October 16, 2026
PPWR Compliance for Malaysian Exporters
Overview
Whether you ship semiconductors and other electronic products, rubber gloves, palm oil‑based products or food products into the EU, there is one recent common obligation that applies to all your contract partners from the EU: since 12 August 2026, they must ensure that your packaging is in conformity with the so-called Packaging and Packing Wast Regulation (PPWR), new legislation at EU-level.
Why you will be made responsible for the packaging
Leaving the law aside and focusing solely on practicalities: it is impossible for your business partner in the EU to know the specifics of your packaging unless you inform him accordingly. Prior to 12 August 2026, your business partner didn’t need to know the full specifics, but this has changed.
For this reason alone, European companies now insist that suppliers from Malaysia and any other country in the world provide detailed information on packaging. We have trained over 50 companies from Europe on the PPWR and know that they will often refuse to purchase from you without such details. At the very least, they will link providing such information to payment and insist that you are liable if they get fined because of wrong information on the packaging.
What your customers will typically demand from you
While this depends on a case-by-case basis, typically, your customers will demand the following:
- 01
a so-called EU Declaration of Conformity for your packaging
- 02
technical documentation, retained for five years (single‑use packaging) or ten (reusable), producible to authorities within ten days of request
- 03
compliance with substance restrictions – heavy metals and PFAS for food‑contact packaging
- 04
traceability marking, and extended producer responsibility (EPR) registration in each EU member state where your packaging first reaches the market
How the PPWR will change over the next years
The obligations which came into force on 12 August 2026 are merely the beginning. Over the next years, your customers from the EU must ensure compliance with, among others:
- 2028: harmonised material‑composition labelling
- 2029: QR code obligation for reusable packaging
- 2030: minimum recyclability grade and minimum recycled content requirements (10–35% depending on packaging type)
Read the contract your buyer sends you
EU buyers are increasingly building PPWR warranties into supply contracts. Why do we know this? Because we often act for EU buyers and therefore know exactly what they require from their suppliers from around the world. The most important obligations include:
- 01
a confirmation that your packaging carries a valid Declaration of Conformity
- 02
an obligation to supply technical documentation on demand
- 03
audit rights and liability if your packaging is rejected at the border or triggers a market withdrawal
Know what you’re actually able to certify before you sign.
Many Malaysian companies simply sign agreements, without checking the contract thoroughly – and a thorough check necessarily requires someone to understand the PPWR and the applicable law, which in many cases will not be Malaysian law.
Do not make the same mistake as you may easily find yourself in an arbitration in which you will be asked to indemnify your customer from the EU, being made responsible to pay millions of Euros in fines in the worst case. See our full treatment of supply chain contract terms for the broader approach; the points above are the ones your EU counterparty will push hardest on.
Why work with us on this
We advise both European buyers and Malaysian exporters directly on PPWR conformity and documentation, drawing on multiple trainings and publications on the PPWR, as well as our broader EU regulatory compliance work organisations both in the European Union and in Malaysia.
Get your PPWR packaging compliance reviewed
Contact us
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