Knowledge

The document pack EU importers must be able to show

From 12 August 2026 the packaging rules in the EU are stricter and easier to check. This is the file your compliance team will be asked for, and the part of it that has to come from the supplier.

What changed and when

Regulation (EU) 2025/40 on packaging and packaging waste applies from 12 August 2026 and replaces the old packaging directive. Conformity is demonstrated with a declaration of conformity and technical documentation, and market surveillance authorities can ask the economic operator for that documentation. Importers and distributors are inside the chain: placing non-compliant packaging on the market is their risk, not only the manufacturer's.

The documents, and who produces them

Document	What it shows	Source
Declaration of conformity	That the packaging meets the applicable requirements	Manufacturer of the packaging, or the importer where they place it under their own name
Technical documentation	Specification, materials, construction, test results	Manufacturer, with input from the converter and printer
Material composition sheet	Every component, material type and weight per unit	Converter — this is what EPR reporting is built from
Food-contact declaration	Compliance with the framework rules for food contact materials	Manufacturer of the material and converter, where the pack touches food
Recyclability statement	Design and material data behind the recyclability assessment	Converter with the design team

Food contact is decided by a register, not by a specification

Where the packaging touches food, the framework rules for food contact materials apply and a declaration of compliance is expected. For recycled plastic in food contact the position is stricter: the recycling process itself has to be authorised and listed before the material can be used for food applications. A material specification alone does not put a supplier inside that regime, so if you need food-grade recycled content, the authorised process is the first question — not the price.

The EPR data your retailer will ask you for

Per-component material type and weight per unit — the figure EPR reporting is calculated from.
Whether components are separable and which collection stream they belong to under national sorting rules.
Registration numbers where your retail customer is already registered in a national scheme.
Any national labelling your market requires, for example separate collection marks in France and the material codes used in Italy.

Keep the file current

Technical documentation has to describe the packaging actually on the market, so it moves when the specification moves — a new material, a coating change or a switch from virgin to recycled content is a documentation change, not just a production detail. Where a claim is made on the pack, the evidence behind it belongs in the same file.

Frequently asked questions

Who issues the declaration of conformity?

The manufacturer of the packaging, or the importer where they place it on the market under their own name. Suppliers pass through the manufacturers' documentation and, where agreed, support the file with specifications and composition data.

Do you register in a national packaging scheme such as LUCID?

Registration duty sits with whoever first places the packaging on the market in that country, which is normally our customer or their distributor. What we owe you is the underlying data — materials, weights, composition — to complete that registration and the reporting that follows.

How quickly can the documents be sent?

The agreed pack travels with the shipping documents, and individual items can be sent earlier on request during the quotation stage. Ask for what you need before the order, so producing it does not become the reason for a delay.

Request a quotation

Send your item, size, quantity, artwork status and destination country — we reply with price, lead time and the compliance documents you need for your market (PPWR, food contact, Declaration of Conformity).

Send your RFQ or email sales@huaxinjiayuan.com