EU Packaging and EPR Rules for Handicraft Importers: PPWR, Germany and France

Oct 10

6 min read

Every cushion, mug or carved box you import into the EU arrives in packaging: polybags, cartons, tissue, tags, fillers. Since 12 August 2026 that packaging falls under a single EU regulation, and in most cases the importer pays for it.

This guide explains who counts as the "producer" when you import, how Germany and France apply extended producer responsibility (EPR), and what information to request from your supplier. For customs paperwork, see our documents and HS codes guide.

For EU duties, GSP and the India–EU trade agreement, see our guide to importing Indian handicrafts into the EU in 2026.

The PPWR in brief

The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025. It applies from 12 August 2026 and replaces the old Packaging Directive 94/62/EC, although some of the directive's provisions continue to apply. Because it is a regulation, the core rules are the same in every Member State. EPR fees and registers are still run nationally.

Obligations are phased in. These are the dates from the Commission's PPWR FAQ and guidance:

Obligation	Applies from
General application, including manufacturer and importer duties	12 August 2026
Harmonised material sorting label (Article 12(1))	12 August 2028, or 24 months after the implementing act if later
Minimisation requirements (Article 10)	1 January 2030
50% maximum empty space for grouped, transport and e-commerce packaging	1 January 2030, or 3 years after the implementing act
Recycled content in plastic packaging	1 January 2030, or 3 years after entry into force of the related act

For food-contact packaging, a PFAS restriction has applied since 12 August 2026. By 2030, all packaging must also be recyclable.

Manufacturer vs producer: which one are you?

The PPWR uses two roles, and an importer can hold both.

Manufacturer: responsible for packaging conformity. Germany's Central Agency explains this as the party that makes the packaging or packaged product, or has it made under its own name or trademark. If you order private-label goods packed under your brand, check whether this role falls to you. The manufacturer draws up the technical documentation and the EU declaration of conformity (Article 39). Suppliers must provide the information needed to show conformity (Article 16), according to the FAQ.
Producer: carries EPR, meaning registration, reporting and fees, in the Member State where the packaging becomes waste. Under Article 3(15), a producer can be a manufacturer, importer or distributor. The Commission's guidance gives the rule that matters most to buyers. A company that buys a packaged product from a third country and supplies it in its own Member State is the producer, because it is the first company making the packaged product available there.

Some practical points from the guidance:

An importer must be established in the EU. A branch of a non-EU company does not qualify.
In distance selling, the guidance treats the distance seller as the producer. Online platforms must check that sellers comply with EPR.
Producers register and report under Article 44 and pay EPR fees in the Member State where the packaging is expected to become waste. If you sell into several EU countries, you may need a registration in each.

The importer must also make sure the non-EU manufacturer's conformity steps have been completed. The importer's own name, trade name or trademark, and postal address must appear on the packaging or an accompanying document.

Germany: VerpackDG and LUCID

On 12 August 2026 the PPWR, together with the national implementing act VerpackDG, replaced Germany's Packaging Act (VerpackG). The basic duties remain the same: registration, system participation and data reporting.

Who is the producer: the first company in the German supply chain. A foreign company is the producer only if it ships directly to end users in Germany.
LUCID registration: if you distribute packaged goods in Germany, you must be registered in LUCID. Registration is free. You enter master data, packaging types and the brand names visible on your packaging.
System participation: if you register packaging that is subject to system participation, you must confirm that you meet this requirement.
Data reporting: you report packaging volumes by material, in kilograms to your system. You must file the same report in LUCID.
Authorised representative: foreign producers without a German branch that sell directly to end users in Germany must now appoint one.

France: EPR, unique identifier and Triman

France has run packaging EPR for a long time. Household packaging has been covered since 1993, and since 2024 it sits in a combined scheme with graphic papers (EMPAP). The scheme names importers whose products are sold in packaging as producers.

Join a PRO: producers join an approved eco-organisme, currently ADELPHE, CITEO or LEKO, and pay a fee that can be adjusted up or down for environmental performance.
Register and use a unique identifier: producers register on ADEME's SYDEREP registry and show a unique identifier.
Triman and sorting information: products under an EPR scheme must carry the Triman logo with instructions on how to sort them. Where parts are sorted differently, each part needs its own instruction.
Penalties: the ministry lists fines of up to €7,500 per unit or tonne placed on the market.

Home textiles have a second French scheme on top of packaging. The TLC scheme covers new household apparel, linen and footwear for consumers. If you import bedsheets, table linen or similar items into France, check your status under TLC as well.

What to ask your supplier

You file the reports, but the data comes from your supplier. Ask for this before the first shipment:

A packaging specification per SKU that lists every component: inner bag, wrap, carton, tags, inserts and fillers.
The material of each component, matching the categories your scheme reports, such as paper and board or plastics.
The weight of each component per unit and per master carton, so you can convert shipments into kilograms by material.
Which components are sales, grouped or transport packaging, because German system participation and French household schemes apply to different packaging.
Conformity information you need as importer or manufacturer, which Article 16 requires suppliers to provide.
Space on labels or inserts for your name and address, any national sorting marks such as Triman, and later the harmonised EU label.
Notice of any change in packaging materials or weights, so your reports stay accurate.

This article is general information, not legal advice. Confirm your obligations with your customs broker, your EPR compliance scheme or the national authority before you sell.

FAQ

I only import and resell. Am I really the packaging producer?

Usually yes. Under the Commission's guidance, the company that first makes a packaged product from a third country available in a Member State is the producer for that country.

Can my Indian supplier register in LUCID for me?

Not for goods you import and resell. In Germany, the producer is the first company in the German supply chain, so that is you. A foreign supplier is the producer only when it ships directly to German end users. In that case it must appoint an authorised representative.

Do I need the new EU sorting label now?

Not yet. The harmonised label under Article 12(1) applies from 12 August 2028, or 24 months after the implementing act if that is later. National requirements such as France's Triman still apply in the meantime.

Does the PPWR cover shipping cartons?

Yes. Transport and e-commerce packaging are within scope, and empty-space limits for them apply from 2030.

Working with Kraft Bharat

Kraft Bharat makes Jaipur blue pottery, Saharanpur wood carving, Sanganeri block print textiles, epoxy resin and wood homeware, and quilted, patchwork and Banjara embroidery bags for buyers worldwide. Tell us your EPR reporting needs when you request samples. We offer custom labels and private label, and provide full export documentation. MOQs are around 500 pieces depending on the product. Samples are paid, and production usually takes 30–45 days. For what else to check in a supplier, see our guide on how to choose handicraft exporters from India.