PPWR checklist: ready in eight steps

From 12 August 2026 the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) applies directly in every member state — with no national implementing act. This PPWR checklist takes you through the preparation in eight concrete steps: from capturing your packaging portfolio and determining your role to issuing the EU declaration of conformity. That way you know exactly what your company has to have done by the cut-off date.

PPWR date of application

12 August 2026 (Art. 71)

Legal form

EU regulation — applies directly, no national transposition

Microenterprise special rule

< 10 employees AND ≤ €2m turnover/balance sheet

Member state penalty rules

to be laid down by 12 February 2027

The PPWR checklist at a glance: 8 steps to 12 August 2026

• 1. Capture the packaging portfolio in full — every packaging item, every material, every format.
• 2. Clarify your role per supply chain and EU country — producer, importer or distributor (Art. 15 et seq.).
• 3. Determine the applicable requirements per packaging item — which obligations actually bite?
• 4. Assemble the technical documentation — bundle the evidence required by Annex VII.
• 5. Draw up the EU declaration of conformity — issue it as producer under Art. 15.
• 6. Check labelling and data requirements — identification and contact details (Art. 12, 15).
• 7. Obtain supplier evidence — request the documents under Art. 16 in structured form.
• 8. Set up a process for ongoing updates — track changes, deadlines and new legal acts.

Step 1: capture the packaging portfolio in full

No inventory, no compliance. List every piece of packaging you place on the market or make available: made of which material, in which format, for which product. The definition of packaging in Art. 3 is broad — it covers not only boxes and bottles but also service packaging, single-use items filled at the point of sale, and tea bags. Also distinguish between sales, grouped and transport packaging, because that classification decides later obligations such as the empty-space ratio.

Step 2: clarify your role per supply chain and EU country

The PPWR distributes obligations along the supply chain across clearly defined roles. The producer carries the main burden (conformity, technical documentation, EU declaration of conformity, Art. 15); the importer verifies the producer obligations and places only conforming goods on the market (Art. 18); the distributor acts with due care and checks, among other things, registration in the producer register (Art. 19). Important: anyone placing goods on the market under their own name or brand, or modifying packaging in a conformity-relevant way, becomes a producer themselves (Art. 21) — with the full burden of obligations. For companies with several functions the obligations apply cumulatively.

Step 3: determine the applicable requirements per packaging item

Not every obligation hits every piece of packaging the same way. For each position in your portfolio, map which requirements actually apply — labelling (Art. 12) and contact details on the cut-off date, later recyclability (Art. 6), minimum recycled content (Art. 7), packaging minimisation (Art. 10) and the empty-space ratio (Art. 24). The result is a solid applicability matrix showing you where action is needed and which deadlines run when. Prioritise the obligations already applicable on 12.08.2026 first and schedule the later design requirements separately — that way you avoid pulling 2030 effort forward while the evidence obligations for the cut-off date are still open.

Step 4: assemble the technical documentation

As a producer you have to carry out a conformity assessment and create the technical documentation under Annex VII. To do that, gather all the evidence per packaging item in structured form in one place — from material details to test and measurement results. Note the retention periods: five years for single-use packaging, ten years for reusable packaging (Art. 15(3)). Importers additionally keep a copy of the EU declaration of conformity (Art. 18(7)), and authorised representatives may keep the documents but not create them themselves (Art. 17). On a reasoned request from the authority the documents have to be produced within ten days — a window only those already holding the documents in order can meet.

Step 5: draw up the EU declaration of conformity

Once the technical documentation stands, the EU declaration of conformity follows: with it the producer confirms that the packaging meets the requirements of Art. 5–12 (Art. 15(2)). It is the central document of market access — without conformity no packaging may be placed on the market (Art. 4(1)). File the declaration and the documentation together and in an audit-proof way, so that they remain available throughout the retention period.

Step 6: check labelling and data requirements

The producer applies an identification (type, batch or serial number) plus name and address, where applicable via a QR code or data carrier (Art. 15(5), (6)). On top of that comes the labelling of the packaging under Art. 12. Importers add their own contact details (Art. 18(3)). Check systematically that every piece of packaging carries the prescribed particulars — missing labelling is one of the most common grounds for objection.

Step 7: obtain supplier evidence

Suppliers deliver not only material but also the supporting documents for your technical documentation (Art. 16). Request these early and in structured form — particularly the particulars prescribed by Annex VII and Art. 5–11. For contact-sensitive packaging the relevant food-contact documents are added. Also keep traceability ready: on request you have to disclose whom you sourced from and whom you supplied (Art. 22).

Step 8: set up a process for ongoing updates

PPWR compliance is not a one-off project. When a packaging item changes, conformity has to be reassessed (series conformity, Art. 15(4)). At the same time many deadlines hang on implementing and delegated acts still to be adopted. So set up a process that continuously tracks portfolio changes, expiring retention periods and new legal acts — ideally with clear ownership and automatic reminders.