Companies importing packaged products into the European Union are preparing for a major change in their compliance responsibilities. From 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste will apply more broadly, placing new obligations not only on packaging producers but also on EU-based businesses introducing packaged goods from non-EU markets.

The requirements cover every packaging layer accompanying an imported product. Retail boxes, plastic films, multipacks, pallets, labels, fillers, tapes and transport wrapping may all fall within the importer’s assessment. Businesses will therefore need far greater visibility over packaging specifications than is typically included in standard customs documentation.

Importers become an important compliance checkpoint

Before placing packaged goods on the EU market, importers must verify that the manufacturer has completed the relevant conformity assessment, prepared the required technical documentation and applied any necessary markings. Where adequate information is unavailable, the importer may need to delay distribution or place the shipment under an internal commercial hold until compliance can be confirmed.

This change is particularly relevant for businesses importing food, cosmetics, household products, electronics and e-commerce goods at scale. Even when the product itself meets European standards, its packaging may create additional legal and commercial exposure if its composition, weight, origin or environmental performance cannot be demonstrated.

Detailed packaging data will become essential

Importers should be able to identify the materials used across every packaging component, including paper, cardboard, plastics, metals, glass, wood and multi-material structures. This data may be required for future recyclability assessments, recycled-content obligations, environmental reporting and Extended Producer Responsibility schemes.

Supplier documentation may include material declarations, packaging weights, test results, confirmation of compliance and, where applicable, an EU declaration of conformity. Procurement teams will need to obtain this information earlier, rather than waiting until goods reach a European port or customs facility.

Food-contact packaging faces additional scrutiny

Food-contact materials will require particularly close attention because the regulation introduces limits for per- and polyfluoroalkyl substances. Packaging containing PFAS at or above the specified thresholds may not be placed on the EU market from the application date. Importers of coated papers, takeaway containers, beverage cups and other food-service formats should therefore review supplier declarations and testing evidence before shipment.

Customs procedures must connect with packaging compliance

The regulation does not create a separate packaging declaration within the customs process, nor does it alter tariff classification, valuation or origin rules. Nevertheless, customs clearance offers a practical opportunity to identify high-risk shipments and confirm whether the necessary packaging information is available.

Companies will need closer coordination between customs, procurement, sustainability and regulatory teams. Brokers and internal customs departments can flag potentially problematic materials, but responsibility for compliance remains with the importer placing the packaging on the market.

Preparation cannot wait until the deadline

Although certain detailed rules on recyclability, recycled content, labelling and packaging minimisation will apply later, importers should have a functioning assessment procedure by 12 August 2026. Businesses that begin mapping suppliers, packaging formats and documentation now will be better prepared to avoid delayed shipments, suspended sales and regulatory penalties once the new framework becomes operational.