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Who is Responsible for PPWR Compliance: Exporter or Importer
This is the question most companies get wrong. The answer depends on who is the "producer" under PPWR.
Under PPWR, the "producer" is the company that places the packaged product on the EU market for the first time. This can be a manufacturer, distributor, or importer, depending on the business model.
If you are a Romanian exporter who manufactures products and sells directly to retailers in France, Germany, or Poland, you are the producer. PPWR compliance is your responsibility.
If you are a Romanian importer who buys finished goods from outside the EU and imports them into Romania to sell, you are the producer (because you are placing them on the EU market for the first time). PPWR compliance is your responsibility.
If you are a Romanian trader who buys products already packaged and placed on the EU market by another producer, then resells them, you are not the producer. PPWR compliance was already handled upstream.
The key: whoever puts the product on the EU market first is responsible for PPWR compliance.
This matters because it determines who pays for redesign, testing, EPR registration, and penalties if something goes wrong.
Romania-Specific PPWR Rules
Romania follows EU-wide PPWR rules but has a few specifics to know.
EPR scheme. Romania's EPR scheme is managed by designated producers' organisations (OP) that collect fees and manage packaging recovery. As a producer, you must register with an OP in Romania. The fee depends on packaging weight and material type. For food companies, expect 5,000 to 15,000 EUR annually. For e-commerce and other sectors, expect 2,000 to 10,000 EUR.
Competent authority. Romania's competent authority for packaging is the Ministry of Environment. If you need an exemption or want to report a compliance issue, contact them. They enforce PPWR through border controls and retailer audits.
Language requirements. Packaging sold in Romania must have Romanian language instructions for disposal and reuse. This applies even if the product is imported. If you import a product with only English or French disposal instructions, you must add Romanian labels or update packaging before sale.
DRS scheme. Romania does not yet have a mandatory Deposit Return System. However, if you sell beverages in countries with DRS (Germany, Denmark, Sweden, Finland, etc.), your bottles must be compatible. This means standard sizes and closures. If you export to these countries, design accordingly.
Export Compliance: Romanian Companies Selling to EU
If you are a Romanian manufacturer or distributor exporting to other EU countries, your PPWR obligations are:
Register as a producer in each country where you sell. In Germany, this means registering with the ZSVR database. In France, with ADEME. In Poland, with appropriate OP. Registration costs 500 to 3,000 EUR per country and requires proof of your company registration and packaging data.
Comply with national language requirements in each market. If you sell in France, packaging must have French disposal instructions. In Poland, Polish. This often means redesigning labels or adding supplementary labels for each market. Cost: 2,000 to 10,000 EUR per country.
Pay EPR fees in each country. You cannot register once and pay globally. Each EU country has its own EPR scheme with different fees. A Romanian exporter selling in five countries pays EPR in five countries. Total annual EPR cost: 15,000 to 50,000 EUR depending on volume and markets.
Comply with any DRS requirements. If you export beverages to Germany, your bottles must be compatible with the German DRS. If you export to Sweden, they must work in the Swedish system. Incompatible bottles mean your products cannot be sold or face fines. Redesign cost: 20,000 to 100,000 EUR per bottle format.
Maintain compliance documentation. Keep records of packaging design, material composition, testing results, and EPR registrations for at least five years. Audits can happen at any time and failure to produce documentation means penalties.
Import Compliance: Companies Importing into Romania from Outside EU
If you import packaged products into Romania from Asia, Africa, or other non-EU regions, you become the producer under PPWR. This means:
Assess whether current packaging complies with PPWR. Most products manufactured for non-EU markets do not comply with PPWR requirements (materials, recyclability, language, etc.). You likely need to redesign packaging before import.
Redesign for PPWR compliance. This is your cost and timeline. Manufacturers outside the EU often refuse to change packaging for a single market. You may need to absorb the redesign cost, negotiate a split cost with the manufacturer, or find alternative suppliers.
Register with Romania's EPR scheme. File your packaging data and pay registration fees. Cost: 500 to 3,000 EUR one-time, plus annual fees based on weight.
Add Romanian language instructions. Even if the original manufacturer provided disposal instructions, they are likely not in Romanian. You must add or replace them before selling in Romania.
Test and validate packaging. If packaging is non-standard or materials are unclear, conduct testing to prove compliance before import. This prevents the product from being held at customs.
Maintain documentation. Keep proof that you assessed PPWR compliance, made any required changes, and registered with EPR. Retailers and regulators will ask for this.
Cross-Border Logistics: What You Need to Know
PPWR compliance is checked at multiple points during import and export.
At the border. EU customs can inspect packaging to verify PPWR compliance. Non-compliant packaging means product holds, inspections, and potential rejection. If an importer discovers non-compliance, the product is seized until compliance is proven.
At the retailer. Retailers (Carrefour, Leclerc, Lidl, E-commerce platforms) conduct PPWR audits on suppliers. Non-compliant suppliers lose shelf space. For exporters, this means losing major distribution channels.
At the consumer. If a consumer or authority discovers non-compliant packaging, the entire shipment can be recalled. This is expensive and damages reputation.
Logistics partners (customs brokers, freight forwarders) cannot help you with PPWR compliance. They can tell you packaging was flagged at customs, but they cannot clear compliance issues. You must resolve them directly.
Special Situation: Exporting from Romania to Vietnam or Beyond
If you are a Romanian exporter also selling outside the EU (Vietnam, Thailand, India, etc.), PPWR applies only to products sold in the EU. Products sold in Vietnam do not need to comply with PPWR.
This creates a dual-packaging situation. You may need two packaging designs: one compliant with PPWR for EU sales, one designed for non-EU markets.
Or you can use one packaging that meets both PPWR and non-EU standards. This is more expensive but simpler operationally.
Either way, clearly label or segregate packaging by destination market. Mixing EU-compliant and non-EU packaging shipments creates customs confusion and delays.
Timeline and Action Plan for Exporters and Importers
For exporters selling to EU markets:
April to June 2024: Audit current packaging and identify which products need redesign. Determine compliance status in each market where you sell.
July to December 2024: Complete redesigns and conduct testing. Apply for EPR registration in each country. Arrange supplementary labels for language requirements.
January to July 2025: Begin production of compliant packaging. Test with retail partners. Train your team and logistics partners on new packaging.
August 2025 onwards: Complete transition to compliant packaging. Verify all shipments to EU meet PPWR requirements before leaving Romania.
For importers bringing products into Romania:
April to August 2024: Audit supplier packaging. Assess PPWR compliance. Initiate redesign discussions with manufacturers.
September 2024 to February 2025: Receive redesigned packaging samples. Conduct compliance testing. Register with EPR and obtain documentation.
March to June 2025: Source compliant packaging. Prepare for import. File all documentation with customs.
July 2025 onwards: Begin importing compliant packaging only. Verify before customs clearance.
Cost Impact for Exporters and Importers
Exporters face costs proportional to the number of markets and product complexity.
Single market export (say Germany only):
Redesign: 20,000 to 100,000 EUR.
EPR registration and initial fees: 5,000 to 15,000 EUR.
Testing and compliance documentation: 10,000 to 30,000 EUR.
Ongoing annual cost (EPR, language updates, audits): 10,000 to 20,000 EUR.
Total Year 1: 45,000 to 165,000 EUR.
Multi-market export (five EU countries):
Redesign: 50,000 to 150,000 EUR (economies of scale, but more complex).
EPR registration and fees across all countries: 15,000 to 50,000 EUR.
Testing and documentation: 20,000 to 50,000 EUR.
Ongoing annual costs: 30,000 to 75,000 EUR.
Total Year 1: 115,000 to 325,000 EUR.
Importers face similar costs:
Assessment and redesign with suppliers: 20,000 to 80,000 EUR.
EPR registration in Romania: 2,000 to 5,000 EUR.
Testing and documentation: 10,000 to 30,000 EUR.
Ongoing annual: 5,000 to 15,000 EUR.
Total Year 1: 37,000 to 130,000 EUR.
These are significant costs but manageable if you start now. Wait until 2026 and costs triple due to last-minute redesigns and expedited shipping.