Importing liquid containers into the EU: PPWR and EPR

If you import liquid containers into the EU, the Packaging and Packaging Waste Regulation makes you a producer whether or not the cans themselves count as packaging. The cartons, pallets and wrap they arrive in are packaging you first make available: you register, you report and you pay the fees, not your supplier and not the factory. Where the cans go to businesses that fill them, they are packaging too, and you keep the manufacturer’s declaration of conformity on file.

What changed, and when

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, was adopted on 19 December 2024, entered into force on 11 February 2025 and has applied since 12 August 2026. The harmonised label is due from 12 August 2028 and recycled-content targets from 1 January 2030. It replaces the old packaging directive with a regulation.

Under the old directive each member state wrote its own version, so an exporter faced 27 slightly different definitions of what counted as packaging, what had to be reported and by when. A regulation removes the translation layer: the text that applies in Ireland is the text that applies in Poland.

Registration, reporting and fee collection still run through each country’s own EPR scheme, so the obligations are now uniform while the paperwork stays local. An importer selling into five member states has one rulebook and five registrations.

PPWR timeline: what applies to containers from 2026 to 2040

The PPWR has applied since 12 August 2026, but the recyclability, recycled-content and re-use duties that reach jerrycans, pails, drums and their export packing start on 1 January 2030 and tighten in 2035, 2038 and 2040.

Where a date hangs on a Commission act, the later date applies: 24 months after the label or design-for-recycling act, 30 months after the reusable-label act, 3 years after the recycled-content act.

The grades come from Annex II. Table 3 scores each packaging unit for design for recycling: grade A at 95% or more, B at 80% or more, C at 70% or more. Below 70% the packaging is technically non-recyclable and may not be placed on the market. Table 1 sets 22 packaging categories, each to get its criteria in delegated acts due by 1 January 2028 (Article 6(4)). Steel jerrycans, tinplate pails and stainless water cans sit in category 4, which names tinplate and stainless steel; HDPE jerrycans in category 10 (rigid PE), polypropylene buckets in 12, cartons in 2 and wooden pallets in 20.

Table 1 also shapes the EPR return. Under Article 44(7) and (8) and Annex IX, a producer placing 10 tonnes or more of packaging a year on a national market reports weight by Table 1 category, and a smaller one by seven material groups. Table 4 lists what the criteria will weigh, including closures, labels, colours, barriers and coatings, and ease of emptying, so a can’s cap, label, pigment and any barrier treatment all count. Our HDPE properties guide covers how the resin recycles.

Packaging used to carry dangerous goods under Directive 2008/68/EC, which applies ADR, RID and ADN to road, rail and inland waterway transport, escapes three of these duties. They are recyclability (Article 6(11)(f) disapplies the whole article), recycled content (Article 7(4)(f)) and the re-use targets (Article 29(4)(a)). Where the PPWR conflicts with that directive, the directive prevails (Article 2(2)). No other article exempts it, so a UN-approved can still meets the heavy-metal limit, needs a declaration and technical file, and counts for EPR fees.

The exemption follows the contents: the same UN-marked HDPE can filled with drinking water or a non-hazardous detergent gets none of it. The text names only carriage under that directive; it does not mention the IMDG Code. Our dangerous goods transport guide covers how a liquid is classed.

PPWR vs PPWD: what changed from the 1994 directive

The PPWR keeps the old directive’s heavy-metal ceiling and turns its general essential requirements into measurable rules the manufacturer must prove in a technical file. Directive 94/62/EC, the Packaging and Packaging Waste Directive (PPWD), told member states what to achieve. Regulation (EU) 2025/40 applies directly in every member state (Article 71), and its Annex XIII maps each old article to its new place.

Parts of the directive run on. Article 70(1) keeps its minimisation requirement until 31 December 2029 and its recycling-target and reporting provisions until 31 December 2028. The Commission’s guidance, Notice C(2026) 3702, says that until the design-for-recycling acts take effect, manufacturers meet the directive’s recycling requirement and EN 13430:2004, with no PPWR conformity assessment for recyclability. It adds that the Decision 97/129/EC abbreviations may not be used after 12 August 2028, so check any material code moulded into a can.

The part that catches importers

Under PPWR an importer that first makes packaging available in a member state is normally the producer, which carries the extended producer responsibility duties. Design, labelling and recycled-content conformity sit with the manufacturer, and the importer must check them before placing the goods on the market. An importer selling under its own name or trademark becomes the manufacturer as well. Concretely:

• Register in each member state where you first place packaging or packaged goods on the market. It is per country, not once for the EU.
• Report packaging data to the national EPR scheme and pay the fees, normally calculated on weight placed on the market multiplied by a per-material rate that varies by material and by country.
• Finance the downstream: collection, sorting, recycling and disposal of the packaging you put into the market.
• Keep the EU Declaration of Conformity on file and be able to produce the technical documentation showing compliance with design, recyclability and substance restrictions.

Retention periods are worth noting because they differ by packaging type: five years for single-use packaging and ten years for reusable. A refillable jerrican is a reusable container, so plan on the longer file.

Reusable also changes what the file has to prove, as well as how long it is kept. Reusable packaging is expected to be designed for multiple cycles, and the evidence sits in the technical documentation alongside the conformity declaration. For a jerrican that is mostly a statement of the obvious, since the whole product is built to be refilled for years, but somebody has to write it down and hold it.

Is a jerrican packaging?

A jerrican sold to a business that fills it, or sold already filled, falls within the packaging definition the PPWR uses, which is why importers of containers get pulled into EPR alongside importers of boxes and bottles. The confusion usually comes from thinking of a jerrican as equipment rather than packaging.

The can is durable, it is bought as a product in its own right, and it may be used for years. What decides it is use: a can sold empty to an end user for its own use is a product, while the same can sold to a filler or sold full is packaging, whatever its price or service life.

The shipping packaging is separately in scope, so the carton, the pallet, the stretch wrap and the corner protectors all count towards the weight you report. An importer who declares only the containers has under-reported, and transport packaging is often a surprising share of the total.

The practical question is which national scheme, which material category and which fee rate apply. Those answers come from the member state, and they differ.

PPWR requirements for importers: the checks before release

An importer may place packaging on the EU market only after checking the manufacturer’s work, and for imports the Commission’s guidance puts that moment at release for free circulation. Article 18(2) sets four checks:

• the manufacturer has carried out the Annex VII conformity assessment and drawn up the technical documentation;
• the packaging carries the Article 12 labels that apply on that date;
• the required documents travel with it;
• a type, batch or serial number and the manufacturer’s name and postal address appear on the packaging, through a QR code or in an accompanying document (Article 15(5) and (6)).

The importer adds its own name, trade name or trademark and postal address the same way (Article 18(3)). It protects compliance in storage and transport (18(5)) and hands an authority the documents within 10 days of a reasoned request (18(8)). Packaging it believes non-compliant stays off the market, and anything already sold is corrected, withdrawn or recalled (18(2) and (6)).

Who counts as the manufacturer decides whose file it is. The Commission’s guidance says a supply chain has one: normally the maker of transport packaging, unless the user’s name or trademark is on it, and the filler of sales packaging. Ordering cans under your own brand, as in a private-label order, makes you the manufacturer (Articles 3(1)(13) and 21). Either way, Article 16 obliges the packaging supplier to give the manufacturer the information it needs, including the Annex VII technical documentation.

The packaging rules run beside the other EU import regimes: the GPSR responsible person for product safety, the commodity code and origin for duty, and CBAM on steel containers. For sales into Great Britain, the counterparts are UK packaging EPR and the Plastic Packaging Tax.

What to ask your supplier for

None of this is filed by the factory, but the factory holds the data you need to file it. Ask for:

• Packaging weight per unit, by material, for the product and its shipping packaging
• Material identification, including the polymer grade for plastic and the coating system for steel
• Recycled content, where any is claimed, with the basis for the claim
• A statement of substance restrictions relevant to the materials used

A supplier who can hand over a weight-by-material breakdown turns your EPR filing into arithmetic. One who cannot is passing the work to you.

Ask for it in the form you will file rather than in the form they hold it. An EPR registration needs weight by material per unit, per SKU, in the units the member state uses. A supplier who sends a specification sheet has given you the raw material for that, not the answer. Agreeing the format once, at the first order, saves reconstructing it from drawings every reporting period.

The other EU regimes that still apply

• ADR for moving dangerous goods by road, with UN marking granted per design type.
• Food contact: Regulation (EC) 1935/2004 framework and 10/2011 for plastics, for anything holding potable water or food-grade liquids.
• REACH for substances, including coatings and treatments.

PPWR sits on top of these rather than replacing any of them. A potable-water container entering the EU answers food contact and packaging rules; a UN-marked fuel can answers ADR and packaging rules.

The regimes are administered by different authorities and none of them checks the others, which is why a shipment can clear one and fail another. That is why compliance failures in this category surface late and all at once: nothing in the chain looks for the thing that is missing. Customs looks at classification and duty. A dangerous-goods inspection looks at UN marking and documentation. EPR enforcement looks at whether you registered and paid.

For a container programme, settle the transport approval first, because it constrains the physical design. Then settle food contact if the liquid requires it. Packaging and EPR come last: they are reporting obligations, not design ones, and can be arranged once the product is fixed.

Transport approval and packaging obligations interact. A packaging obligation is calculated from weight by material, and a transport approval constrains the wall thickness that weight comes from. A design driven up in gauge to pass a drop test therefore carries a higher EPR fee for the life of the programme. That is no reason to under-specify a can. Know the fee consequence at design stage, not as a surprise in the first reporting year.

What we hold, and what remains yours

We hold UN certification for our dangerous-goods designs plus ISO 9001, ISO 14001, ISO 45001, and we supply the weights, material identification and documentation you need for a filing. What we cannot do is register on your behalf: EPR registration attaches to the party placing goods on the market in a member state, which is the importer. Any supplier telling you they have handled your EPR has misunderstood the regulation.

Where to start

Common questions

When does the EU PPWR apply?

Regulation (EU) 2025/40 was adopted on 19 December 2024, entered into force on 11 February 2025 and has applied since 12 August 2026. Later duties are phased in: the harmonised material label from 12 August 2028 at the earliest, and recyclability grades and minimum recycled content in plastic packaging from 1 January 2030.

As a regulation, it applies directly in every member state, with no transposition into 27 national laws.

Who is the producer under PPWR if I import containers?

Usually you are, for the packaging you first make available in each member state, starting with the cartons and pallets the cans arrive in. Registration, data reporting and EPR fees sit with you rather than with the overseas manufacturer, and where the cans are packaging you also keep a copy of the EU declaration of conformity.

If you sell empty cans to a business that fills them, that filler is normally the producer of the cans. Any supplier claiming to have handled your EPR has misunderstood the regulation.

Do I register for EPR once for the whole EU?

No. Registration is per member state, in each country where you first place packaging or packaged products on the market. Fees are normally calculated on weight placed on the market multiplied by a per-material rate, and both the rate and the scheme differ by country.

How long must PPWR technical documentation be kept?

Five years from placing on the market for single-use packaging and ten years for reusable packaging, together with the EU declaration of conformity (Articles 15(3) and 18(7)). A jerrican is reusable packaging only when it meets the Article 11 criteria, including being placed on the market to be re-used multiple times, and sits in a re-use system (Article 26).

A can filled once and discarded is single-use. Where one design sells both ways, keep the file for ten years.

What should I ask a supplier for to file my EPR return?

Packaging weight per unit broken down by material, for both the product and its shipping packaging; material identification including polymer grade or coating system; recycled content with the basis for any claim; and a statement of relevant substance restrictions. That turns the filing into arithmetic.

Is PPWR mandatory in the UK?

Not in Great Britain. DAERA, Northern Ireland’s environment department, says the PPWR does not apply to packaging placed on the market in England, Scotland or Wales, and that no decision has been taken on aligning the UK with it. Much of it applies in Northern Ireland from 12 August 2026 under the Windsor Framework, but its reuse, EPR and deposit return parts do not. A UK business shipping packaging into the EU meets the PPWR there.

What does PPWR stand for?

PPWR stands for the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 of 19 December 2024. It was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025 and has applied since 12 August 2026.

It replaced Directive 94/62/EC, the Packaging and Packaging Waste Directive, often shortened to PPWD, which each member state had written into its own law.

What must a PPWR declaration of conformity contain?

Annex VIII gives the model. It carries an identification number and a unique identification of the packaging, the name and address of the manufacturer and of any authorised representative, and a statement that it is issued under the manufacturer’s sole responsibility.

It adds a description of the packaging that allows traceability, the Union acts it conforms to, the standards or specifications applied, any notified body, and a signature with place and date. Under Article 39 it must be kept up to date and be in a language the member state requires.

What does PPWR Article 5 say about PFAS and heavy metals?

Article 5 caps the sum of lead, cadmium, mercury and hexavalent chromium in packaging at 100 mg/kg. From 12 August 2026 it also bars food-contact packaging containing PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS, or 50 ppm for all PFAS including polymers.

Substances of concern must be kept to a minimum, and compliance is shown in the Annex VII technical documentation (Article 5(6)).

Can packaging imported before 12 August 2026 still be sold?

In general, yes. The Commission’s guidance, discussing the PFAS limits, says packaging placed on the market before 12 August 2026 may stay on the market and need not be withdrawn, and that for imports the date that counts is release for free circulation.

Reusable packaging placed on the market before 11 February 2025 never has to be brought into conformity (Article 15(9)), and packaging made or imported before a labelling deadline may be sold for 3 years after it (Article 12(12)).

Does a non-EU manufacturer need an authorised representative under PPWR?

Not when it sells through an EU importer, because the importer is then the producer. For conformity, Article 17 lets any manufacturer appoint an authorised representative by written mandate to hold the declaration and technical file, but it is optional.

For EPR, a producer selling direct to end users in a member state where it is not established must appoint an authorised representative for EPR there (Article 45(3)). A member state may require one from any producer based outside the EU.

Where can I read the official PPWR text and guidance?

On EUR-Lex, where Regulation (EU) 2025/40 appears in the Official Journal L series of 22 January 2025, in HTML and PDF. The Commission has added a guidance document, Commission Notice C(2026) 3702, which interprets selected articles such as the definitions of manufacturer, producer and importer, and a set of frequently asked questions dated 3 August 2026. Both are linked from the Commission’s packaging waste page.

Do existing national EPR registrations still apply under PPWR?

Yes. The Commission tells producers to keep complying with the existing registration rules in each member state where their packaging is likely to become waste. Article 44 then has every member state set up a register on a common format within 18 months of the Commission’s implementing act on that format.

Once a register runs, producers report each previous calendar year by 1 June (Article 44(7)), directly or through a producer responsibility organisation.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

• Regulation (EU) 2025/40: Packaging and Packaging Waste (PPWR)
• European Commission: packaging waste and extended producer responsibility
• ADR: Agreement concerning the International Carriage of Dangerous Goods by Road (UNECE)
• European Commission: food contact materials
• ECHA: REACH regulation
• Commission Notice C(2026) 3702: Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste, European Commission, 2026
• Packaging and Packaging Waste Regulation (PPWR): Frequently Asked Questions, European Commission, Directorate-General for Environment, 3 August 2026
• Extended producer responsibility for packaging: a guide for small businesses, European Commission, Directorate-General for Environment, 2026
• Directive 94/62/EC of the European Parliament and of the Council of 20 December 1994 on packaging and packaging waste (PPWD), Articles 5, 8, 9 and 11, repealed by Regulation (EU) 2025/40 from 12 August 2026
• Directive 2008/68/EC of the European Parliament and of the Council on the inland transport of dangerous goods, Articles 1 and 6 and Annex I
• DAERA (Northern Ireland): packaging and packaging waste, the EU PPWR in Northern Ireland

First published 12 August 2026

Last reviewed 28 October 2026 by Clarence Cheang, Co-Founder & COO. How we review our guides Fortitude21 makes and sells liquid containers; our guides carry no affiliate links.