For beverages shipped from Vietnam to the European Union (EU), the Packaging and Packaging Waste Regulation (PPWR) covers packaging entering the EU market, including filled cans and bottles. This guide addresses EU market-entry packaging duties, not Vietnam's export customs procedures. The Vietnamese supplier provides packaging evidence while the EU buyer determines importer, manufacturer and country-specific producer-responsibility obligations before placing goods on sale.
Check which packaging and business roles are covered
Regulation (EU) 2025/40 applies to packaging regardless of material or origin. Assess the beverage can or bottle, closure, labels, multipack and shipment packaging separately. A glass bottle is covered even though plastic-specific recycled-content targets do not apply to its glass body.
The legal “manufacturer” may be the company marketing packaged goods under its own name or trademark, not simply the physical factory. The EU importer has separate checks under Article 18. “Producer” for extended producer responsibility (EPR) is another definition, assessed for each Member State. Contract terms should assign who supplies evidence without assuming they can override legal roles.
Apply 2026 requirements before the first EU sale
The PPWR generally applies from 12 August 2026. Article 5(5) restricts per- and polyfluoroalkyl substances (PFAS) in food-contact packaging at specified limits, including 25 parts per billion for an individual targeted PFAS, 250 parts per billion for the targeted sum, and 50 parts per million including polymeric PFAS, with measurement conditions in the law.
Request material-specific evidence rather than declaring every container “PFAS-free”. PPWR Article 5 and Commission implementation guidance explain the restriction and market-placement timing.
Under Articles 15, 18, 38 and 39, the qualifying packaging manufacturer must arrange conformity assessment, assemble Annex VII technical documentation and draw up the EU declaration of conformity when requirements are met. The importer must check conformity and required documents before placing packaging on the EU market. For direct food contact, independently assess Regulation (EC) 1935/2004 and applicable material-specific rules. A PPWR declaration alone does not replace food-contact compliance.
Put later milestones on the correct calendar
Trigger | Beverage-packaging decision |
|---|---|
12 August 2028 or later | Harmonised material-sorting labels apply from the later of that date or 24 months after relevant implementing acts take effect. Article 12 also sets exclusions, including certain transport and deposit-return packaging. |
1 January 2029 | Member States target 90% separate collection of specified single-use plastic beverage bottles and metal beverage containers up to 3 litres, using deposit-return arrangements subject to exceptions. This is not a 90% collection obligation imposed directly on each exporter. |
1 January 2030 or later | Design-for-recycling requirements depend on the Article 6 delegated acts. Do not treat 2030 as an unconditional start date for every design criterion. |
1 January 2030 or later | Article 7 provides a 30% post-consumer recycled-content target for qualifying single-use plastic beverage bottles, or three years after the relevant implementing act enters into force, whichever is later. Exceptions and calculation rules must be assessed. |
These dates are different legal triggers, not one universal “PPWR deadline”. Read Articles 6, 7, 12 and 50 alongside the Commission FAQ when specifying packaging for a future launch.
Separate EU importer conformity from national EPR
Before market placement, the EU importer should verify required manufacturer and importer identifiers, traceability and the applicable compliance documents. Under Article 18, an importer with reason to believe packaging does not conform must not place it on the market until corrected.
EPR registration, packaging reporting, fees and deposit-return participation depend on the Member State and the party qualifying as a producer under Articles 44–45 and national measures. A French launch and a German launch may require distinct registrations or operational arrangements. Check those duties with the local buyer rather than assigning them automatically to the Vietnamese factory. PPWR Articles 18, 44–45.
Assemble a decision-ready packaging file
Before confirming production artwork or the first EU shipment:
- Identify the EU destination countries, legal importer, brand owner and likely EPR producer.
- Record the bottle or can, cap, label, sleeve and secondary-packaging material specifications and weights.
- Obtain supplier declarations and relevant food-contact and PFAS evidence for the actual materials.
- Confirm who holds Annex VII technical documentation and the EU declaration of conformity.
- Check national EPR and deposit-return participation and the label rules applicable on the planned sale date.
- Keep a dated change log for packaging reformulation, market expansion and implementing-act updates.
Work with Nam Viet Group. Share your destination countries, packaging formats, volumes, artwork and buyer compliance requests. Our B2B team can coordinate product and packaging specifications for your importer's review, without offering legal certification or customs-clearance guarantees.
Scope note: This is a packaging-planning guide for EU beverage imports. Food product labelling, food-contact safety and each Member State's operational rules still require separate assessment.
Frequently asked questions
Does the 2030 plastic recycled-content target apply to aluminium beverage cans?
Not to the metal can body. Article 7 concerns plastic packaging parts, with separate categories and exemptions. Review plastic closures and secondary packaging separately rather than assigning the bottle target to every format. [PPWR, Article 7](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R0040).
Can one EU deposit-return symbol be printed for all destination countries?
Not automatically. Article 12 addresses harmonised and national deposit-return marks, while collection arrangements vary by Member State. Approve each market artwork only after the local buyer confirms its system. [PPWR, Article 12](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R0040).
Can one PFAS report be reused when a cap or liner supplier changes?
Only if its tested scope still represents the final packaging and demonstrates the applicable limits. Under Articles 15–16, manufacturers need suitable supporting material from suppliers. Reassess evidence after a material or supplier change. [PPWR, Articles 15–16](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R0040).
Must retailers destroy beverage packaging stocked before 12 August 2026?
Not automatically. Recital 14 distinguishes packaging already placed on the EU market before a relevant requirement applies from new placements. Keep evidence of the first EU market placement and check the specific duty date. [PPWR, recital 14](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R0040).
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