MF confirms PPWR checks upon import: documentation must be available upon request.
In an official position (letter dated 24 August 2026, ref. no. DC5.8870.1169.2026), the Ministry of Finance confirms that customs authorities may request importers to provide documentation required under the PPWR. Although such documents do not need to be routinely attached to the customs declaration, failure to provide them during an inspection may affect whether the goods can be released for free circulation.
The Ministry of Finance (MF) emphasizes that the PPWR does not require technical documentation or an EU Declaration of Conformity to be attached to every import customs declaration. Nor does it introduce new customs document codes.
This does not mean, however, that importers can operate without the required documentation. Under Articles 15 and 46 of the Union Customs Code, customs authorities may request information necessary to determine whether an imported product and its packaging comply with EU requirements and may lawfully be placed on the market.
We highlighted the risk of customs inspections following the start of the PPWR’s application earlier. In our article published on Prawo.pl, “PPWR from August 2026: How to prepare for inspections?”, we pointed out that businesses should be prepared for verification of packaging compliance and the related documentation. The MF’s position therefore confirms our earlier assumptions regarding the inspection powers of customs authorities.
Particular importance should be attached to requirements concerning substances present in packaging. The PPWR Regulation, applicable from 12 August 2026, sets, among other things, limits on PFAS in food-contact packaging. For all packaging, the total concentration of lead, cadmium, mercury and hexavalent chromium is subject to a limit of 100 mg/kg. Compliance with these requirements should be demonstrated through technical documentation.
Customs authorities do not thereby become market surveillance authorities within the meaning of the PPWR. They may, however, inspect goods and apply prohibitions and restrictions when releasing them for free circulation. If the required documentation is not provided or indicates that the packaging is non-compliant, the release of the goods may be withheld.
For importers, this means ensuring access to packaging-related documentation – including where packaging is merely a component of the imported product. It is worth verifying whether suppliers provide the relevant declarations and test results and whether these documents can be promptly produced in the event of a customs inspection.
If you have any questions regarding the PPWR, packaging technical documentation, or the impact of the new requirements on import processes, please do not hesitate to contact us.
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