PPWR Applies Now: What Commercial Refrigerator Importers Should Do Next

A Real Packaging Documentation Request From a European Distributor

On 12 August 2026, the EU's Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, became fully applicable across all 27 member states. We know what that means in practice, because it has already reached our inbox: an Italian distributor recently sent us a formal request for technical documentation on every packaging component we use for the commercial refrigerators we ship to them: cardboard, foam, film, strapping, plywood base and all.

Similar documentation requests are increasingly appearing in EU supply chains as importers prepare for PPWR requirements. This article is not a legal summary of the regulation. It is a working to-do list: what to request, how to judge whether a supplier's answer is trustworthy, and which deadlines actually matter to you.

PPWR in 60 Seconds

The PPWR replaces the old Packaging Directive 94/62/EC. Because it is a regulation rather than a directive, it applies directly and uniformly in every EU member state, with no national transposition and no waiting period. It covers all packaging placed on the EU market, regardless of material or sector, and explicitly includes transport and grouped packaging in B2B trade. That means the plywood base and strapping around a 150 kg single-door upright commercial refrigerator are in scope just as much as the cardboard box around a spare shelf.

That's the summary. What matters is who carries the obligation.

Who Is Responsible: You or Your Supplier?

This is the single most important point in the regulation for importers. Under the PPWR, the party that first makes packaged goods available on the EU market is the "producer". For goods manufactured outside the EU, that producer is you, the importer. Extended producer responsibility (EPR) registration, eco-modulated fees, and reporting duties sit with you, and they cannot be contractually shifted to a Chinese manufacturer.

Your supplier's role is different but essential: they are your source of data and documentation.

A supplier who understands this division is already halfway to being useful to you.

Anatomy of a Packaging Documentation Request

The request letter we received is a good template, as it asked for exactly what the regulation's conformity logic requires. If you are drafting your own request to suppliers, it should cover three blocks:

1. Technical information per packaging component. For each item (cardboard box, protective film, EPS inserts, wooden pallet, plastic strapping), request:

• Material description and material designation
• Packaging weight
• Packaging manufacturer (name and address)
• Identification code or product reference, where available
• Percentage of recycled content, where applicable

2. Compliance-supporting documentation. Declaration of Conformity with Regulation (EU) 2025/40 or, where not yet available, a statement describing the current status of compliance; technical data sheets; recyclability information; evidence of compliance with restricted-substance requirements (heavy metals, SVHC); and any test reports or certificates supporting the above.

3. The honesty clause. This is the part we consider best practice: if any document is not yet available, the supplier should state which documents are missing, why, and the expected date they will become available. In August 2026, with the regulation barely applicable and testing capacity backlogged across the industry, a complete-and-perfect file from any supplier should raise more questions than it answers. A transparent status statement is worth more than an overclaim.

One detail that is easy to miss: the request should also cover spare parts packaging, not just the finished units. Shelves, drawer kits, guide rails and caster sets shipped as spares are packaged goods too.

Commercial Refrigerator Packaging, Component by Component

Commercial kitchen refrigeration travels in a fairly standard export packaging stack. Here is what to look at for each component, based on the typical combination used for upright cabinets, counters, saladettes and prep tables:

Corrugated cardboard cartons. Cardboard boxes are exempt from the 2030 transport-packaging reuse targets, but they are not exempt from everything else: from 2030, grouped and transport packaging must keep empty space below 50%, and recycled content and recyclability data will still be requested. Ask for: board grade, weight per unit, recycled content %, and the manufacturer's details.

EPS foam boards and protective film. This is the component under the most long-term pressure. Expanded polystyrene (EPS), used in export packaging both as rigid impact-protection boards and as thin protective foam film around cabinet surfaces, is technically recyclable but poorly collected in practice. From 2030, all packaging must meet recyclability performance grades: packaging below 70% recyclability (below grade C) cannot be placed on the market. Ask for: current recyclability status and whether the packaging maker has a substitution roadmap. Nobody has fully solved protective foam for a 150 kg cabinet yet; what you want is a supplier who is working on it rather than one who hasn't noticed the question.

LLDPE stretch film. Stretch film used as pallet wrap received an exemption from the reuse targets via a Commission delegated decision in early 2026 (together with plastic strapping), on the grounds that mandatory reuse was impractical for load stability and hygiene. The recyclability and recycled-content obligations still apply. Ask for: material designation (LLDPE), weight per unit, and recycled content.

PP plastic strapping. Same exemption as stretch film. Ask for: material confirmation (PP), weight per unit, and manufacturer reference.

Fumigation-free plywood base and protective top board. Plywood bases are standard for commercial refrigerators because they avoid ISPM-15 heat treatment requirements. Under the PPWR, note two things: first, wood packaging is fully in scope for documentation; second, Article 29(4) exempts packaging custom-designed for large-scale machinery and equipment from the reuse targets, a provision worth discussing with your compliance adviser for heavy equipment crating. Ask for: material confirmation, weight, and whether the base is a one-way or returnable design.

The PPWR Timeline That Matters to You

The August 2026 column is the one that is already live, and it is documentation-heavy rather than hardware-heavy.

What a Trustworthy Supplier Response Looks Like Right Now

So what should you expect back from a commercial refrigerator manufacturer this month? Not a golden file. A credible response in August 2026 looks like this:

1. A completed component information sheet: every packaging item, with material designation, weight, manufacturer and reference codes, in a structured table you can file directly into your technical documentation.
2. A status-of-compliance statement covering restricted substances: what has been verified, what is being tested, and with whom.
3. A dated plan for the documents still in progress, for example heavy-metals and SVHC test reports currently with the packaging suppliers' laboratories.

And three answers that should worry you:

• "You don't need any documents for B2B packaging." Wrong. B2B and transport packaging are explicitly in scope.
• "Our CE certificate covers the packaging." It does not. CE marking applies to the appliance; the packaging requires its own conformity assessment and DoC under the PPWR.
• No testing plan at all. The regulation has been published since January 2025. A supplier should at least be able to explain their current compliance status and documentation plan.

Our own position, for the record: CORESUN provides a component-level packaging information sheet for the products we ship (cardboard, foam boards and protective film, strapping, plywood base pallet and protective board), and restricted-substance testing with our packaging suppliers is currently in progress. We state this plainly because that is what the regulation, and frankly good trading practice, asks of all of us right now. When the test reports land, they go into the same documentation pack.

FAQ

Does the PPWR apply to B2B transport packaging? 

Yes. The regulation covers all packaging placed on the EU market, explicitly including transport and grouped packaging in business-to-business trade.

Who is the "producer", the Chinese manufacturer or the EU importer? 

For goods manufactured outside the EU, the importer who first makes the packaged products available on the EU market is the producer, and carries the EPR registration, fee and reporting obligations. These cannot be transferred to the non-EU supplier.

Is plywood or wooden pallet packaging covered by the PPWR? 

Yes, wood packaging is fully in scope for documentation, substances and recyclability requirements. However, packaging custom-designed for large-scale machinery and equipment is exempt from the transport-packaging reuse targets under Article 29(4). Confirm the applicability to your shipments with a compliance adviser.

What happens if documentation isn't complete by 12 August 2026? 

The conformity obligations apply from that date, so gaps should be closed as quickly as possible. In practice, regulators and market surveillance will look for a credible conformity process. A documented status statement, an active testing plan and dated commitments from suppliers are the responsible interim position: not silence, and not fabricated paperwork.

Are cardboard boxes and plastic strapping exempt from reuse targets? 

Cardboard boxes are exempt from the 2030 transport-packaging reuse targets, and pallet wrap plus strapping received an exemption through a 2026 Commission delegated decision. All remain subject to the other PPWR requirements: substances, documentation, recyclability and, from 2030, empty-space and recycled-content rules.

Do goods shipped before 12 August 2026 need to be recalled? 

No. For imported goods, "placing on the market" happens at release for free circulation in EU customs, not at the shipping date. Goods customs-cleared before 12 August 2026 remain on the market under the previous rules. Goods cleared after that date should be covered by PPWR conformity documentation. In practice, enforcement follows a sequence: authorities must first give the operator a corrective window before any withdrawal or recall. A documented compliance status and an active testing plan are the right response, not panic.

Importing commercial refrigerators and preparing your PPWR technical documentation? Request our component-level packaging information sheet for the models you buy, and ask us anything about how our export packaging is documented.

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