Ministry of Finance Confirms PPWR Import Checks: Documentation Must Be Available on Request
In its official position (letter dated 24 August 2026, reference no. DC5.8870.1169.2026), the Ministry of Finance confirms that customs authorities may require importers to provide documentation mandated under the PPWR. Although these documents do not normally need to be attached to the customs declaration, their absence during an inspection may affect whether the goods can be released for free circulation.
The Ministry of Finance emphasises that the PPWR does not require technical documentation or an EU declaration of conformity to be attached to every import declaration. It also does not introduce new customs document codes.
This does not, however, mean that the importer may lack the required documentation. Under Articles 15 and 46 of the Union Customs Code, customs authorities may request the information necessary to determine whether the imported product and its packaging meet EU requirements and may be lawfully placed on the market.
We had already highlighted the risk of inspections once the PPWR begins to apply. In the Prawo.pl article “PPWR from August 2026: How to Prepare for an Inspection?”, we indicated that businesses should be prepared for verification of packaging compliance and the related documentation. The Ministry’s position therefore confirms our earlier assessment of customs authorities’ inspection powers.
The requirements relating to substances present in packaging are particularly important. The PPWR, which applies from 12 August 2026, sets, among other things, limits for PFAS in food-contact packaging. For all packaging, the combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg. Compliance with these requirements should be demonstrated in the 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 documentation is not provided or demonstrates that the packaging is non-compliant, the release of the goods may be suspended.
For importers, this means ensuring access to documentation relating to packaging, including where packaging is only one component of the imported product. It is worth checking whether suppliers provide the relevant declarations and test results, and whether the documents can be submitted promptly in the event of a customs inspection.
If you have any questions about the PPWR, packaging technical documentation or the impact of the new requirements on import processes, please contact us.
Contact:
Krzysztof Wiński, Partner
krzysztof.winski@thedy.pl
Łukasz Pamuła, Senior Manager
lukasz.pamula@thedy.pl