PPWR reaches packaging placed on the EU market whatever its origin, so any exporter outside the EU, Indian companies included, is affected, but which duties land depends on the selling route. Article 2 applies the Regulation to all packaging regardless of material. When the EU buyer resells the goods, the EU importer carries the producer duties. When the Indian company sells directly to end users, including EU businesses that use the goods themselves, it becomes the producer there.
Article 2(1) provides that the Regulation applies to all packaging, regardless of the material used, and to all packaging waste, whether it arises in industry, other manufacturing, retail or distribution, offices, services or households. Nothing in it turns on where the packaging was produced.
The selling route decides the role
| Route into the EU | Producer under Article 3(1), point (15) | What the Indian company carries |
|---|---|---|
| Sale to an EU importer or distributor that resells | The EU operator that first makes it available on a Member State territory | Manufacturer duties under Article 15, which the importer checks under Article 18(2) |
| Sale direct to end users in a Member State, including businesses that use the goods | The third-country seller itself, under points (c) and (d) | Producer duties, including extended producer responsibility registration and, where the Member State requires it, an authorised representative under Article 45(3) |
| Packaging designed under an EU customer’s brand | The EU operator that first sells it in each Member State; the brand owner is the manufacturer under Article 3(1), point (13)(a) | Supplier duties, plus whatever the contract adds |
Points (c) and (d) of Article 3(1), point (15), settle this. A manufacturer, importer or distributor “established in a Member State or in a third country” that first makes packaging or packaged products available directly to end users in another Member State is the producer. Distance selling is named in the opening words, so a direct-to-consumer webshop is covered.
What that means in practice
An Indian company selling to EU buyers that resell does not register in EU producer registers. It supplies the evidence the importer must check under Article 18(2), and a gap there stops the importer placing the goods on the market. An Indian company selling directly to end users, including businesses that use the goods, is the producer and takes on registration and reporting, with an authorised representative where the Member State requires one.
Indian plastic waste and extended producer responsibility obligations run separately. Meeting them does not satisfy the PPWR, which applies on top of them.
Sources: Regulation (EU) 2025/40, PPWR Frequently Asked Questions, second edition
GreenSutra’s EU PPWR solutions work starts by establishing which of these three routes a business uses. The PPWR compliance guide sets out the role definitions.