The PPWR, the EU regulation on packaging and packaging waste, applies from 12 August 2026. If you import packaged goods from China and sell them in Poland, you are an importer and a producer within the meaning of the PPWR. An importer's obligations come down to three things: your details on the packaging, documents from the factory and registration in BDO.
What is the PPWR and when does it apply?
The PPWR (Packaging and Packaging Waste Regulation) is Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste. It applies directly in all EU member states from 12 August 2026 (Art. 71). It replaced Directive 94/62/EC.
Some requirements come later. Harmonised labels showing the material composition of packaging apply from 12 August 2028 or 24 months after the Commission's implementing acts, whichever is later (Art. 12(1)).
Are you an importer under the PPWR?
Yes, if you are established in the EU and place packaging from a third country on the market. Placing on the market means making packaging available on the EU market for the first time, empty or with a product inside (Art. 3(10) and (17) PPWR). Goods from China in a carton are therefore also an import of packaging.
The same importer is usually also a producer for extended producer responsibility purposes, because they are the first to make packaged products available in Poland (Art. 3(15)(b)). EPR (extended producer responsibility, ROP in Polish) means the producer finances the collection and treatment of waste from the packaging it places on the market (Art. 45).
If the goods carry your brand, the PPWR also treats you as the manufacturer of the packaging (Art. 3(13)(a)). Private label from China therefore brings manufacturer obligations: conformity assessment, technical documentation and an EU declaration of conformity. This applies to any packaged goods, from furniture such as coffee tables to small accessories.
What must an importer do before selling?
Before placing goods on the market, the importer checks that the manufacturer has carried out the conformity assessment of the packaging and drawn up the technical documentation. The importer gives its name and address on the packaging or in an accompanying document, and keeps a copy of the EU declaration of conformity for 5 years, or 10 years for reusable packaging (Art. 18 PPWR).
Checklist based on Art. 18 and Art. 5:
- The packaging meets the requirements of Art. 5–12. The combined concentration of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg (Art. 5(4)).
- The manufacturer has carried out the conformity assessment procedure and drawn up the technical documentation (Art. 18(2)(a)).
- The packaging bears a type, batch or serial number and the manufacturer's details (Art. 18(2)(d) in conjunction with Art. 15(5) and (6)).
- Your name, registered trade name or trade mark and postal address are on the packaging or, where that is not possible, in a QR code or an accompanying document (Art. 18(3)).
- A copy of the EU declaration of conformity is available to the authorities for 5 years for single-use packaging and 10 years for reusable packaging (Art. 18(7)). If an authority asks, you hand over the documents within 10 days (Art. 18(8)).
- From 12 August 2026, food-contact packaging may not contain PFAS above the limits in Art. 5(5).
So you order the packaging documents from the factory together with the goods, not after customs clearance. Our team in China can request them as early as the negotiation stage. That is how import from China works with us: we oversee production and quality on site.
How does BDO connect with the PPWR?
BDO (the Database on Products, Packaging and Waste Management) is the Polish register in which businesses placing packaged products on the market must be entered. You apply before starting the activity. Operating without the required entry carries an administrative fine of PLN 1,000 to PLN 1,000,000 (BDO).
The entry gives you a registration number, which you show on invoices and contracts, among other documents (BDO). The registration fee and the annual fee are PLN 200 for a micro-enterprise and PLN 800 for other companies; the annual fee is due by the end of February (BDO).
The PPWR requires producers to register in a national register of producers and prohibits making packaged products available without registration (Art. 44(2) and (4)). Member states must set up these registers within 18 months of the Commission's first implementing act (Art. 44(1)).
In Poland, EPR entries under the PPWR are already going into BDO. In September 2026, the Marshal of the Mazowieckie Voivodeship entered authorised representatives for EPR there on the basis of Art. 45(3) PPWR.
What does Allegro require?
Allegro asks producers within the meaning of the PPWR for an EPR number for each country they ship to; for Poland, that is the BDO number. On top of that comes a declaration that the packaging complies with EU requirements, submitted in the Account details (Dane konta) tab. For now, a missing number does not block sales (Allegro).
Allegro counts as producers, among others, companies that import packaged products and are the first to sell them in the country, and sellers of goods under their own brand. You enter the number as the PPWR number (EPR PPWR / BDO).
Allegro has announced that once EU countries adapt their registers to the PPWR, it will check the EPR number for each country before allowing sales. The legal basis is Art. 45(4) PPWR in conjunction with the Digital Services Act (DSA). The platform must obtain the producer's registration number and a declaration that the EPR requirements are met.
On its EPR page, Allegro describes the BDO number as mandatory but notes that it is not obliged to verify it.
What to do before your first sale?
Check your status, apply for a BDO entry, order the packaging documents from the factory and add your details to the packaging. On Allegro, enter your BDO number in the account details. You do each step once, before the first delivery.
We have collected an importer's packaging and product safety obligations on our page PPWR, BDO and GPSR when importing from China.
Legal status checked: September 2026.