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Regulation explainer

Packaging Waste Rules in the EU: Does Your Shipment Need to Comply?

small importers and resellers shipping to European Union. Drafted with AI assistance from the regulation dataset and approved by a person before publication; see the editorial policy.

Guide

Every box, bag, pallet wrap, and bottle you ship into the European Union counts as packaging — and packaging is regulated. The rule behind this is EU Directive 94/62/EC, and it applies far more broadly than most small importers expect.

What EU Directive 94/62/EC Actually Covers

EU Directive 94/62/EC governs packaging and packaging waste across the European Union. It is not limited to one product category. It applies to any packaging placed on the EU market, regardless of what is inside it — so it can apply to your shipment even if the product itself is covered by a completely different regulation.

In plain terms, if you are importing goods into the EU and those goods arrive in any kind of packaging — retail boxes, shrink wrap, cardboard inserts, plastic containers — that packaging falls under this directive.

Who Needs to Pay Attention

If you import, resell, or distribute packaged goods into the EU, EU Directive 94/62/EC applies to you, not just to manufacturers. Small importers and resellers are often the first link in the supply chain responsible for ensuring packaging meets the requirement, since they are the ones placing it on the EU market.

What the Directive Requires

There are two main elements to EU Directive 94/62/EC compliance:

**Heavy metal limits.** Packaging materials are restricted for combined levels of lead, cadmium, mercury, and hexavalent chromium (Cr6+). The limit is 100 ppm total for these four substances combined, measured across the packaging material.

**Supporting documentation.** To demonstrate compliance, you should be able to produce:

  • A heavy metals test certificate for the packaging material
  • A recyclability declaration
  • A packaging composition statement
  • These documents are typically requested from your supplier or packaging manufacturer, since they have direct knowledge of the materials used.

    What This Means for Your Shipment

    Before you ship, check whether your supplier can provide the three documents above. If they cannot, that is a signal to ask questions before the goods leave the factory, not after they arrive at an EU port.

    Packaging compliance is often overlooked because attention naturally goes to the product itself. But under EU Directive 94/62/EC, the packaging is regulated independently, and gaps here can hold up a shipment just as easily as a problem with the product inside it.

    You can review the full requirement at [EU Directive 94/62/EC](/regulations/eu-packaging-waste-94-62), and see how [supplier compliance](/supplier-compliance) documentation fits into your broader import checks.

    If you want help keeping track of which documents you need and which ones you already have, Complyra is worth a look.

    Complyra checks product and supplier information against regulatory requirements to support procurement decisions. It does not issue certifications or guarantee legal compliance; final responsibility for compliance remains with the buyer and supplier.

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