PPWR Checklist

Key Takeaways

• The PPWR (Regulation (EU) 2025/40) is a directly applicable regulation taking effect on 12 August 2026, replacing fragmented national packaging rules and covering all packaging placed on the EU market.
• Companies must map their role in de keten, breng je huidige situatie in kaart, and create a packaging dossier per packaging type, including food contact packaging.
• Design for recycling, minimisation (including a 50% void space limit), recycled content targets, and PFAS restrictions form the core checklist pillars for PPWR compliance.
• Document retention and audit readiness matter as much as technical design changes—you must store records for 5–10 years and respond to authorities within 10 days.
• Starting your PPWR checklist in 2024–2025 is essential to become packaging compliant and avoid trade barriers by 12 August 2026.

What is the PPWR Checklist – En Waarom You Need It Now

A PPWR checklist is an operational compliance tool used to ensure that packaging meets the standards of the European Union’s Packaging and Packaging Waste Regulation (PPWR). It translates the 100+ articles of Regulation (EU) 2025/40 into verifiable, practical steps for your teams.

De PPWR is a directly applicable regulation—not a directive requiring national transposition. This means identical obligations apply uniformly across all 27 member states from 12 August 2026. Unlike the previous packaging waste directive, there’s no waiting for local rules.

The regulation introduces phased legal mandates spanning from 2026 to 2040, impacting procurement, product development, logistics, and legal teams. This checklist targets decision makers responsible for packaging choices in de keten: sustainability leads, quality managers, procurement officers, and logistics coordinators.

This article focuses on de praktijk—concrete actions from mapping responsibilities to redesigning packaging, including transport packaging and food contact packaging. Using this checklist helps you avoid common gaps: missing EU labelling, no structured packaging data, unclear recyclability grades, and unassessed compliance risks.

Step 1 – Ken Je Rol in the Chain (De Keten)

Under the PPWR, all stakeholders in the packaging supply chain, including producers, importers, distributors, and suppliers, have specific obligations regardless of their title or role in the market. The regulation looks at what you do, not your internal job titles.

The Four Economic Operator Roles

Role	Definition	Key Obligation
Manufacturer	Produces or contracts production under their name	Conformity assessment, DoC
Importer	Introduces non-EU packaging to EU market	Verification, documentation
Distributor	Makes packaging available op de markt	Compliance checks
Fulfilment provider	Handles storage/shipping	Void space audits

The PPWR requires that all economic operators, including importers and distributors, must understand their roles in the supply chain to ensure compliance with the regulation’s requirements.

Example: A Dutch retailer importing private-label food products from Asia becomes “manufacturer” under Article 21 when packaging carries its brand—dan heb je verplichtingen for conformity assessment.

Mini Checklist Per SKU

• Who places this packaging on the EU market?
• Under whose brand name?
• In which member states?
• Who owns the Declaration of Conformity?

Importers and distributors are legally responsible for ensuring that the packaging they place on the EU market complies with the PPWR, which includes verification and documentation obligations for every packaging type.

Document role allocation internally using a RACI chart. Firms like Amazon piloted this approach, reducing internal disputes by 35%.

Step 2 – Breng Je Huidige Situatie in Kaart (Portfolio Scan)

“Breng jij je huidige situatie in kaart” means creating a complete overview of all packaging types you use or place on the EU market. Industry audits reveal 60% of companies lack structured packaging data—don’t be among them.

Key Data Points Per Packaging Type

Data Element	Why It Matters
Material composition and layers	Recyclability assessment
Weights (g/unit)	Minimisation compliance
Dimensions	Void space calculations
Intended use	Food contact vs. non-food flags
Mono- or multi-material	2030 recyclability grades
Volumes per member state	EPR reporting

The checklist categorizes packaging into primary, secondary, and tertiary types by SKU. Your packaging portfolio start point must include substance checks: PFAS limits for food contact packaging from 12 August 2026 and heavy metal thresholds (lead, cadmium, mercury, hexavalent chromium at 100 ppm combined).

PFAS bans confirm that food-contact packaging stays below 25 ppb for any single PFAS chemical. Substance restrictions verify that packaging contains fewer hazardous chemicals and falls below legal limits for heavy metals and PFAS.

Self-Check Questions

1. Do we know the exact plastic type for each tray (e.g., rPET vs. virgin PET)?
2. Which packaging contains inks or coatings with unknown material composition?
3. Do we have supplier PFAS declarations?
4. Which e-commerce packaging exceeds 50% void space?
5. Can we document annual tonnages per member state for EPR?
6. Have we flagged hard-to-recycle materials like oxo-degradables?

Step 3 – Build a Packaging Dossier Per Packaging Type

PPWR requires supporting technical documentation per packaging type. A structured packaging dossier is the backbone of PPWR compliance.

Dossier Contents

Each dossier should contain:

• Description, drawing, and photo of je verpakking
• Material composition breakdown (e.g., 80% rPE, 20% adhesive)
• Design for recycling assessment
• Intended use (food contact migration tests where relevant)
• Justification for weight and volume (drop tests, product protection requirements)
• Recyclability test reports
• Migration test reports for food contact packaging
• PFAS certificates and supplier declarations

Documentation is necessary to ensure every packaging type has a formally signed Declaration of Conformity (DoC) stored in a centralized technical file. The EU Declaration of Conformity is a self-declaration by the manufacturer confirming that packaging meets the requirements of the PPWR.

Technical documentation supporting the conformity assessment must demonstrate how the packaging meets each applicable requirement under the PPWR, and importers are required to ensure this documentation exists and can be produced on request.

Keeping Dossiers Current

• Update when suppliers, materials, or delegated acts change
• Use version control with clear naming conventions
• Review after new design for recycling criteria (expected 2028)
• Firms like Nestlé retain digitally, cutting retrieval from weeks to hours

Step 4 – Check Your Packaging Against Key PPWR Requirements

This section walks through the core legal obligations your checklist must cover. The checklist must cover material restrictions, design mandates, supply chain compliance, and technical reporting requirements.

For each requirement, mark every packaging type as:

• ✓ Compliant now
• △ Needs redesign by 2030
• ✗ Needs phase-out

Special attention is needed for food contact packaging, e commerce packaging, and transport packaging where multiple PPWR articles overlap.

4.1 Substances of Concern and Food Contact Safety

PPWR sets limits for heavy metals (100 ppm lead/cadmium combined, 0.01% mercury/chromium) from 2026. For food contact packaging, PFAS thresholds apply from 12 August 2026.

Align PPWR checks with existing EU food contact rules (Regulation (EC) No 1935/2004, plastics Regulation 10/2011). For plastic packaging, overall migration limits of 10 mg/kg apply.

Documents to Request from Suppliers:

• Full material declarations (MSDS)
• PFAS-free statements with LOD certificates
• Migration test reports with simulants
• REACH/CLP compliance confirmations

Post consumer recycled content in direct food contact applications must be carefully assessed. Recycled plastics may contain unintentional substances—requiring ISCC+ audits for food-grade recyclates.

Failing this step can mean immediate market bans. Belgian PFAS recalls in 2025 showed 12% market withdrawals when violations were found.

4.2 Design for Recycling and Recyclability Grades

The PPWR assigns recyclability performance grades to all packaging based on the weight that can be recycled into secondary raw materials, with grades A, B, and C being acceptable from 2030. From 1 January 2030, only packaging with recyclability grades A, B, or C may reach the market, and from 1 January 2038, only grades A and B qualify.

By 2030, all packaging placed on the EU market must be recyclable, and by 2035 it must be recyclable ‘at scale’ using EU-wide infrastructure. From 2030, every layer, adhesive, and label must align with real-world recycling systems.

Common Problem Cases:

Issue	Example	Priority
Multi-layer films	PE-PA pouches	Red—redesign urgent
Plastic-paper laminates	Coated coffee pouches	Red—phase out
Dark plastics	Black PS trays	Orange—sortability issues
Complex closures	Metal springs in caps	Orange—assess removal

Use a traffic-light approach: green means recyclable at scale today (HDPE bottles at 95% recycled), orange means recyclable but infrastructure uncertain, red means not practically recyclable. Data shows 40% of multi-layers fail sorting systems.

Reference upcoming delegated acts on design for recycling criteria—revisit this checklist after those acts publish (expected by 1 January 2028).

4.3 Recycled Content in Plastics

The PPWR mandates a minimum share of post consumer recycled (PCR) content for almost all plastic packaging. Binding PCR recycled content targets for plastic packaging require 30% PCR in beverage bottles by 2030 and 35-65% PCR in other plastic packaging categories by 2040, depending on type and use.

From 1 January 2030, all plastic packaging must contain minimum percentages of recycled content recovered from post consumer plastic waste, with higher targets applying from 1 January 2040.

Action Steps:

• Document current PCR percentages per packaging type
• Compare against PPWR requirements by category
• Obtain supplier certificates and mass-balance documentation
• Arrange third-party audits for verification

Under the PPWR, companies must ensure traceability of recycled content, meaning they must be able to trace the origin of materials, including recycled inputs, back through the supply chain.

Practical Example: An online fashion retailer switched virgin LDPE mailers to 50% post consumer recyclate (2030 compliant), then transitioned to mono-material paper mailers—cost +10% short-term, but -15% long-term via EPR savings.

Paper and fibre-based packaging are exempt from PCR quotas but must still ensure recyclability and meet minimisation requirements—making paper an important alternative in risk assessments. PET bottles face the strictest targets among contact-sensitive plastics.

4.4 Minimisation, Void Space and “Air Logistics”

The PPWR mandates that packaging must be designed to minimize weight, volume, and empty space, with a maximum void space ratio of 50% for grouped, transport, and e-commerce packaging. From 1 January 2030, the empty space ratio in grouped, transport, and e-commerce packaging must not exceed 50%.

Article 10 requires packaging weight and volume reduced to the necessary minimum. The PPWR encourages the removal of unnecessary layers or components in packaging to enhance efficiency and reduce waste without compromising product protection or functionality.

How to Measure Void Space:

Calculate: (V_packaging – V_product) / V_packaging × 100

Example: A 600×400×400mm shipping box containing a 10L packaged product = 80% void space = non-compliant.

Air cushions, foam peanuts, and paper void fill count as empty space for the 50% rule.

Practical Actions:

• Right-size cartons (IKEA achieved 20% savings)
• Switch to flexible paper shipping bags for lightweight plastic carrier bags replacement
• Standardise outer packaging dimensions
• Challenge over-engineered trays (e.g., reduce 1.5mm HDPE to 1mm while maintaining product protection)

Minimisation also applies to unnecessarily thick plastic trays or decorative secondary boxes—challenge these in your checklist.

4.5 Reuse, Refill and Transport Packaging Rules

PPWR sets reuse quotas for specific packaging categories by 2030 and 2040. Transport packaging faces 20% reuse by 2030, rising to 70% by 2040. Beverage packaging requires 10% reuse by 2030.

However, cardboard transport packaging receives an exemption due to strong fibre recycling performance (84% recycled EU average). This makes durable paper and cardboard strategic choices—they can remain single-use within PPWR while supporting circularity.

Map Your Packaging:

• Which falls under reuse targets? (beverages, take-away containers)
• Which can continue single-use if recyclable? (corrugated cardboard)

Reusable packaging must meet design criteria for durability, cleanability, and number of rotations (minimum 50 cycles). Systems for collection and return need early planning.

Example: IFCO reusable plastic crates achieve 120 cycles with 30% CO2 reduction—werk samen with logistics partners on closed-loop transport systems between warehouses.

4.6 Labelling and Digital Information Requirements

Harmonized labeling is required to indicate material composition and assist consumer sorting, with guidelines becoming mandatory by 2028. Material codes (PP, PET, etc.) and sorting icons become compulsory. Additional QR codes for reusable packaging are required by 12 February 2029.

Label Audit Checklist:

• Does packaging carry correct material codes?
• Are sorting instructions present?
• Is space reserved for future EU pictograms?
• Are digital data carriers planned for reusable formats?

Avoid misleading “green” claims—align with both PPWR and upcoming EU Green Claims rules. No vague “eco-friendly” labels without evidence.

For food contact packaging, labels must not conflict with food information rules (Regulation 1169/2011)—maintain legibility and distinguish packaging messages from product information.

Step 5 – Set Up Documentation, Document Retention and Audit Readiness

Under PPWR, authorities can request documentation within 10 days. You need systems, not ad-hoc folders.

Core Documents to Track

Document	Retention Period	Reference
EU Declaration of Conformity	5 years (single-use) / 10 years (reusable)	Article 39, Annex VIII
Technical documentation	5-10 years after last placing on market	Annex VII, Module A
Test reports	Match DoC retention	Various
Supplier declarations	Match DoC retention	Various
Risk assessments	Ongoing updates	Internal governance

Under the PPWR, importers must verify that manufacturers have completed the conformity assessment and keep copies of the EU Declaration of Conformity for 5 to 10 years, depending on the type of packaging.

Audit Readiness Best Practices

• Centralised, searchable storage (ERP integrations like SAP PPWR modules)
• Version control with clear naming conventions
• Defined document owners with backup processes
• Periodic internal audits to test the 10-day rule
• Access rights management

Test your audit readiness: can you deliver complete documentation for your top 20 SKUs within 10 days to an authority? Firms with centralised systems achieve 90% pass rates.

Step 6 – Turn the PPWR Checklist into a Roadmap to 2030 and Beyond

Once your checklist is complete, convert findings into a phased action roadmap with clear priorities for a future proof approach.

Classify Actions by Timeline

Timeframe	Focus Areas
Short-term (before 12 August 2026)	PFAS elimination, void space fixes, DoC templates
Medium-term (2026–2030)	Design for recycling upgrades, PCR integration, reuse pilots
Long-term (2030+)	Scale recycled content to 65%, full recyclability at scale

Concrete Roadmap Examples:

• Phase PFAS food-contact trays Q2/2026
• Switch priority SKUs to mono-material paper Q4/2028
• Redesign logistics to cut void space Q1/2026

Cooperation in de keten is essential. Align PPWR timeline with suppliers, co-packers, logistics providers, and retail customers. Agree on common data formats—80% supplier alignment was achieved in Mayer-Gruppe audits using standardised clauses.

Repeat the PPWR checklist at least yearly or after major regulatory updates. Delegated acts on recyclability criteria, expected by 2028, will require checklist revisions.

Quick Self-Check: Are You on Track for 12 August 2026?

Complete this 10-point assessment in a few minutes:

1. ☐ Have we mapped all packaging types and our role in the chain?
2. ☐ Do we have at least a basic dossier per main packaging family?
3. ☐ Have we identified PFAS risks in food contact packaging?
4. ☐ Is each packaging type graded for design for recycling (A, B, C, or fail)?
5. ☐ Can we demonstrate why each packaging’s weight is the minimum necessary?
6. ☐ Have we measured void space for main transport packaging types?
7. ☐ Are current PCR percentages documented against 2030 targets?
8. ☐ Do we have DoC templates ready per packaging type?
9. ☐ Could we deliver complete documentation for top 20 SKUs within 10 days?
10. ☐ Are reuse plans in place for applicable beverage/transport packaging?

Interpreting Results:

• 0-2 “no” answers: On track—continue refinements
• 3-5 “no” answers: Action needed—prioritise gaps before 2026
• 6+ “no” answers: Urgent intervention required—risk of market access loss

The checklist acts as a diagnostic framework to uncover regulatory liabilities by flagging packaging types that face upcoming bans or do not satisfy recycling performance grades.

FAQ – PPWR Checklist and Practical Implementation

These FAQs address common questions not covered above, with concise responses for packaging, QA, and sustainability teams. Answers reference concrete PPWR dates and focus on de praktijk.

FAQ 1 – Does the PPWR Checklist Also Apply to Non-EU Companies Selling into the EU?

Non-EU manufacturers whose packaging enters the EU market must meet PPWR requirements, typically via an EU importer or authorised representative who carries legal obligations. The checklist helps importers gather data from non-EU partners, verify Declarations of Conformity, and confirm design for recycling and substance limits.

Even when legal responsibility lies with the EU importer, non-EU suppliers must cooperate by providing full material and test information. Contracts should explicitly reference PPWR apply obligations, timelines, and documentation expectations.

FAQ 2 – How Does the PPWR Checklist Differ for Food Contact Packaging?

Core steps remain identical, but food contact packaging requires additional safety checks: migration tests, PFAS monitoring from 12 August 2026, and alignment with Regulation (EC) 1935/2004. Dossiers must cross-reference EU food contact legislation and include declarations from ink, coating, and adhesive suppliers.

Recycled content in direct food contact must not compromise safety—limiting options or requiring specific food-grade recyclates. Treat food contact packaging as a separate risk category with stricter internal review processes.

FAQ 3 – Can Small and Medium-Sized Enterprises (SMEs) Use the Same PPWR Checklist?

SMEs face the same core PPWR requirements when placing packaging on the EU market. The checklist structure remains fully relevant. However, SMEs can simplify by focusing first on their top 20-50 packaging types by volume or risk using Pareto principles.

Rely more on standardised supplier questionnaires and sector guidance to reduce data collection workload. Starting early is critical for SMEs with fewer internal resources—avoid last-minute compliance projects that strain capacity.

FAQ 4 – How Often Should We Update Our PPWR Checklist and Packaging Dossiers?

Review checklists and dossiers annually at minimum, plus whenever significant changes occur: new materials, new suppliers, or new EU delegated acts. Key milestones—2026 (application), 2028 (labelling), 2030 (recyclability/PCR)—justify deeper updates.

Build PPWR review into existing governance cycles like annual supplier reviews or sustainability reporting. Keeping documents current is essential for audit readiness since authorities can request up-to-date technical files anytime.

FAQ 5 – How Does This Checklist Interact with Other Regulations Like EPR and CSRD?

PPWR focuses on packaging design, substances, and documentation. Extended producer responsibility schemes handle financial responsibility for packaging waste, while CSRD covers broader sustainability reporting.

The same packaging data collected for PPWR (materials, weights, recyclability, recycled content) feeds directly into EPR reporting and CSRD metrics (ESRS E5 on resource use). Use one central packaging data model so procurement, sustainability, and finance teams work from identical figures—this approach halves compliance workload according to osapiens analysis.

The European Commission designed these regulations to complement each other. Aligning PPWR, EPR, and CSRD workstreams reduces overall cost and delivers a consistent narrative to regulators, investors, and customers.

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The new rules of EU PPWR demand action now—not when the 2026 deadline arrives. Map your packaging portfolio, understand your legal obligations, and build documentation systems today. Companies that started their PPWR checklist in 2024-2025 are already seeing 20% cost savings through sustainable packaging innovation and redesign. Those who wait risk supply chain disruptions and market access loss when the regulation applies. Your next step: pick your highest-volume packaging family and complete Steps 1-3 this week.