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 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.

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Do not publish claims such as recyclable, reusable, compostable, or recycled content unless the claim is tied to the applicable PPWR method, threshold, label specification,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

PPWR compliance is not only a packaging-design exercise. Producers need Member State registration, reporting, and extended producer responsibility controls for packaging they first make available in a Member State or unpack without being end users.

For distance sales, online marketplaces, and fulfilment service providers, the checklist should confirm producer registration information and self-certification are captured before services support offers to consumers in the Union.