PPWR checklist: what you must do now, by role

The PPWR has applied since 12.08.2026. Which steps you must take today depends on your role per packaging: manufacturers issue the EU declaration of conformity (DoC), distributors verify, importers keep a copy of the DoC. This checklist separates what is mandatory today from what you should record as a precaution.

Status

October 2026, duties since 12.08.2026

Fines

from 12.02.2027, usually up to EUR 10,000

Role

applies per packaging, not per company

Submission deadline

10 days after a reasoned request from the authority

Step 1: determine the role per packaging

Four questions decide: Does the packaging carry your name or trademark? Do you set the specification, for example for a made-to-measure box? Do you import from a third country yourself? Are you a micro-enterprise with a packaging supplier in the same Member State? Whoever carries the brand or sets the specification is the manufacturer. For neutral standard items such as shipping cartons, tape or pallets, the maker of the item is the manufacturer. A shipping label is not branding.

Manufacturer checklist: mandatory today

• Record the components per packaging: material, weight, inks, labels, closures.
• Ask every component supplier for information under Art. 16: confirmation on heavy metals (at most 100 mg/kg per component), SVHC declaration under REACH, for food contact a PFAS declaration and food-contact documents. With name, function and date of the declaring person and an undertaking to report changes.
• Request test reports only for risk materials: flexible PVC, printed parts from third countries, recycled material of unknown origin, paper or moulded fibre in contact with food (total fluorine).
• Set up technical documentation under Annex VII a to f per packaging, including a risk analysis.
• Issue the DoC under Annex VIII: place, date, name, function, signature. In Germany in German or English.
• Put the identifier plus name and address on the packaging or in the accompanying documents (Art. 15(5) and (6)).
• Keep DoC and technical documentation for 5 years, 10 for reusable packaging, counted from the last unit placed on the market.
• Record sourcing and supply data per component (Art. 22).

Distributor checklist: verify, do not declare

• Check per supplier that the producer is listed in the packaging register.
• Check that the identifier plus name and address of the manufacturer appear on the packaging or in the accompanying documents.
• File an informal verification note. A DoC copy is not mandatory but useful as evidence of due diligence.
• Keep sourcing and supply data (Art. 22).
• Own brands: whoever sells goods under their own name becomes the manufacturer under Art. 21.

Importer checklist: copy and address

• Request the DoC copy from the third-country maker, in Germany in German or English.
• Obtain a written undertaking that the technical documentation will be provided on request.
• Put your own name and address on the packaging or in the accompanying document (Art. 18(3)).
• Keep the DoC copy for 5 or 10 years (Art. 18(7)).
• For contract manufacturing under your own brand the manufacturer checklist applies. The micro-enterprise exception does not apply because the supplier is outside the EU.

Record as a precaution, not yet mandatory

You will not need these data until 2028 to 2030, but they are cheap to collect today: a bill of materials with material per layer and weight with tolerance, recycled content split into post-consumer and post-industrial, and an assessment of recyclability. Performance grades under Art. 6 only exist after the delegated act, minimum recycled content from 2030, the sorting label under Art. 12 at the earliest in 2028. Certificates such as ISCC PLUS alone do not prove a recycled share and are not a prerequisite today.