What Every EU Importer of Footwear Needs to Know
If you import footwear into the EU, PPWR already applies to your packaging — and “packaging” means more than you think.
Since 12 August 2026, Regulation (EU) 2025/40 (PPWR) has fully replaced the old Packaging Directive. It’s no longer a directive that each member state interprets differently — it’s a single, directly applicable regulation across the entire EU.
Here’s what you need to know.
- Who is responsible?
Under PPWR, the importer placing packaging or packaged goods on the EU market for the first time is typically the “Producer.”
That means: you — not your Chinese supplier — carry the compliance responsibility, including EPR registration, technical documentation, and the Declaration of Conformity (DoC).
Your supplier’s job is to give you the evidence. Your job is to hold the compliance.
- What’s already mandatory (since 12 August 2026)
Heavy metals
All packaging materials must meet a combined limit of ≤ 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium.
Labelling
Packaging must show the manufacturer’s or importer’s name and contact details, plus a batch/type/serial identifier. If the packaging is too small, this can be on an accompanying document — but at least one component of the sales packaging must carry it.
Technical documentation + DoC
Before placing packaging on the market, you must have:
· Technical documentation — material composition, supplier info, test reports, conformity assessment records
· Declaration of Conformity (DoC) — a self-declaration signed by the Producer
The DoC is not a third-party certificate. It’s your legal self-declaration, and the responsibility stays with you.
If a market surveillance authority asks, you must provide the technical file (including DoC) electronically within 10 days.
- A common misconception: “Do I need a test report for every order?”
No. PPWR manages compliance by packaging type, not by order.
If the material, ink, glue, and supplier stay the same, different sizes and different orders can share one test report.
But you must re-test if any of these change:
· Paperboard supplier
· Ink brand or formulation
· Glue
· Print colour (different colours = different ink formulations)
- Coming in 2030 — plan now
Void space limit
From 1 January 2030, e-commerce packaging must not exceed 50% empty space, unless technically unavoidable. If you’re shipping shoe boxes in oversized cartons with filler, that model won’t comply.
Recyclability
From 2030, all packaging must be recyclable and rated A, B, or C. Packaging below 70% recyclability will be considered “technically non-recyclable” and banned from the EU market. From 2038, the minimum rises to grade B.
Recycled content in plastic packaging
Plastic components (e.g. tape, poly bags) face mandatory recycled content thresholds from 2030.
- What to do now — an action checklist
- Confirm your role. If you’re the importer, you’re the Producer.
- Map every packaging component. Inner box, outer carton, tape, filler, poly bag — each is a separate compliance unit.
- Get heavy-metal test reports. One per packaging component. Different suppliers = separate reports.
- Build your technical file and sign your DoC. Your supplier provides material data; you sign the declaration.
- Register for EPR in the member state(s) where you place goods on the market.
- Review your packaging design against the 2030 void-space and recyclability rules.
12. One practical note
The harmonised labelling rules (the standardised sorting pictograms) are still pending. The Commission missed the 12 August 2026 deadline for the implementing act.
That doesn’t stop you from acting now. Heavy metals, technical documentation, DoC, EPR registration, and the traceability labelling requirements are all live or imminent.
The bottom line
PPWR isn’t a supplier problem — it’s an importer problem. The earlier you build your compliance file, the smoother your EU market access stays.
