19/08/2026
Who registers for packaging EPR under PPWR? Chinese supplier or EU importer?
The core rule comes down to one question: Who first places the packaged goods on the EU market?
Here is the responsibility breakdown across 4 common scenarios:
1. Standard B2B (Selling to an EU Importer)
EU importer handles import, customs & local resale.
EU importer = responsible party. Chinese manufacturer is exempt from PPWR registration.
2. Direct-to-Consumer (Amazon / Independent D2C Sites)
Chinese cross-border seller takes full responsibility. Requires EPR registration, authorized representative, recycling system and annual filings.
3. Direct B2B sale to EU companies for internal use (no resale):
Chinese seller bears PPWR packaging obligations.
4. OEM / Custom-Made Parts
β EU client handles customs: The EU customer holds EPR responsibility (whether for in-house use or resale). The Chinese manufacturer is exempt.
β Chinese supplier arranges customs (e.g., DDP): The Chinese supplier is the party first placing the goods on the market and must fulfill full EPR obligations, regardless of end-use.
π‘ Liability is determined by 5 factors: company location, destination market, sales channel, import entity, end-use.
Always define import-clearance and compliance responsibilities in contract; do not rely on verbal "internal use only" agreements.
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