PPWR Compliance for FMCG Importers in Italy

Published
, 22 minute read

Quick summary: Learn how FMCG importers bringing products into Italy can prepare for PPWR compliance, including manufacturer verification, CONAI registration, Declaration of Conformity checks, technical documentation, and August 2026 readiness.

The Packaging and Packaging Waste Regulation (PPWR) is set to transform how Fast-Moving Consumer Goods (FMCG) importers bring packaged products into Italy and the wider European Union. For businesses that import packaged foods, beverages, household products, personal care items, home care products, pet care products, or other consumer goods from outside the EU, PPWR introduces a distinct and demanding set of obligations.

Unlike manufacturers, importers do not design or produce packaging themselves — yet under PPWR they carry direct legal responsibility for confirming that packaging placed on the EU market for the first time already meets every applicable requirement. This makes verification, documentation, and supplier oversight the centre of an importer’s compliance strategy.

Unlike the previous Packaging and Packaging Waste Directive, PPWR is a regulation that applies directly across all EU Member States. This creates a consistent compliance framework while significantly raising the stakes for importers who place packaging from non-EU manufacturers onto the Italian and EU markets.

For FMCG importers managing multiple overseas suppliers, diverse product portfolios, private-label ranges, and large volumes of packaging SKUs, achieving compliance requires far more than a customs declaration. It demands rigorous supplier verification, centralized documentation, and digital processes capable of proving — on demand — that every consignment of packaging entering the EU already complies.

Importers that begin preparing today will be better positioned to avoid customs delays, respond to market surveillance requests, and protect their business from the compliance and reputational risks of non-conforming packaging.

Key Takeaways

If your business imports packaged consumer goods into Germany from outside the EU, PPWR introduces new verification and record-keeping responsibilities before goods ever reach the market.

Key compliance areas for importers include:

  • Verifying the manufacturer’s conformity assessment
  • Confirming a valid Declaration of Conformity (DoC) exists
  • Reviewing technical documentation for completeness
  • Checking packaging labelling and marking requirements
  • Understanding when an importer becomes a “manufacturer” (Article 21)
  • Appointing or verifying an EU (or Italy-based) authorised representative
  • CONAI registration and Contributo Ambientale (CAC) reporting
  • Packaging data and supplier documentation management
  • Substance restriction checks
  • Corrective action and market withdrawal readiness
  • Audit and market surveillance readiness

Rather than treating PPWR as a one-time customs formality, FMCG importers should establish scalable verification processes that support supplier onboarding, private-label programs, and future regulatory developments.

Prepare for PPWR Before Compliance Deadlines Arrive

PPWR implementation requires more than understanding regulatory requirements — it requires a structured verification and documentation roadmap built around your supply chain.

📘 Download your complimentary PPWR Implementation Handbook.

What Is the Packaging and Packaging Waste Regulation (PPWR)?

The Packaging and Packaging Waste Regulation (PPWR) establishes a harmonized legal framework governing packaging placed on the European Union market, regardless of whether it originates inside or outside the EU.

Its objective is to reduce packaging waste, improve recyclability, promote recycled content, encourage reuse, and support the EU’s transition toward a circular economy.

Unlike the Packaging and Packaging Waste Directive, which required implementation through national legislation, PPWR applies directly across all EU Member States. For importers, this means the same obligations apply whether packaging is sourced from Berlin or Bangkok — there is no lighter-touch regime simply because packaging is manufactured outside the EU.

The regulation addresses packaging throughout its lifecycle, including:

  • Packaging design
  • Packaging minimization
  • Design for recyclability
  • Recycled plastic content
  • Reuse systems
  • Packaging labelling
  • Technical documentation
  • Declaration of Conformity
  • Market surveillance
  • Extended Producer Responsibility (EPR)

For FMCG importers, compliance is not about redesigning packaging — it is about proving, through documented evidence, that the packaging your overseas suppliers manufacture already meets these requirements before it enters the EU market.

Why PPWR Matters for FMCG Importers in Italy

Italy is one of the largest import markets in Europe for packaged consumer goods, sourcing products from manufacturers across Asia, the Americas, the UK, and other non-EU regions for domestic consumption and re-export across the European Union.

FMCG importers bring in products across numerous categories, including:

  • Packaged foods
  • Soft drinks and beverages
  • Dairy and frozen foods
  • Snacks and confectionery
  • Household cleaning products
  • Laundry detergents
  • Home care products
  • Personal care products
  • Pet food
  • Private-label consumer packaged goods

These products arrive in a wide range of packaging formats, including PET and HDPE bottles, glass containers, aluminium cans, flexible pouches, plastic tubs, trays, folding cartons, corrugated shipping cases, shrink wrap, pallets, and display-ready packaging.

Under PPWR, importers are legally responsible for ensuring that packaging manufactured outside the EU complies with applicable requirements before it is placed on the EU market for the first time. This obligation exists independently of the overseas manufacturer’s own compliance efforts — if the manufacturer’s documentation is incomplete, the importer, not a distant supplier, is the party EU authorities will hold accountable.

Compliance therefore extends well beyond customs clearance. Importers must engage directly with overseas manufacturers, packaging suppliers, laboratories, freight forwarders, and EU-based logistics partners to collect, verify, and retain compliance evidence before goods are released to the Italian market.

Without structured verification processes, importers may experience:

  • Customs and border delays
  • Detained or rejected consignments
  • Incomplete or inconsistent supplier documentation
  • Increased retailer compliance requests
  • Costly packaging rework at the point of import
  • Difficulty responding to market surveillance inspections
  • Increased administrative burden across multiple suppliers

At the same time, Italian retailers and consumers are demanding more sustainable, verifiably compliant packaging — making PPWR readiness a competitive differentiator for importers who get it right early.

How PPWR Interacts with Italy’s CONAI System

Italy has operated a mature national Extended Producer Responsibility (EPR) system for packaging since 1998 through CONAI (Consorzio Nazionale Imballaggi), established under Legislative Decree 152/2006 (the Italian Environmental Code). PPWR does not replace this system — it layers new EU-wide obligations on top of it, and importers must manage both in parallel.

For FMCG importers, this means two separate but connected compliance tracks:

  • PPWR conformity — verifying the overseas manufacturer’s conformity assessment, technical documentation, and Declaration of Conformity
  • CONAI registration and reporting — registering as a packaging “producer” (a category that explicitly includes importers), declaring packaging quantities and materials placed on the Italian market, and paying the Contributo Ambientale CONAI (CAC), an environmental contribution based on material type and weight

CONAI membership is compulsory — there is no voluntary alternative — for any business, including non-Italian importers, placing packaged goods on the Italian market for the first time. Importers without a legal entity in Italy must also appoint an authorised representative established in the country to handle CONAI registration, reporting, and communication with Italian authorities.

Italy’s national CONAI labelling format and the new harmonized EU sorting symbols introduced under PPWR are permitted to run side by side during a transitional period until 11 August 2028, after which harmonized EU labelling will apply. Importers should track both formats during this window rather than assuming one immediately replaces the other.

Italy has also signalled it may seek national flexibility under Article 9 of PPWR for certain single-use plastic packaging, potentially mandating biodegradability and compostability standards in place of standard recyclability requirements for specific formats. Importers sourcing single-use plastic packaging for the Italian market should monitor this development closely, as it could affect which packaging specifications suppliers need to meet.

Understand Your Responsibilities Under PPWR

Manufacturers, importers, distributors, and brand owners each have distinct responsibilities under PPWR. As an importer, your role is defined by Article 3 of the regulation: you are the economic operator established in the EU who first places packaging or packaged products from a third country on the EU market.

Critically, importers do not issue their own Declaration of Conformity. Instead, before releasing goods to the Italian market, an importer must verify that the non-EU manufacturer has already carried out the conformity assessment, compiled the technical documentation, and issued a valid DoC. The importer’s obligation is one of diligent verification, retention, and cooperation with authorities — not of original conformity assessment.

Read our complete guide to PPWR Roles & Responsibilities.

What Should FMCG Importers Prioritize Before the August 2026 PPWR Deadline?

Although several PPWR obligations — including packaging minimization, recycled content targets, and reuse requirements — will be introduced progressively, 12 August 2026 marks the first major compliance milestone.

From this date, importers placing packaged products on the Italian and EU market should be prepared to demonstrate that every consignment is backed by valid conformity evidence.

Rather than waiting until shipments are held at the border, FMCG importers should build the verification, documentation, and digital infrastructure needed to support long-term compliance.

The following seven priorities should form the foundation of every importer’s PPWR compliance strategy.

1. Verify the Manufacturer’s Conformity Assessment

Before releasing any consignment, importers should confirm that the overseas manufacturer has completed a valid packaging conformity assessment for every packaging format and material used.

For FMCG importers, this means building a standard pre-shipment verification checkpoint into procurement and logistics workflows, rather than treating it as a customs-time afterthought.

2. Confirm a Valid Declaration of Conformity (DoC) Exists

PPWR requires an EU Declaration of Conformity (DoC) confirming that packaging complies with applicable regulatory provisions.

Importers must obtain and retain a copy of the manufacturer’s DoC for every packaging type before goods are placed on the market — and must be able to produce it to German and EU authorities on request. For businesses working with dozens of overseas suppliers, tracking DoCs manually across spreadsheets and email quickly becomes unmanageable.

3. Check Packaging Labelling and Marking Compliance

Imported packaging must carry the required identification markings, including batch or serial information and the responsible economic operator’s name and contact address. Where the manufacturer is outside the EU, importers must also ensure their own name and address appear on the packaging or accompanying documentation as required.

Reviewing artwork and labelling before shipment helps avoid costly relabelling or rework once goods have already left the country of origin.

4. Understand When You Become the “Manufacturer” (Article 21)

Under Article 21, an importer that places packaging or packaged products under its own brand or trademark — or that modifies packaging in a way that may affect compliance — is reclassified as the manufacturer. This shifts the full weight of conformity assessment, technical documentation, and DoC issuance onto the importer.

This is especially relevant for private-label programs, where a German importer sources generic products from an overseas supplier and sells them under its own brand. Importers should map their private-label portfolio now to identify where this reclassification applies.

5. Appoint or Verify an EU Authorised Representative Where Needed

Where the overseas manufacturer has no physical establishment in the EU, PPWR expects a designated EU authorised representative to serve as the point of contact for market surveillance authorities. Importers should confirm whether their manufacturers already have one in place and, where they do not, factor this into supplier onboarding requirements.

6. Register with CONAI and Manage the Contributo Ambientale (CAC)

Alongside PPWR conformity checks, importers placing packaged goods on the Italian market for the first time must register with CONAI and declare packaging quantities and materials to determine their CAC liability. This is a distinct obligation from PPWR conformity and should be tracked separately in the compliance calendar, with renewal and reporting cycles built into standard operating procedures.

7. Build a Robust Packaging Data and Supplier Verification Strategy

Importer compliance depends on accurate, complete, and accessible supplier data. Many FMCG importers continue managing overseas supplier documentation across disconnected spreadsheets, email chains, freight-forwarder records, and shared drives.

As PPWR requirements expand, fragmented supplier data creates unnecessary complexity and increases the risk of releasing non-compliant packaging onto the market. A centralized packaging data and supplier verification strategy improves visibility across sourcing regions and strengthens audit readiness — and makes CONAI reporting easier to reconcile against the same underlying packaging data.

Which FMCG Packaging Is Covered Under PPWR?

One of the most common questions FMCG importers ask is whether PPWR applies only to specific packaging materials or product categories.

The answer is simple: PPWR applies to virtually all packaging placed on the EU market, irrespective of the material used, the type of consumer product it contains, or whether the packaging was manufactured inside or outside the EU.

Whether you import packaged foods, beverages, dairy products, frozen foods, household cleaners, detergents, home care products, pet food, or personal care products, the packaging accompanying these products is generally within scope of the regulation.

For FMCG importers, compliance extends beyond consumer-facing packaging to include secondary and transport packaging used to move goods from the country of origin to the Italian market.

Primary Packaging

Primary packaging comes into direct contact with the product and plays a vital role in preserving product quality, ensuring hygiene, extending shelf life, and enhancing consumer convenience.

  • PET beverage bottles
  • HDPE detergent bottles
  • Plastic tubs
  • Glass jars
  • Aluminium beverage cans
  • Flexible pouches
  • Stand-up pouches
  • Sachets
  • Food trays
  • Paper cartons
  • Aerosol cans
  • Plastic containers
  • Milk cartons
  • Beverage cartons

Primary packaging represents one of the largest verification areas for importers because it directly influences recyclability, material composition, recycled content, and packaging design decisions made entirely by the overseas manufacturer.

Secondary Packaging

Secondary packaging groups products together for retail presentation and distribution while providing additional protection.

  • Folding cartons
  • Multipacks
  • Promotional packaging
  • Shelf-ready packaging
  • Display boxes
  • Shrink wrap
  • Cardboard sleeves
  • Retail display units

Although secondary packaging may never come into direct contact with the product, it is still subject to PPWR requirements. Importers should include secondary packaging within their supplier verification checklists and documentation records.

Transport Packaging

Transport packaging protects goods throughout international shipping, warehousing, and distribution — a stage importers manage directly.

  • Corrugated shipping cartons
  • Stretch films
  • Pallets
  • Pallet wraps
  • Plastic crates
  • Protective inserts
  • Bulk transport containers
  • Intermediate packaging

Transport packaging often represents a significant volume of imported material and should not be overlooked when assessing PPWR obligations, particularly since importers directly control freight and logistics arrangements.

Imported Packaging — The Core of an Importer’s Compliance Scope

Because imported packaging is, by definition, an importer’s entire area of responsibility, businesses should ensure every overseas supplier provides complete compliance documentation before goods are shipped.

Typical documentation to collect includes:

  • Material specifications
  • Packaging declarations
  • Technical documentation
  • Laboratory reports
  • Recycled-content information
  • Supplier compliance statements
  • The manufacturer’s Declaration of Conformity

Strong supplier collaboration — including pre-shipment checklists and standardized documentation templates — is essential for maintaining complete and accurate compliance records across a global supplier base.

Does PPWR Apply to Every Packaging Material?

Yes. Importers should assess every packaging material used across their sourcing portfolio, including:

  • Plastic
  • Paper
  • Cardboard
  • Glass
  • Aluminium
  • Steel
  • Flexible films
  • Composite materials
  • Laminates
  • Multi-layer packaging

Each material presents different regulatory considerations relating to recyclability, recycled content, material composition, and future packaging design requirements. Creating a comprehensive, supplier-mapped packaging inventory is one of the first and most important steps toward PPWR compliance for importers.

Read our complete guide to PPWR Scope.

Key PPWR Requirements FMCG Importers Must Verify

PPWR introduces several interconnected obligations affecting packaging design, recyclability, and documentation. As an importer, your role is not to implement these requirements yourself but to verify — with evidence — that your overseas manufacturers already have.

1. Packaging Minimization

Packaging should contain only the amount of material necessary to protect, preserve, transport, handle, and market products safely. Although Article 10 packaging minimization requirements become applicable later in the PPWR implementation timeline, importers should begin requesting evidence from suppliers today.

2. Design for Recyclability

Packaging should be designed to facilitate efficient collection, sorting, and recycling. Importers should request recyclability assessments from manufacturers as a standard part of supplier onboarding and periodic re-verification.

3. Recycled Plastic Content

PPWR introduces phased recycled content requirements for specific plastic packaging categories. Importers should begin preparing by:

  • Requesting recycled-content declarations from suppliers
  • Verifying supporting laboratory documentation
  • Monitoring packaging specifications for changes
  • Tracking recycled-content percentages by SKU and supplier

4. Reuse and Refill

PPWR encourages increased use of reusable and refillable packaging systems where appropriate. Importers should assess whether overseas suppliers can support reuse-compatible formats as retailer and regulatory expectations evolve.

5. Substance Restrictions

Packaging materials should comply with applicable restrictions relating to substances of concern. Importers should maintain visibility, through supplier declarations, into:

  • Material composition
  • Additives
  • Heavy metals
  • Adhesives
  • Printing inks
  • Coatings
  • Chemical declarations
  • Supplier compliance statements

Early and structured supplier engagement improves transparency while reducing the risk of goods being detained at the border pending further documentation.

6. Packaging Labelling

PPWR introduces harmonized packaging labelling intended to improve recycling and waste sorting across the European Union. Importers should review supplier artwork approval processes and ensure imported packaging carries compliant labelling before shipment, including material identification, recycling instructions, and recycled-content information where applicable.

Read our complete guide to PPWR Requirements.

Responsibilities of FMCG Importers Under PPWR

Although overseas manufacturers produce packaging components, FMCG importers remain directly responsible for ensuring packaging complies before it is placed on the Italian and EU market for the first time.

Compliance requires collaboration across multiple business functions, including:

  • Procurement and Sourcing
  • Customs and Trade Compliance
  • Regulatory Affairs
  • Quality Assurance
  • Supply Chain and Logistics
  • Legal
  • Sustainability
  • Retailer and Customer Relations

Importers managing multiple overseas suppliers, private-label ranges, and product portfolios should establish standardized supplier verification and documentation processes across the business — before goods reach an Italian port or warehouse.

Documentation Required for PPWR Compliance

Documentation provides the evidence supporting every packaging compliance decision. Importers should centralize documentation collected from overseas manufacturers to improve governance, visibility, and audit readiness.

Manufacturer-Issued Documentation to Collect

  • Declaration of Conformity (DoC)
  • Technical documentation
  • Conformity assessment records
  • Packaging specifications
  • Material composition and Bills of Materials (BOMs)
  • Packaging weights and dimensions

Supplier Documentation

  • Supplier declarations
  • Material certifications
  • Compliance statements
  • Laboratory reports
  • Recycled-content declarations

Importer-Retained Documentation

  • Records confirming verification checks performed
  • Internal compliance procedures and checklists
  • Corrective action records
  • Correspondence with the EU or Italy-based authorised representative, where applicable
  • CONAI registration confirmation and CAC declarations
  • Version-controlled compliance records

Maintaining structured documentation enables importers to respond quickly to customs authorities, retailer sustainability questionnaires, and market surveillance inspections while reducing administrative effort.

Read our complete guide to PPWR Technical Documentation.

Building a Future-Ready PPWR Compliance Strategy for FMCG Importers

As the Packaging and Packaging Waste Regulation (PPWR) reshapes packaging compliance across Europe, FMCG importers must move beyond understanding the regulation and begin embedding supplier verification into sourcing, procurement, logistics, and customs operations.

Unlike manufacturers, FMCG importers manage relationships with overseas suppliers across multiple countries, time zones, and documentation standards — spanning thousands of SKUs, private-label programs, seasonal packaging, and retailer-specific formats. This complexity makes verification significantly more challenging than for a manufacturer with in-house production.

Achieving PPWR compliance requires more than a customs checklist — it demands centralized supplier data, standardized documentation collection, structured verification workflows, and digital processes that can scale across a global supplier base.

Organizations that invest in these capabilities today will not only be better prepared for upcoming PPWR milestones but will also reduce border delays, strengthen supplier accountability, and lower long-term compliance costs.

Common PPWR Compliance Challenges for FMCG Importers

1. Verifying Manufacturers You Don’t Directly Control

Unlike manufacturers, importers cannot simply change internal processes to fix a compliance gap — they depend entirely on overseas suppliers to generate accurate conformity assessments, technical documentation, and DoCs. Chasing corrections across time zones and language barriers slows resolution.

2. Complex, Multi-Country Supplier Networks

Packaging materials and finished goods are often sourced from multiple manufacturers across different countries, each with its own documentation standards, formats, and levels of PPWR awareness. Without standardized templates, collecting consistent compliance evidence becomes increasingly resource-intensive.

3. Fragmented Supplier Documentation

Many FMCG importers still manage supplier and packaging information across:

  • Freight-forwarder records
  • Customs broker communications
  • Supplier portals and email chains
  • Individual spreadsheets
  • Shared drives

Centralizing this information is essential for maintaining a single source of truth ahead of every shipment.

4. Private-Label and Article 21 Reclassification Risk

Every private-label product sourced from an overseas supplier carries a risk of being reclassified from importer to manufacturer under Article 21, shifting full conformity assessment and DoC obligations onto the importer. Without a clear mapping of which SKUs are private-label, this risk can go unnoticed until a market surveillance inspection.

5. Border Delays and Detained Consignments

Incomplete or missing conformity documentation can result in shipments being held at customs, creating costly delays and disrupting retailer delivery commitments.

6. Growing Documentation Requirements

PPWR requires importers to retain comprehensive conformity evidence for every packaging type sourced from every supplier. Managing this manually across a large supplier base often leads to:

  • Inconsistent records
  • Missing or outdated DoCs
  • Duplicate documentation
  • Increased audit preparation time

7. Preparing for Future PPWR Requirements

Many PPWR obligations will be introduced in phases over the coming years. Importers need verification systems that can adapt to future requirements relating to:

  • Packaging minimization
  • Recycled content
  • Design for recyclability
  • Reuse targets
  • Harmonized labelling
  • Extended Producer Responsibility (EPR)

Building scalable verification processes today reduces future implementation effort as more overseas suppliers come into scope.

How Digital Traceability Supports PPWR Compliance for Importers

Managing supplier verification across a global sourcing base requires connected, accurate, and continuously updated information. Digital traceability platforms help importers centralize compliance evidence while improving collaboration with overseas manufacturers, customs partners, and internal teams.

Centralized Supplier and Packaging Data

Maintain structured information relating to:

  • Manufacturer conformity assessments and DoCs
  • Packaging specifications and material composition
  • Packaging Bills of Materials
  • Product-to-packaging-to-supplier relationships

A single source of truth eliminates duplicate records and improves data accuracy across every sourcing country.

Digital Manufacturer Onboarding and Verification

Digitally onboard overseas manufacturers and collect:

  • Declarations of Conformity
  • Technical documentation
  • Material declarations
  • Laboratory reports
  • Recycled-content evidence

Automated reminders help reduce delays and improve documentation completeness ahead of each shipment.

Technical Documentation Management

Maintain version-controlled technical files containing engineering drawings, test reports, conformity assessment records, and Declarations of Conformity received from every manufacturer — simplifying customs checks and market surveillance inspections.

Workflow Automation

Standardize pre-shipment verification through configurable workflows that include supplier document review, compliance validation, internal approvals, and document version control — reducing manual effort while improving consistency across suppliers.

Audit and Border Readiness

Respond quickly to customs authorities, retailer sustainability questionnaires, and market surveillance inspections. Centralized documentation enables faster access to compliance evidence when a shipment is queried.

Cross-Functional Collaboration

Enable procurement, customs and trade compliance, regulatory affairs, quality assurance, and logistics teams to work from the same supplier and packaging data — improving visibility while reducing duplication across departments.

Simplify PPWR Compliance with TraceX

Managing PPWR compliance across multiple overseas manufacturers, private-label programs, and packaging formats requires a digital approach. TraceX’s PPWR Solution helps FMCG importers centralize supplier verification, streamline documentation collection, automate compliance workflows, and maintain audit-ready records from a single platform.

Whether you import packaged foods, beverages, household products, home care products, pet food, or other consumer goods, TraceX simplifies PPWR compliance across your entire supplier network.

With TraceX, FMCG Importers Can:

  • Centralize manufacturer DoCs and technical documentation across all suppliers
  • Track packaging specifications and material composition by SKU and origin country
  • Digitize overseas manufacturer onboarding and documentation collection
  • Maintain version-controlled compliance records for every shipment
  • Automate pre-shipment conformity verification workflows
  • Flag private-label SKUs at risk of Article 21 reclassification
  • Track CONAI registration status and CAC declaration cycles alongside PPWR conformity records
  • Track recycled-content declarations and supplier evidence
  • Monitor packaging or supplier changes through structured workflows
  • Improve collaboration across procurement, customs, regulatory affairs, and quality teams
  • Respond quickly to customs queries, retailer requests, and market surveillance inspections

Instead of managing verification through disconnected spreadsheets and email, TraceX provides a scalable digital platform that supports continuous PPWR compliance for importers.

Conclusion

The Packaging and Packaging Waste Regulation represents one of the most significant changes to packaging compliance in recent years — and for FMCG importers, it shifts real legal responsibility onto the business bringing goods into the EU, even when packaging design decisions were made entirely overseas.

For FMCG importers bringing products into Germany, compliance is no longer a matter of trusting supplier assurances — it requires rigorous verification, centralized documentation, and digital processes capable of proving conformity for every shipment.

Organizations that begin preparing now can reduce customs delays, strengthen supplier accountability, improve packaging transparency, and respond more effectively to retailer and regulatory requirements.

As the 12 August 2026 implementation milestone approaches, importers should focus on verifying manufacturer documentation, mapping private-label reclassification risk, and digitizing supplier verification workflows.

Those that adopt a proactive, digital-first approach will be well positioned not only for PPWR compliance but also for the broader transition toward sustainable, circular packaging across their supply chains.

Frequently Asked Questions


Does PPWR apply to FMCG importers in Italy?

Yes. Any FMCG importer placing packaged products from outside the EU onto the Italian or EU market for the first time must verify that the packaging complies with applicable PPWR requirements, register with CONAI, and retain supporting documentation.

Do importers need to issue their own Declaration of Conformity?

No. Importers do not issue their own DoC. Instead, they must verify that the non-EU manufacturer has already carried out the conformity assessment, prepared technical documentation, and issued a valid DoC before goods are placed on the market.

When does an importer become a manufacturer under PPWR?

Under Article 21, an importer that places packaging or packaged products under its own brand or trademark, or that modifies packaging in a way that may affect compliance, is reclassified as the manufacturer and takes on the full conformity assessment and documentation obligations.

Which packaging is covered under PPWR?

PPWR applies to primary, secondary, and transport packaging across materials including plastic, paper, cardboard, glass, metal, flexible films, and composite packaging — regardless of where the packaging was manufactured.

What documentation should FMCG importers maintain?

Importers should maintain manufacturer-issued Declarations of Conformity, technical documentation, conformity assessment records, packaging specifications, Bills of Materials, supplier declarations, laboratory reports, recycled-content evidence, and records of their own verification checks.

Does PPWR replace Italy’s CONAI system?

No. PPWR layers new EU-wide conformity obligations on top of Italy’s existing CONAI framework. Importers must continue registering with CONAI and paying the Contributo Ambientale (CAC) while also meeting PPWR’s conformity assessment, DoC, and documentation requirements. Italy’s national labelling format and the new harmonized EU symbols may be used together until 11 August 2028.

How can TraceX help with PPWR compliance for importers?

TraceX provides a centralized digital platform that streamlines overseas manufacturer verification, documentation collection, technical documentation management, conformity checks, and audit readiness — helping FMCG importers build scalable, continuous PPWR compliance processes.

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