list anyway.

There is one relief. Under Article 12, the harmonised material label does not apply to transport packaging, except e-commerce packaging.

The empty space rule will matter more for your cartons. From 1 January 2030 at the earliest, a business that fills grouped, transport or e-commerce packaging must keep empty space at 50% or less (Article 24). Paper fill, air cushions and bubble wrap all count as empty space. The calculation method is due by 12 February 2028. A carton sized to the product already saves freight, as our guide on volumetric weight shows, and it will help here too.

What we, or any packaging supplier, cannot do for you

I want to be honest about the limits here, ours included.

1. We cannot sign your EU declaration of conformity. If you are the manufacturer, it is yours. If your EU buyer is the manufacturer, it is theirs.

2. We cannot give you a PPWR recyclability grade before the EU criteria exist. Nobody can.

3. We cannot promise that recycled content from India will count before the equivalence method is out.

4. We will not translate your declaration into Polish and Spanish (that is the manufacturer's job under Article 39).

What a good supplier can do is give you clean data for each item, and say in writing what it cannot give yet. Be careful with one-line answers. "We are PPWR compliant" on a letterhead is NOT a document.

Your calculation: how many document sets do you need?

Count packaging items, not products.

Many exporters picture one file per SKU and give up before they start.

Let us take an example. The figures are made up to show the method. They do not come from a real company.

A home textiles exporter ships 40 SKUs to the EU. Each SKU goes into a poly bag with a printed header card, inside a carton. All cartons are sealed with the same tape, and every pallet gets the same stretch film.

So this exporter needs to collect 11 document sets from suppliers, not 40 × 5 = 200. If the 11 items come from 4 suppliers, that is 4 letters.

With your own products, it goes like this:

1. List every SKU you ship to the EU.
2. Next to each, list every packaging item it uses, down to tape and labels.
3. Remove the duplicates. What is left is your list of supplier items.
4. Group the items by supplier and send each supplier the 10-point list above.
5. Tick off what comes back. The gaps are your work plan.

A check you can do this week

Take your best-selling EU product and the packing list of its last shipment. Try to name the supplier, the material and the lot number of every packaging item in that shipment.

If that takes more than an hour for one product, it will not happen in 10 days for forty.

Start with the five products that earn you the most in Europe. Send the list to their packaging suppliers this month, and keep one folder per packaging item. If we supply you, send us the same list. I would much rather answer it now than in a hurry after your buyer's compliance team calls.