PPWR Indian exporters carry no direct producer duty for business-to-business sales, since Regulation (EU) 2025/40 places national registration, extended producer responsibility and labelling on the EU importer; their task is supplying compliant packaging plus conformity data, including substance-limit checks and the technical file, from 12 August 2026.
Where the compliance duty sits
Under Regulation (EU) 2025/40, obligations attach to the producer: a manufacturer, importer or distributor established in a Member State that first makes packaging available there, or one selling directly to end users in another Member State (Article 3). For a business-to-business sale from an Indian supplier to an EU importer, the EU importer is the producer and carries national producer-register entry and extended producer responsibility (Articles 44 and 45). Extended producer responsibility does not fall directly on the Indian exporter for such sales. Mapping the producer line early keeps the correct party accountable.
What Indian exporters must supply
The practical task is supplying the packaging data and conformity evidence the importer relies on, ready before the Regulation applies from 12 August 2026. Core deliverables:
- A packaging inventory by material and weight.
- Substance-limit checks: PFAS in food-contact packaging at 25 ppb single, 250 ppb sum and 50 ppm total fluorine; heavy metals (lead plus cadmium plus mercury plus hexavalent chromium) not exceeding 100 mg/kg from 12 August 2026.
- Recyclability grading against the A, B or C scale, with grades set by delegated acts not yet adopted.
- Recycled-content data per plastic part.
- Readiness for the harmonised material-composition label, mandatory from 12 August 2028.
- The conformity file (internal production control, Annex VII, Article 38) with the EU Declaration of Conformity (Annex VIII, Article 39).
Under the internal-production-control route the manufacturer self-declares; any independent conformity or laboratory testing sits with accredited third parties.
PPWR sits on top of India’s Plastic Waste Management Rules
Indian extended producer responsibility does not satisfy PPWR. The Plastic Waste Management Rules and the Central Pollution Control Board regime are separate, and PPWR applies in addition to, not in place of, Indian obligations.
| Aspect | PPWR (EU 2025/40) | India Plastic Waste Management Rules |
|---|---|---|
| Jurisdiction | EU market | India |
| Duty holder for B2B export | EU importer as producer | Indian producer, importer, brand owner |
| Exporter role | Supply compliant packaging and conformity data | Register under CPCB EPR |
| Applies from | 12 August 2026 | Already in force |
GreenSutra’s consultants often see exporters assume an Indian EPR registration transfers to Europe, when the two tracks must run side by side. A short PPWR discovery brief maps the packaging and the producer line.
Sources: Regulation (EU) 2025/40 · European Commission, Packaging waste