This free checklist turns the PPWR into a dated action list for packaging buyers. Every row gives the article, the date it applies from, the role responsible and, in the PDF, the evidence to hold. It covers Regulation (EU) 2025/40 as of October 2026: items that already apply since 12 August 2026, the takeaway duties of 2027 and 2028, the sorting label, and the 2030 to 2038 design requirements. The download is a plain A4 PDF with tick boxes, and it needs no email address.
ppwr-compliance-checklist.pdf (A4, 3 pages)
An optional box lets you ask for an update when the sorting-label act or the design-for-recycling criteria are adopted; the file itself is not gated. This is a planning aid, not legal advice. Obligations depend on your role in each Member State; confirm them with the competent authority, your compliance scheme or counsel.
Status as of October 2026. Sources: Regulation (EU) 2025/40 on EUR-Lex (eur-lex.europa.eu/eli/reg/2025/40/oj) and Commission guidance notice C(2026) 3702 of 5 June 2026 (non-binding).
How to use the PPWR checklist
Start with the first row: decide whether you are the manufacturer, importer, distributor or EPR producer for each item. Then work down the "Who" column and tick only the rows that name your role. Keep one copy of the checklist per item code, because the evidence differs between a cup, a food box and a mailer.
For the full picture behind each row, read the PPWR overview for foodservice and e-commerce buyers. The rows below link to the detailed guides: PFAS-free food packaging, the declaration of conformity, recyclability grades and labelling requirements.
Which PPWR items already apply (from 12 August 2026)?
Since 12 August 2026, the manufacturer's conformity assessment, technical documentation and EU Declaration of Conformity apply, together with the PFAS limits for food-contact packaging and the identification details on packaging. The PFAS limits have no sell-off period, so stock made earlier is not exempt if it is placed on the market after that date; packaging placed on the market before it may stay on the market, according to the Commission's guidance.
| Item | Article | Applies from | Who |
|---|---|---|---|
| Work out your PPWR role for each printed item (manufacturer, importer, distributor, EPR producer) | Art 3(1), point 13 | 12 Aug 2026 | All |
| Food-contact packaging: no more than 25 ppb for any single PFAS and 250 ppb for the sum (targeted analysis), and 50 ppm for all PFAS including polymeric PFAS. If total fluorine is above 50 mg/kg, get proof of the fluorine source | Art 5(5) | 12 Aug 2026 (no sell-off period) | Manufacturer ensures; importer checks; distributor must not supply non-compliant packaging; material supplier gives fluorine proof on request |
| Sum of lead, cadmium, mercury and hexavalent chromium in packaging: 100 mg/kg maximum | Art 5(4) | 12 Aug 2026 (general application) | Manufacturer |
| Collect information from packaging and material suppliers needed to show conformity | Art 16 | 12 Aug 2026 | Manufacturer requests; supplier provides |
| Draw up and keep technical documentation, and re-assess it when design, materials or referenced standards change | Art 15, Annex VII | 12 Aug 2026 | Manufacturer |
| Draw up and sign the EU Declaration of Conformity in the language(s) of each Member State of supply | Art 39, Annex VIII | 12 Aug 2026 | Manufacturer |
| Keep the declaration and technical documentation for 5 years (single-use) or 10 years (reusable) after placing on the market | Art 15(3), Annex VII point 4 | 12 Aug 2026 | Manufacturer; importer keeps a copy of the declaration |
| Put manufacturer name and postal address, and a type, batch or serial number, on the packaging (or data carrier or accompanying document) | Art 15(5) and 15(6) | 12 Aug 2026 | Manufacturer |
| Before placing imported packaging on the market: check the manufacturer's assessment, documentation and labelling, add importer name and address, supply documents to authorities within 10 days of a reasoned request | Art 18, incl. Art 18(3) | 12 Aug 2026 | Importer |
| Verify documentation and labelling before making packaging available, and do not supply packaging known to be non-compliant | Distributor duties (article not cited in our guides) | 12 Aug 2026 | Distributor |
| Importer or distributor that sells under its own name or modifies packaging in a way that could affect compliance takes on the manufacturer role | Art 21 | 12 Aug 2026 | Importer, distributor |
| Non-established producers appoint an EPR authorised representative; a written mandate can also cover keeping documentation | Authorised representative provisions (article not cited in our guides) | 12 Aug 2026 (general application) | Producer without establishment in the Member State |
| General recyclability principle applies now; until the design-for-recycling delegated acts exist, the old Packaging Directive requirements and standards such as EN 13430 remain the reference | Art 6(1) | 12 Aug 2026 | Manufacturer |
| Register, report and pay EPR fees under each country's scheme (for example LUCID and a dual system in Germany under VerpackDG) | National law | Varies by country; VerpackDG applies from 12 Aug 2026 | Producer |
| Check printed environmental claims: generic claims such as eco-friendly or biodegradable without recognised excellent performance are banned. Related rule, not part of the PPWR | Directive (EU) 2024/825 | 27 Sep 2026 | Brand owner |
| PE-lined paper beverage cups: keep the printed Plastic in product marking in the local language. Related rule, not part of the PPWR | Implementing Regulation (EU) 2020/2151 | In force | Brand owner, manufacturer |
Two points are often misread. First, the declaration is a conclusion drawn from evidence, so the technical file must exist before anyone signs it. Second, recyclability is not yet assessed against grades: the Commission guidance says manufacturers need not run the recyclability conformity assessment until the design-for-recycling delegated acts enter into force, so any grade quoted today is an estimate.
What are the PPWR deadlines for 2027 and 2028?
Two takeaway duties start in 2027 and 2028, and the sorting label follows no earlier than 12 August 2028. Takeaway outlets must accept customers' own containers from 12 February 2027 and offer a reusable option from 12 February 2028. The label date will in practice be later because the implementing act had not been adopted as of October 2026.
| Item | Article | Applies from | Who |
|---|---|---|---|
| Takeaway outlets must let customers use their own containers at no higher price | Art 32 | 12 Feb 2027 | Final distributor (HORECA takeaway) |
| Takeaway outlets must offer a reusable packaging option at no higher price (micro-enterprises exempt) | Art 33 | 12 Feb 2028 | Final distributor (HORECA takeaway) |
| Watch: Commission due to adopt design-for-recycling criteria and grades per packaging category | Art 6(4) | By 1 Jan 2028 | Commission; manufacturers monitor |
| Harmonised material sorting label, including e-commerce packaging. Applies on the later of 12 Aug 2028 or 24 months after the implementing act; the act was not adopted as of October 2026 | Art 12(1) | Not before 12 Aug 2028 | Manufacturer; importer checks |
| Packaging manufactured or imported before the label deadline may be made available for up to three years after it takes effect | Art 12(12) | From the label date | Manufacturer, importer |
What applies from 2029 to 2038?
The reusable-packaging label starts no earlier than 12 February 2029, and the main design requirements start on 1 January 2030, with later steps in 2035 and 2038. Several 2030 dates move later if the Commission adopts its supporting acts late.
| Item | Article | Applies from | Who |
|---|---|---|---|
| Reusable packaging label with QR code or open data carrier (later of 12 Feb 2029 or 30 months after its implementing act) | Art 12(2) | Not before 12 Feb 2029 | Manufacturer of reusable packaging |
| Packaging must reach grade A, B or C (70 % or more); below 70 % is technically non-recyclable | Art 6(3) | 1 Jan 2030, or 24 months after the delegated acts if later | Manufacturer |
| Minimum recycled content in plastic packaging: contact-sensitive PET 30 %, contact-sensitive non-PET 10 %, other plastic 35 % (50, 25 and 65 % from 2040) | Art 7 | 1 Jan 2030 at the earliest | Manufacturer of plastic packaging |
| Restrictions on single-use plastic packaging for food and drink consumed on HORECA premises, plastic condiment portions (except with takeaway) and very lightweight plastic carrier bags (with exceptions). Commission guidance treats paper-based packaging with 5 % or more plastic as covered | Annex V; guidance C(2026) 3702 (non-binding) | 1 Jan 2030 | Final distributor and manufacturer |
| Maximum 50 % empty space in grouped, transport and e-commerce packaging | Art 24 | 1 Jan 2030, or 3 years after the methodology act if later | Operator who fills the packaging |
| Packaging minimisation: weight and volume reduced to the minimum needed for function | Art 10 | 2030 | Manufacturer |
| Takeaway outlets endeavour to offer 10 % of products in reusable packaging | Art 33 | 2030 | Final distributor (HORECA takeaway) |
| Recycled at scale (2035, or 5 years after its implementing acts if later); only grades A or B (2038) | Art 6(2)(b) and Art 6(3) | 1 Jan 2035; 1 Jan 2038 | Manufacturer |
Who is who in the checklist
The Who column uses the PPWR roles. One company can hold several roles, and the role can differ by country.
| Role | Simplified meaning |
|---|---|
| Manufacturer | Whoever manufactures packaging or has it designed or manufactured under its own name or trademark; often the brand owner of custom printed packaging |
| Importer | EU operator placing packaging from a third country on the EU market; adds its name and address |
| Distributor | Any other operator in the supply chain making packaging available |
| Final distributor | The operator handing packaging to the end customer, such as a takeaway outlet |
| Producer (EPR) | For service packaging, the operator first making it available in that Member State |
Most buyers first want to know whether the brand owner counts as the manufacturer. The guide to the PPWR declaration of conformity sets out when a chain, a converter or an importer is the manufacturer, and the national authority's reading can differ for empty printed service packaging.
What this checklist does not cover
It does not cover national EPR detail, food-contact rules, or markets outside the EU. The PPWR does not apply in Great Britain; see the UK packaging regulations guide. For Germany and Austria, see packaging compliance in Germany and Austria, and for food-contact documents see food-contact packaging compliance.
Next step: ask your supplier for the documents on the list
Send the evidence column to each packaging supplier and compare what comes back. To put these requirements into a quotation request, use the packaging RFQ template and the RFQ guide. 9 Packaging is an Istanbul-based B2B printed packaging manufacturer and exporter; documentation for each item is agreed at quotation and technical review. Contact our team.