PPWR for Suppliers Outside the EU: What Manufacturers in Bosnia and Herzegovina, Serbia and Croatia Should Know

For manufacturers in Bosnia and Herzegovina or Serbia, the PPWR does not apply as national law, but it becomes relevant as soon as packaging or packaged goods reach the EU market. The obligations lie with the company that places the packaging on the market in the EU, and that company asks its suppliers for the information it needs. In Croatia, as an EU Member State, Regulation (EU) 2025/40 applies directly.

Why the Packaging Regulation also affects suppliers outside the EU

The PPWR has applied directly in all Member States since 12 August 2026. It is not tied to where a company is based, but to the placing of packaging on the EU market. A manufacturer from Brčko, Tuzla or Novi Sad that delivers palletized goods to a customer in Germany packs those goods with cartons, stretch film, strapping and pallets. This packaging is placed on the market in the EU, and someone has to meet the requirements for it.

In practice, this is often the EU customer in its role as importer or manufacturer. For its technical documentation and declaration of conformity, however, it needs data that only the supplier knows: materials, substances, weights, dimensions and origin of the packaging components.

The roles: manufacturer, importer, distributor

The PPWR allocates obligations to different economic operators:

• Manufacturers of packaging or packaged products
• Importers, who bring packaging or packaged products from third countries into the EU
• Distributors, who pass them on within the EU

Which role a company has depends on the specific supply model and the contracts. This should be settled in writing for every supply relationship, because it determines who carries out the conformity assessment, who issues the EU declaration of conformity and who registers for extended producer responsibility.

What information EU customers ask for

Since the start of application, packaging placed on the market must have technical documentation and an EU declaration of conformity. EU customers therefore pass their information requests on along the supply chain. Typical requests concern:

• Material data: type and weight of carton, film, strapping, pallets and filling material
• Substances: information on the substance restrictions under Art. 5
• Supplier declarations: declarations from material and packaging suppliers
• Technical documentation: specifications, drawings, packing schemes
• Preparing for 2030: recycled content in plastic parts (Art. 7), recyclability (Art. 6), empty space (Art. 24) and reusability of transport packaging (Art. 29)

A structured material review and documentation means this data does not have to be searched for again with every request.

A supplier declaration is not a declaration of conformity

A common misunderstanding: the declaration of a film supplier or carton manufacturer relates to that particular material. It is not automatically a complete declaration of conformity for every assembled package, such as a load unit consisting of a pallet, cartons, edge protectors, stretch film and strapping. Whoever is responsible for the packaging as a whole must bring the individual details together and assess them.

Croatia: the regulation applies directly

Croatia is an EU Member State. For companies there, the PPWR has applied directly since 12 August 2026, without a national implementing act. A company in Croatia that makes packaging, places packaged products on the market or imports them from Bosnia and Herzegovina or Serbia may itself be a manufacturer or importer within the meaning of the regulation. Croatian companies are therefore often the link in the chain: they have obligations of their own and at the same time ask suppliers outside the EU for information.

As for all Member States, Croatia must lay down rules on penalties and notify them to the Commission by 12 February 2027 (Art. 68).

What to clarify with your EU customers

Before you compile documents, a clarifying conversation is worthwhile. Important questions are:

• Which role does the customer take on, and which does it expect from you?
• Which packaging components are affected: only the sales packaging, or also transport packaging, pallets and load securing?
• In what format and language should the information be supplied?
• Is the transport packaging handled in the customer’s reuse system? The reuse quotas under Art. 29 concern economic operators who use the packaging within the EU. How they affect a supplier outside the EU depends on roles and contracts.
• Which information does the customer need now, and which only with a view to 2030?

For discussions with German-speaking partners, our international business communication service helps ensure that technical documents arrive clearly and completely.

First steps: a practical checklist

1. Inventory: record all packaging components for each product and load unit.
2. Ask your suppliers: obtain current declarations on materials and substances.
3. Clarify roles: record with each EU customer who takes on which obligations.
4. Organize documents: keep specifications, weights and declarations in one central, traceable place.
5. Mark gaps: make missing information visible and name those responsible.
6. Plan for the deadlines: keep the dates up to 2030 in view, see the guide PPWR deadlines 2025 to 2040.

Well prepared for conversations with EU customers

Suppliers who can present their packaging data in an orderly way make life easier for their customers and build trust. Our PPWR and EU compliance service helps you interpret your customers’ requirements and close gaps in a targeted way. If you want to know where you stand today, request an initial assessment.