PPWR Checklist 2026: What Applies Now, Role by Role

Which PPWR Obligations Apply Now, and Who Carries Them?

Since 12 August 2026, Regulation (EU) 2025/40 has applied, and each obligation follows the role a company holds for a given packaging. The manufacturer draws up the conformity file (Article 15), the supplier provides the data behind it (Article 16), the importer checks it (Article 18) and the distributor verifies registration and identification (Article 19).

The lists below give today's actions, one per line, with their provisions. They are written for German small and medium-sized companies — brand owners, importers, distributors, converters — and hold across the Union, because Article 71 makes the Regulation directly applicable in all Member States.

Key Facts

• Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
• Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included.
• Under Article 5(5), food-contact packaging containing PFAS above the thresholds has been prohibited from being placed on the market since 12 August 2026.
• The EU declaration of conformity follows the model of Annex VIII, under Article 39(2).
• Under Article 6, the A/B/C grades become binding on 1 January 2030, or later if the delegated act is delayed.
• The five statements above are confirmed by our dated PPWR referential (baseline reviewed 15 September 2026); the role obligations of Articles 15 to 22, 44 and 45 are read on the text and listed below.

Which Role Do You Hold for Each Packaging?

A company holds a role per packaging, not once for the whole business. Under Article 3(1) of Regulation (EU) 2025/40, the same company can be manufacturer of its own-brand packaging, importer of goods bought outside the Union and distributor of third-party brands, each role with its own obligations.

• A manufacturer is the person that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark (Article 3(1)(13)).
• A supplier is any person that supplies packaging or packaging material to a manufacturer (Article 3(1)(16)).
• An importer is a person established in the Union that places packaging from a third country on the market (Article 3(1)(17)).
• A distributor is any person in the supply chain, other than the manufacturer or the importer, that makes packaging available on the market (Article 3(1)(18)).
• A producer is the manufacturer, importer or distributor that first makes packaging or packaged products available on the territory of a Member State (Article 3(1)(15)).

Under Article 21, an importer or a distributor that places packaging on the market under its own name or trademark, or modifies packaging already on the market in a way that could affect compliance, is considered a manufacturer. Under Article 15(12), the Union-based packaging supplier of a micro-enterprise brand owner is the manufacturer for the purposes of Article 15.

What Must a Brand Owner or Manufacturer Do Before Placing Packaging on the Market?

Before placing packaging on the market, the manufacturer checks it against the applicable requirements, assesses conformity and draws up the Annex VII technical documentation and the EU declaration of conformity, under Article 15 of Regulation (EU) 2025/40. A brand owner with packaging made under its own name or trademark is, as a rule, that manufacturer (Article 3(1)(13)).

• Check each packaging and each component. Under Article 5(4), the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
• For food-contact packaging, check PFAS against the limit values of Article 5(5).
• Record the design facts behind the recyclability obligation of Article 6(1): materials, components, separability.
• Check that no feature aims only to increase perceived volume, such as double walls or false bottoms (Article 10(2)).
• Carry out the conformity assessment of Article 38 and draw up the Annex VII technical documentation (Article 15(2)).
• Draw up the EU declaration of conformity on the Annex VIII model (Article 39(2)).
• Provide the declaration in the language or languages each Member State of sale requires (Article 39(2)).
• Mark each packaging with a type, batch or serial number or another identifying element (Article 15(5)).
• Show your name or trademark and a postal address on the packaging or its data carrier (Article 15(6)).
• Keep the documentation and the declaration for 5 years after placing on the market, 10 years for reusable packaging (Article 15(3)).

What Must an Importer Check Before Placing Packaging on the EU Market?

Before placing third-country packaging on the market, the importer ensures that the manufacturer has assessed conformity and drawn up the Annex VII technical documentation, under Article 18(2) of Regulation (EU) 2025/40. The importer adds its own name and postal address and keeps a copy of the EU declaration of conformity, under Article 18(3) and 18(7).

• Place on the market only packaging that conforms to Articles 5 to 12 (Article 18(1)).
• Before placing, ensure that the manufacturer has assessed conformity and drawn up the Annex VII documentation (Article 18(2)(a)).
• Check the manufacturer's identification element, name and postal address on the packaging (Article 18(2)(d)).
• Add your own name or trademark and postal address to the packaging (Article 18(3)).
• Hold back packaging that you have reason to believe does not conform (Article 18(2)).
• Keep a copy of the declaration for 5 years, 10 years for reusable packaging (Article 18(7)).
• Protect compliance during storage and transport (Article 18(5)).
• If you sell under your own name or trademark, apply the manufacturer list in full (Article 21).

More in our article on importer obligations for goods from non-EU manufacturers.

What Must a Distributor Verify Before Making Packaging Available?

Before making packaging available on the market, the distributor verifies that the producer of that packaging is registered in the register of producers of Article 44 and that the manufacturer and the importer have identified themselves on the packaging, under Article 19(2) of Regulation (EU) 2025/40. A distributor acts with due care, under Article 19(1).

• Verify that the producer is registered in the register of producers (Article 19(2)(a) and Article 44).
• Verify the identification and contact details of the manufacturer and the importer on the packaging (Article 19(2)(c)).
• Hold back packaging that you have reason to believe does not conform (Article 19(3)).
• Protect conformity during storage and transport (Article 19(3)).
• If you sell under your own name or trademark, or modify packaging in a way that could affect compliance, apply the manufacturer list (Article 21).
• If you are the first to make the packaging available in your Member State, you are its producer there (Article 3(1)(15)).

What Does a Converter or Packaging Supplier Owe Its Customers?

A converter that makes packaging under a customer's name or trademark is a supplier under Article 3(1)(16) of Regulation (EU) 2025/40, and owes that customer the information and documentation needed to demonstrate conformity, under Article 16(1). A converter that places packaging on the market under its own name is the manufacturer (Article 3(1)(13)).

• Decide, packaging by packaging, whether you are manufacturer or supplier (Article 3(1)(13) and (16)).
• As supplier, give the manufacturer the information and documentation needed to demonstrate conformity, including the Annex VII technical documentation (Article 16(1)).
• Provide that documentation in a language the manufacturer easily understands, on paper or electronically (Article 16(1)).
• For contact-sensitive packaging, include the documentation required by the Union acts applicable to it (Article 16(2)).
• Report heavy metals per component (Article 5(4)). A heavy-metals concentration is measured per component and is never added up across components: the worst component sets the result.
• If a customer is a micro-enterprise, you can be the manufacturer of its packaging (Article 15(12) and Article 21).

See also our article on what counts as supplier evidence.

Who Registers as a Producer, and in Which Member State?

The producer registers in the register of producers of each Member State where it first makes packaging or packaged products available, under Article 44(2) of Regulation (EU) 2025/40. The producer is the manufacturer, importer or distributor that first makes the packaging available in a Member State, under Article 3(1)(15).

• Map, per packaging and per Member State, which operator first makes it available there (Article 3(1)(15)).
• Register in each Member State concerned (Article 44(2)).
• Do not make packaging available for the first time in a Member State where you are not registered (Article 44(4)).
• If you sell across a border directly to end users, appoint by written mandate an authorised representative for extended producer responsibility in each Member State of sale other than your own (Article 45(3)).

The Commission proposal COM(2025) 982 of 10 December 2025 proposes to suspend Article 45(3) until 1 January 2035; it is not adopted as of the referential baseline of 15 September 2026. Article 17 provides a different and optional mandate, the authorised representative for conformity tasks. Registers, thresholds and fees are national law: see our guide to producer registration across EU markets and, for Germany, our article on Germany's VerpackDG and the LUCID register.

Which PPWR Obligations Do Not Apply Yet?

Three headline obligations of Regulation (EU) 2025/40 do not bind today: the recyclability performance grades (Article 6), the recycled-content minimums (Article 7) and the harmonised label (Article 12). Under Article 6, the A/B/C grades become binding on 1 January 2030, or later if the delegated act is delayed.

The Article 6(4) delegated act is due by 1 January 2028 and has not been adopted. The Article 12(6) implementing acts were due by 12 August 2026 and have not been adopted. See also our article on which obligations apply today and which wait on a delegated act.

Which Actions Apply to Each Role Today?

Each role under Regulation (EU) 2025/40 carries a short list of actions that apply today, set out in Articles 15 to 22, 44 and 45. The table condenses the checklists above; a company holding several roles for different packaging applies several rows.

What Does the Referential Not Confirm?

Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the Key Facts, the Article 5(4) statements, the Article 6(4) and 12(6) act statuses, and the Article 12(1) and 24(1) dates in the table. Its claim check returned no match for the following statements, read on the text of Regulation (EU) 2025/40.

• The definitions of Article 3(1) and the micro-enterprise rules of Articles 15(12) and 21.
• Articles 15 to 22 as phrased here, including retention for 5 years and for 10 years for reusable packaging.
• Articles 6(3), 7(1), 10(1), 10(2), 17, 38, 39(2), 44, 45(3) and 71 as phrased here, and COM(2025) 982.
• Anything about a national register, threshold or fee, German law included.

Frequently Asked Questions

Does this checklist apply outside Germany?

Yes. Under Article 71, Regulation (EU) 2025/40 is binding in its entirety and directly applicable in all Member States, so the obligations of Articles 15 to 22 read the same everywhere. The referential does not vouch this sentence.

Can a distributor be the producer?

Yes. Under Article 3(1)(15)(b), a distributor established in a Member State that first makes packaged products available on that territory is the producer there. Article 44(2) obliges that producer to register there. The referential does not vouch either sentence.

How PPWR Connect Helps

PPWR Connect records the markets on which each SKU is placed, inside and outside the EU-27, and a per-market obligation profile answers who the producer is for a packaging item in each jurisdiction where it is sold. Supplier documents are filed as evidence against the SKU for the Declaration of Conformity. The EPR country guide is included in the Professional and Enterprise plans, and the EPR registration wizard in the Enterprise plan. PPWR Connect is software: it is not an authorised representative, a producer responsibility organisation or a notified body. Start with our PPWR compliance software or the PPWR readiness assessment.

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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.