PPWR compliance checklist

Start each packaging review by confirming whether the item is packaging under Article 3 and whether it is sales, grouped, transport, e-commerce, service, reusable, refill, or another relevant format. Article 2 makes the scope broad, so do not exclude a format only because it is used in industry, retail, offices, services, households, or distribution.

Then map the accountable role. The checklist should identify the manufacturer, supplier, importer, distributor, final distributor, fulfilment service provider, producer for extended producer responsibility (EPR) purposes, and any authorised representative where relevant.

For each packaging type, run the Article 5 to Article 11 checks before approving a design, supplier change, material substitution, or claim. The output should be a yes/no decision with evidence, not a generic statement that the packaging is sustainable.

Where a date or threshold is not yet active, keep it as a tracked PPWR requirement with the delegated or implementing act dependency noted. This prevents teams from treating future design, calculation, or chain-of-custody rules as optional.

Keep the current recyclability rule separate from the later scoring method. The Commission's June 2026 guidance says Article 6(1) applies from 12 August 2026, but manufacturers do not perform the PPWR recyclability conformity assessment under Article 38 and Annex VII until the Article 6(4) delegated act enters into force. Until the design-for-recycling condition applies, the guidance directs manufacturers to the previous Packaging Waste Directive requirements and related harmonised standards. This Commission interpretation is guidance; Article 6 and the future secondary acts control the binding method.

Label checks should be separate from sustainability checks because the packaging may need different evidence for material composition, deposit and return, reuse, recycled-content claims, compostability, and online pre-purchase information.

Do not publish claims such as recyclable, reusable, compostable, or recycled content unless the claim is tied to the applicable PPWR method, threshold, label specification, and evidence file.

The checklist should produce a technical file that can support the EU declaration of conformity and authority requests. Article 15 requires manufacturers to place only compliant packaging on the market and, unless Article 15(11) applies, carry out conformity assessment, draw up technical documentation, and draw up an EU declaration of conformity.

Supplier evidence should be collected early because Article 16 requires suppliers to give manufacturers the information and documentation needed to demonstrate conformity of packaging and packaging materials. A supplier can prepare evidence, but the manufacturer remains responsible for the packaging's conformity unless Article 3(13)(b) changes who is the manufacturer or Article 15(12) treats the supplier as the manufacturer for Article 15.

PPWR compliance is not only a packaging-design exercise. Once the relevant Article 44 register and reporting system apply, producers need Member State registration and reporting controls for packaging they first make available in a Member State or unpack without being end users. Extended producer responsibility is a separate duty under Article 45.

For distance sales, online platforms covered by Article 45(4), and fulfilment service providers supporting offers to consumers in the Union, the checklist should confirm producer registration information and self-certification are captured before services are provided.