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From August 12, 2026, packaging placed on the EU market must meet PPWR’s chemical restrictions, and every manufacturer of packaging or packaged goods must have a valid Declaration of Conformity in place. This PPWR compliance checklist covers the four phases to work through before the deadline.
Phase 1: Determine Your Legal Role and EPR Status
☐ Identify your supply chain role. Establish whether PPWR classifies your business as a Manufacturer (you produce packaging or sell it under your own brand), an Importer (you bring packaging into the EU), or a Distributor (you make packaging available on the market after the manufacturer or importer). Your role determines your compliance obligations.
☐ Check the Brand Rule. If you are an importer or distributor but sell packaging under your own name or trademark, or if you modify packaging in a way that affects compliance, PPWR classifies you as the Manufacturer. You carry all manufacturer obligations.
☐ Confirm your Producer status for EPR. If you are the first business to make packaging available in a specific Member State, you are a Producer under PPWR and must register in that country’s national producer register. This applies per Member State, so selling into multiple markets may mean multiple registrations.
Phase 2: Map Your Packaging Portfolio
☐ Break down packaging by component and material. Plastic food containers face different regulatory requirements than cardboard or glass. Map each packaging unit by component and material type before starting your compliance assessment.
☐ Prepare for a consolidated Declaration of Conformity. PPWR requires a single EU Declaration of Conformity covering all applicable Union acts, including overlapping directives and harmonized standards. A gap in any one of those acts could undermine the entire compliance dossier.
Phase 3: Audit Food-Contact Packaging for Chemical Restrictions
The August 12, 2026 chemical restrictions apply specifically to food-contact packaging. If any of your packaging touches food, complete this phase in full.
☐ Identify all food-contact packaging in your portfolio.
☐ Verify heavy metals limits. Obtain documentation confirming that the combined concentration of lead, cadmium, mercury, and hexavalent chromium does not exceed 100 mg/kg.
☐ Address the total fluorine rule. If your packaging’s total fluorine (TF) content exceeds 50 mg/kg, you must obtain documentation differentiating PFAS-sourced fluorine from non-PFAS fluorine. A standard material declaration is not sufficient.
☐ Secure PFAS declarations from suppliers. If TF exceeds the 50mg/kg limit, you need structured test results confirming PFAS concentrations to not meet or exceed:
- 25 ppb for any single targeted PFAS
- 250 ppb for the sum of targeted PFAS
- 50 ppm for total PFASs, including polymeric PFAS
Phase 4: Finalize Your Documentation
☐ Compile your Annex VII technical documentation. Gather conformity assessments and supporting documentation proving your packaging meets PPWR’s sustainability and safety requirements.
☐ Issue the EU Declaration of Conformity. Formally issue the single EU DoC based on your completed conformity assessment.
☐ Set up your retention system. The DoC and technical documentation must be kept available for national authorities for:
- 5 years for single-use packaging
- 10 years for reusable packaging
Importers must retain a copy of the DoC for the same timeframes.
How PAQR can help
Working through this checklist generates a significant volume of supplier data, compliance documentation, and technical files that need to be structured, stored, and available for audit.
PAQR’s supplier request portal lets you collect PFAS declarations, heavy metals certifications, and material documentation directly from your suppliers. Responses are stored centrally alongside your component data and compliance records in one auditable workspace. When your technical files are complete, you can generate your Declaration of Conformity from the same platform.
Get a head start on PPWR implementation. Click “Try now for free” on paqr.com to start a free trial.
