PPWR生效后卖家暂停欧盟销售，合规专家给出替代方案
Why sellers are pausing EU sales over the PPWR – and what to do instead
欧盟《包装和包装废弃物法规》（PPWR）自2026年8月12日起适用，部分英国等地卖家因不清楚具体要求而暂停欧盟销售。包装合规顾问Nadezda Walz指出，EPR注册（如德国LUCID）与PPWR下的包装合规声明是两项不同义务，互不替代；品牌方通常被视为制造商，需按每种包装类型、以销售国要求的语言出具声明，依据供应商技术文档，食品接触包装的PFAS限值通常需要实验室报告。
文章区分了EPR注册与PPWR包装合规声明两项义务，并给出从供应商收集技术文档的起步顺序，便于卖家核对自身材料缺口。
Nadezda Walz helps online sellers with packaging compliance (EPR, LUCID, PPWR) and is a former Amazon FBA seller herself. packaging-compliance.de. Today Nadezda share’s the challenges she’s see with PPWR and her advice for continuing to sell to the EU while remaining compliant:
Since the 12th of August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) has applied. Some sellers, including many in the UK, have paused their EU sales because they are unsure what is actually required of them. That reaction is understandable. But there is a better way: a clear plan, step by step.
Why it feels so confusing
When I told a business owner I know that he would need data on heavy metals in every part of his packaging – down to the labels and tape – he looked at me as if I had made it up. That is a normal first reaction to a new law. I used to sell on Amazon FBA myself, and I only learned about Germany’s packaging register, LUCID, when Amazon asked me for the registration number. There was no one to ask, and YouTube talks about success stories, not paperwork.
Two different obligations
Many sellers mix these up:
- EPR registration (such as LUCID in Germany): you register and pay for the recycling of your packaging in each country where you sell.
- The EU Declaration of Conformity for packaging (new under the PPWR): you confirm that the packaging itself meets the requirements, for example on heavy metals.
One does not replace the other.
Who issues the declaration
Under the PPWR, the manufacturer is not only the company that physically makes the packaging, but also the one that has packaging or a packaged product made under its own name or trademark. If your brand is on the product and everything is made in China, it is usually you who is responsible – not the factory. A declaration is needed for each type of packaging, in the language or languages required by each country where the product is sold.
Which documents support it
The declaration is based on technical documentation. The PPWR does not require new lab tests for everything: test reports or substantiated declarations from your suppliers can be used. Testing is needed where such evidence is missing – and for food-contact packaging, PFAS limits usually call for a lab report. A simple “we are compliant” letter without data is weak evidence.
In practice, this takes time. One of my clients spent about a month collecting documents from her supplier in China – and received only half of what she had asked for. The regulation is new, and many suppliers do not yet know exactly what is expected of them. But this is changing: more and more suppliers already know about the PPWR. As with any new law, the start is difficult, but the market adapts quickly.
Labelling
Packaging labelling is already mandatory. Harmonised sorting pictograms will follow later, but the obligation to label applies now.
Where to start tomorrow
- List every type of packaging you use: boxes, bags, filling material – and labels and tape.
- Ask your suppliers for technical documentation for each one.
- Check your EPR registration in every EU country where you sell.
- Prepare a declaration for each packaging type, in the required languages.
- Check your labelling.
My main advice: do not stop selling in a panic. Start by requesting documents from your suppliers – it is the step that takes the longest.
来源：channelx · channelx.world