The short answer
From 12 August 2026 all packaging placed on the EU market, including packaging around products made in China, must comply with the Packaging and Packaging Waste Regulation (EU) 2025/40: limits on PFAS in food-contact packaging and on heavy metals, an EU declaration of conformity and technical documentation. Harmonised labels follow from 2028 and, from 2030, mandatory recyclability, minimum recycled content and a maximum empty space ratio of 50%. The obligations fall on manufacturers, importers and distributors, but the data is requested from Chinese suppliers.
Who this guide is for
Chinese packaging manufacturers, producers of goods packed in China and sold in the EU, and online sellers and platforms shipping to European consumers.
Who has obligations
The manufacturer is whoever produces the packaging or has it designed and produced under its own name; the importer is whoever first places it on the EU market; distributors and fulfilment service providers must check compliance. Anyone selling directly to European consumers from outside the EU must appoint an authorised representative for extended producer responsibility in each Member State where they sell.
What changes from 12 August 2026
Food-contact packaging must not exceed the limits set for PFAS; for all packaging, the combined concentration of lead, cadmium, mercury and hexavalent chromium must stay below 100 mg/kg. Every packaging item needs an EU declaration of conformity and technical documentation demonstrating compliance with the requirements, to be kept and provided to the authorities on request.
The next milestones: 2028 and 2030
From August 2028 the harmonised material label for waste sorting comes in. From 2030 all packaging must be recyclable (grades A, B or C), plastic packaging must contain a minimum share of recycled content, e-commerce, grouped and transport packaging may not have more than 50% empty space, and certain single-use formats are banned.
E-commerce and distance sales
Anyone shipping directly to European consumers must be entered in the producer registers of the destination countries and join the extended producer responsibility schemes; online platforms must check this. Without registration, products can be removed from the marketplace.
Step by step
- 01Inventory packaging by product: materials, weights, suppliers, destination markets
- 02Collect PFAS and heavy metal declarations from suppliers
- 03Prepare the EU declaration of conformity and technical documentation
- 04Register with EPR schemes and appoint the authorised representative where required
- 05Plan for the 2028 harmonised labels
- 06Redesign packaging for recyclability, recycled content and empty space by 2030
Mistakes to avoid
- Assuming the regulation only applies to European manufacturers
- Forgetting secondary and transport packaging
- Putting off redesign until 2029, when suppliers and recycled materials will be scarcer
How we help
From Shanghai we collect declarations and data from packaging suppliers; from Rome we prepare the technical documentation, check recyclability requirements and handle EPR registrations in Italy and other countries.