Yes. Every packaged product placed on the European market is subject to the PPWR, regardless of the country of manufacture. The obligation falls on the party placing it on the market (importer, brand, private-label distributor or authorised representative established in the EU), which signs the declaration of conformity and keeps it for 10 years (reusable packaging) or 5 years (single-use packaging). Surveillance authorities may inspect packaging produced in Germany or China alike. For a non-EU brand selling through a marketplace, the importer or established authorised representative bears legal responsibility, and that appointment is now required: since 10 July 2026 in France for every producer not established there, and since 12 August 2026 under Article 45 of the PPWR. Our dedicated article explains the mechanism.
Read the source article: PPWR packaging regulation: EU 2025/40 changes in 2026