Coverage of the EU Packaging and Packaging Waste Regulation has focused on what packaging must contain. Equally consequential is who is answerable for it, and the answer catches people out.
The scope
Businesses placing packaging on the EU market — manufacturers, importers, distributors and e-commerce operators — should assess their obligations. The regulation became enforceable on 12 August 2026 with no grace period.
Two items on that list deserve attention.
Importers carry the obligation
A producer outside the EU selling into it does not escape the regulation. The entity placing the goods on the market is responsible.
For a small beverage brand this cuts two ways depending on which side of the transaction you sit.
If you import ingredients, concentrates or packaging components from outside the EU, you carry the compliance obligation for that packaging — not your supplier. If your supplier cannot produce substance declarations, that is your exposure, not theirs.
If you export into the EU, your importer carries it. They will increasingly ask you for documentation, and a supplier who cannot provide it becomes a compliance risk they can resolve by changing supplier.
This liability is frequently accepted without being understood, usually because it lives in a contract clause nobody read closely.
E-commerce shipping packaging counts
The transit box is packaging under the regulation, not logistics material.
For a brewery or beverage brand selling direct to consumers, this brings the shipping carton, void fill, protective inserts and tape into scope alongside the bottle and label.
Minimisation requirements apply. A small item shipped in an oversized box with plastic void fill is exactly the pattern the rules target.
What applies now versus later
In force from 12 August 2026: Article 5 on substances of concern, requiring that presence and concentration of such substances in materials and components be minimised, alongside essential requirements on design for recycling and minimisation.
Still ahead: harmonised pictograms, mandatory recycled content (2030 and beyond), recyclability grading (2028 onward). Implementation is phased to 2040.
Practical steps
Establish who the importer of record is for every component you buy from outside the EU. Not who you buy from — who places it on the market.
Collect declarations, not assurances. A verbal confirmation from a supplier is not a compliance record.
Audit your shipping configuration. Box-to-product ratio is the most visible minimisation issue and the easiest to fix.
Follow the consultations. Public comment on implementing guidance is ongoing, and the detail of how requirements are demonstrated is still being settled.
