EU Packaging - Requirements for Importers


What are the packaging regulation obligations for an importer in the EU?


The regulations define the responsible party for showing compliance as usually the packer/ filler or importer of packed or filled packaging. If the packaging has a brand, trademark or other distinctive mark, the obligation to demonstrate compliance would normally be considered to fall upon the brand owner rather than the packer/filler.

The basic requirements are:

  1. Packaging volume and weight must be the minimum amount to maintain the necessary levels of safety, hygiene and acceptance for the packed product and for the consumer.
  2. Packaging must be manufactured so as to permit reuse or recovery in accordance with specific requirements.
  3. Noxious or hazardous substances in packaging must be minimised in emissions, ash or leachate from incineration or landfill.
  4. Packaging cannot contain any of the heavy metals (cadmium, mercury, lead and hexavalent chromium) over 100 ppm in total weight (with some exemptions)
  5. Technical documentation supporting the essential requirements (1-3 above) and heavy metal limits must be retained for 4 years from date placed on the market and provided when requested by an enforcement officer within 28 days.

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