Checks before placing packaging on the market
Article 18 requires importers to ensure that the manufacturer carried out the conformity assessment and drew up the required technical documentation. The importer also checks required labelling, accompanying documents and the manufacturer’s identification information.
- Actual manufacturer identity and contact information
- Packaging identity that matches the supplied documents
- Manufacturer EU Declaration of Conformity
- Confirmation that the Annex VII file can be made available
- Required labelling and accompanying documentation
- Importer identification and contact information
When documents are missing or inconsistent
Request the actual manufacturer documents and record the mismatch. Do not create a Declaration in the importer’s name merely to fill the gap. If there is reason to believe the packaging is not compliant, resolve the issue before placing it on the market.
PPWR Docs prepares an Importer Verification Record, shows missing checks and creates a specific manufacturer request. It can connect later evidence without hiding the period when the issue was unresolved.
When the importer route can change
An importer that uses its own name or trade mark on the packaging, or modifies packaging in a way that could affect compliance, can be treated as the manufacturer under Article 21, subject to the specific micro-enterprise rule.
National packaging-registration and EPR responsibility is a separate assessment. The company can need a country registration action even when it does not own the manufacturer Declaration.
The final route depends on the complete supply and branding facts. Use specialist review for unusual agency, marketplace or micro-enterprise structures.