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.

ItemArticleApplies fromWho
Work out your PPWR role for each printed item (manufacturer, importer, distributor, EPR producer)Art 3(1), point 1312 Aug 2026All
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 sourceArt 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 maximumArt 5(4)12 Aug 2026 (general application)Manufacturer
Collect information from packaging and material suppliers needed to show conformityArt 1612 Aug 2026Manufacturer requests; supplier provides
Draw up and keep technical documentation, and re-assess it when design, materials or referenced standards changeArt 15, Annex VII12 Aug 2026Manufacturer
Draw up and sign the EU Declaration of Conformity in the language(s) of each Member State of supplyArt 39, Annex VIII12 Aug 2026Manufacturer
Keep the declaration and technical documentation for 5 years (single-use) or 10 years (reusable) after placing on the marketArt 15(3), Annex VII point 412 Aug 2026Manufacturer; 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 2026Manufacturer
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 requestArt 18, incl. Art 18(3)12 Aug 2026Importer
Verify documentation and labelling before making packaging available, and do not supply packaging known to be non-compliantDistributor duties (article not cited in our guides)12 Aug 2026Distributor
Importer or distributor that sells under its own name or modifies packaging in a way that could affect compliance takes on the manufacturer roleArt 2112 Aug 2026Importer, distributor
Non-established producers appoint an EPR authorised representative; a written mandate can also cover keeping documentationAuthorised 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 referenceArt 6(1)12 Aug 2026Manufacturer
Register, report and pay EPR fees under each country's scheme (for example LUCID and a dual system in Germany under VerpackDG)National lawVaries by country; VerpackDG applies from 12 Aug 2026Producer
Check printed environmental claims: generic claims such as eco-friendly or biodegradable without recognised excellent performance are banned. Related rule, not part of the PPWRDirective (EU) 2024/82527 Sep 2026Brand owner
PE-lined paper beverage cups: keep the printed Plastic in product marking in the local language. Related rule, not part of the PPWRImplementing Regulation (EU) 2020/2151In forceBrand 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.

ItemArticleApplies fromWho
Takeaway outlets must let customers use their own containers at no higher priceArt 3212 Feb 2027Final distributor (HORECA takeaway)
Takeaway outlets must offer a reusable packaging option at no higher price (micro-enterprises exempt)Art 3312 Feb 2028Final distributor (HORECA takeaway)
Watch: Commission due to adopt design-for-recycling criteria and grades per packaging categoryArt 6(4)By 1 Jan 2028Commission; 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 2026Art 12(1)Not before 12 Aug 2028Manufacturer; importer checks
Packaging manufactured or imported before the label deadline may be made available for up to three years after it takes effectArt 12(12)From the label dateManufacturer, 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.

ItemArticleApplies fromWho
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 2029Manufacturer of reusable packaging
Packaging must reach grade A, B or C (70 % or more); below 70 % is technically non-recyclableArt 6(3)1 Jan 2030, or 24 months after the delegated acts if laterManufacturer
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 71 Jan 2030 at the earliestManufacturer 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 coveredAnnex V; guidance C(2026) 3702 (non-binding)1 Jan 2030Final distributor and manufacturer
Maximum 50 % empty space in grouped, transport and e-commerce packagingArt 241 Jan 2030, or 3 years after the methodology act if laterOperator who fills the packaging
Packaging minimisation: weight and volume reduced to the minimum needed for functionArt 102030Manufacturer
Takeaway outlets endeavour to offer 10 % of products in reusable packagingArt 332030Final 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 2038Manufacturer

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.

RoleSimplified meaning
ManufacturerWhoever manufactures packaging or has it designed or manufactured under its own name or trademark; often the brand owner of custom printed packaging
ImporterEU operator placing packaging from a third country on the EU market; adds its name and address
DistributorAny other operator in the supply chain making packaging available
Final distributorThe 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.