PPWR Compliance Checklist for Importers & Distributors

Introduction

If you import packaged products into the EU or distribute them across EU member states, PPWR places specific obligations on you as an "importer" or "distributor." This checklist provides a step-by-step action plan to ensure you meet all compliance requirements before August 12, 2026.

What is an Importer Under PPWR?

Under PPWR, an importer is any person who places packaging or products with packaging originating in a third country (non-EU) on the EU market for the first time. As an importer, you have specific legal responsibilities:

• Ensure packaging compliance: You must verify that all imported packaging meets PPWR requirements before placing it on the EU market
• Obtain and hold Declarations of Conformity (DoC): You must have a valid DoC for every packaging type and product line
• Register for EPR: Register in the national EPR scheme of every member state where you sell
• Supply compliance documentation: Provide downstream customers (retailers, distributors) with copies of DoCs and compliance evidence

Step 1: Audit Your Packaging Portfolio (Now–June 2026)

Actions to Take:

• Create a complete inventory of all packaging types and SKUs that you currently import or distribute
• For each package, document:
  • SKU and product name
  • Packaging material (plastic, cardboard, glass, metal, etc.)
  • Weight of packaging per unit
  • Supplier/manufacturer name and country
  • Annual volumes sold in the EU
  • Countries where sold
• Prioritize packaging by volume (highest volume first) — focus compliance efforts on your top 80% of sales
• Flag any packaging that you suspect may be non-recyclable or contain hazardous substances (PFAS, mercury, etc.)

Tools & Resources:

• Use a spreadsheet or database to track portfolio (include columns for SKU, material, weight, supplier, volumes, countries)
• Review your supplier documentation — many packaging suppliers already have draft DoCs or compliance data available

Step 2: Request Declarations of Conformity (DoCs) from Suppliers (April–July 2026)

Actions to Take:

• Contact all packaging suppliers and request a formal Declaration of Conformity for each packaging type
• Specify that the DoC must comply with PPWR Article 39 and Annex VIII
• Request the following information in the DoC:
  • Packaging description and SKU
  • Recyclability grade (A–E) with calculation method
  • Recycled content percentage by material type
  • Confirmation that packaging meets weight limits (if applicable)
  • Declaration that no prohibited substances (PFAS, mercury, cadmium, lead) are intentionally added
  • REACH compliance statement
  • Supplier signature and date
• Set a deadline for suppliers to provide DoCs (e.g., July 31, 2026) — do not wait until August
• For suppliers who are slow to respond, escalate to senior management — this is a critical compliance deadline

Template to Send Suppliers:

Dear [Supplier Name], We are preparing for compliance with EU Regulation 2025/40 (PPWR), which applies August 12, 2026. We require a Declaration of Conformity (DoC) for all packaging supplied to us. Please provide the attached template DoC, signed and dated, by [date]. The DoC must include recyclability grade, recycled content percentage, substance declarations, and REACH compliance. If you cannot provide this, we may need to source alternative packaging.

Step 3: Assess Recyclability Grades (May–July 2026)

Actions to Take:

• Review the recyclability grades provided in supplier DoCs — grades should be A, B, C, D, or E
• If a supplier cannot provide a grade, contact a third-party testing lab to conduct a recyclability assessment
• Create a summary table of all your packaging with assigned grades:
  • Grade A: Best (≥95% recycling efficiency)
  • Grade B: Good (85–94%)
  • Grade C: Fair (70–84%)
  • Grade D: Poor (<70%) — must be phased out by Jan 1, 2030
  • Grade E: Non-recyclable — must be phased out by Jan 1, 2030
• Identify any Grade D or E packaging — begin planning phase-out or upgrade strategy

Grade Assessment Costs:

• If supplier provides grade: Cost is typically zero (you may need to verify)
• If third-party testing required: Expect 500–2,000 EUR per packaging type
• Budget for 10–20 test assessments if you have diverse packaging portfolio

Step 4: Verify Recycled Content Claims (June–July 2026)

Actions to Take:

• Request documentation from suppliers showing the recycled content percentage for each packaging material
• For PET plastic, request:
  • Supplier certificate of recycled content (e.g., 30% rPET)
  • Mass balance documentation from the recycled plastic provider
  • Third-party verification (ISO 14855 or equivalent)
• For aluminum and glass, request similar documentation
• Store all documentation in a centralized compliance file — you must be able to produce this evidence to authorities upon request
• Do not make recycled content claims you cannot verify. False claims can result in fines and product seizures.

Step 5: Check for Prohibited Substances (April–June 2026)

Actions to Take:

• Request from suppliers confirmation that packaging does not intentionally contain:
  • PFAS (per- and polyfluoroalkyl substances) in food-contact materials
  • Mercury, cadmium, lead, hexavalent chromium in inks or coatings
  • Restricted phthalates in flexible plastics (if they contact food)
• If suppliers cannot confirm, order independent lab testing (PFAS content, heavy metals analysis)
• Flag any non-compliant packaging for immediate replacement or reformulation
• Budget for additional testing: 300–1,000 EUR per test

Step 6: Register for EPR Schemes (June–August 2026)

Actions to Take:

• Identify all EU member states where you place packaged products on the market
• For each country, research the national EPR scheme:
  • Scheme name and contact information
  • Registration deadline (most require registration 3–6 months before first sale)
  • Reporting requirements (annual or quarterly volumes by material type)
  • Fee structure (per-ton or per-kg of packaging)
  • Fee modulation by recyclability grade
• Complete registration applications for each country by July 2026 — do not wait until August
• Prepare volume data (in kg or tons) of packaging placed on the market in each country by material type:
  • Plastic (separate by type: PET, HDPE, LDPE, PP, etc.)
  • Paper/cardboard
  • Glass
  • Aluminum
  • Steel
  • Wood
  • Other
• Budget for EPR fees:
  • Typically 1–10 EUR per ton of packaging, depending on grade and country
  • Grade A packaging: lowest fees
  • Grade D/E packaging: highest fees (incentive to phase out)
  • For a distributor moving 1,000 tons/year of plastic packaging: estimate 5,000–15,000 EUR annually

Key EPR Schemes to Register With:

• Germany: Der Grüne Punkt (The Green Dot) or ZSVR
• France: Citeo
• Italy: CONAI
• Spain: Ecoembalajes
• Poland: PRCOP, PZWSH, EE
• Netherlands: VDD
• Belgium: Be.Verpakt
• Portugal: VALORPACK

Tip: Use an EPR management platform or consultant to handle multi-country registration — the complexity is high.

Step 7: Update Supply Chain & Customer Communication (June–August 2026)

Actions to Take:

• Notify all customers (retailers, distributors) that you are compliant with PPWR as of August 12, 2026
• Provide customers with copies of DoCs for all packaging you supply to them
• Create a simple summary document for each product showing:
  • Recyclability grade
  • Recycled content percentage
  • Any weight/material restrictions
  • Compliance declaration
• Set up a process to track and update DoCs as suppliers issue revised versions
• Communicate changes to suppliers (e.g., if you upgrade packaging to Grade A)

Step 8: Prepare for Labeling Changes (July–August 2026)

Actions to Take:

• Review PPWR requirements for packaging labeling:
  • All packaging must display material composition
  • Separate collection instructions must be clear and harmonized
  • Sorting instructions must be visible
• Check with suppliers whether they are updating labels to comply with new harmonized labeling rules
• If labels are not updated, place an order with suppliers for compliant labels (allow 4–6 weeks for production)
• Test new labels on mock-ups to ensure they display correctly and meet all requirements

Step 9: Plan for Digital Product Passport (DPP) – August 28, 2027 (Plan Now)

Actions to Take (in 2026):

• Understand that DPP is required by August 28, 2027 (14 months away from August 2026)
• DPP must include:
  • Packaging composition
  • Recyclability grade
  • Recycled content percentage
  • Sorting instructions
  • Link to Declaration of Conformity
• Most DPPs will be accessible via QR code on the packaging
• Begin discussions with packaging suppliers about QR code integration
• Evaluate DPP platforms (some are emerging, others in development)

Step 10: Prepare for Deposit Return Scheme (DRS) – January 1, 2029

Actions to Take (Planning in 2026):

• If you distribute or sell beverages in the EU, note that DRS becomes mandatory January 1, 2029
• Begin monitoring your member states for DRS implementation details
• Prepare for:
  • Container deposit labeling
  • Reverse logistics for returned containers
  • Registration with national DRS bodies
  • Potential increased packaging costs (deposit liability)

Step 11: Train Your Team (June–August 2026)

Actions to Take:

• Conduct training for:
  • Procurement team: understanding DoC requirements, grade definitions
  • Supply chain team: tracking compliance documentation, managing supplier changes
  • Sales team: communicating compliance to customers, providing DoCs upon request
  • Compliance/quality team: maintaining records, managing audits
• Create a simple internal compliance manual (2–5 pages) summarizing key PPWR requirements
• Document your compliance process (who does what, when, how records are maintained)

Step 12: Audit Compliance Before August 12, 2026

Actions to Take:

• Conduct an internal compliance audit in July 2026:
  • All packaging has a valid DoC: ✓ or ✗
  • Recyclability grades assigned: ✓ or ✗
  • Recycled content documented: ✓ or ✗
  • Prohibited substance declarations: ✓ or ✗
  • EPR registered in all countries: ✓ or ✗
  • Labels updated: ✓ or ✗
  • Customer DoCs prepared: ✓ or ✗
• Identify any gaps and remediate immediately
• Document the audit and retain records for at least 10 years

Compliance Checklist Summary

Cost Estimation

One-time setup costs (2026):

• Recyclability testing (if needed): 5,000–20,000 EUR
• Substance testing (PFAS, heavy metals): 2,000–10,000 EUR
• EPR registration and setup: 3,000–8,000 EUR
• Training and documentation: 1,000–3,000 EUR
• Label updates and production: 5,000–20,000 EUR
• DPP planning/platform selection: 2,000–10,000 EUR

Total one-time cost estimate: 18,000–71,000 EUR

Ongoing annual costs:

• EPR fees: 5,000–50,000 EUR (depending on volume and grades)
• DoC maintenance and supplier communication: 1,000–3,000 EUR
• Compliance auditing and reporting: 2,000–5,000 EUR

Total ongoing annual cost estimate: 8,000–58,000 EUR

Key Takeaways for Importers & Distributors

• DoCs are non-negotiable: You must have valid, complete DoCs for every packaging type by August 12, 2026
• Suppliers are responsible too: If a supplier provides incorrect or incomplete DoCs, they are liable — make sure you verify
• EPR is complex and costly: Register early and budget for ongoing fees in multiple countries
• Phase out D/E grades now: Do not wait until 2029–2030 — move to A/B grades in 2026
• DPP is coming in 2027: Start planning your QR code and digital passport strategy
• Enforcement is strict: Non-compliance can result in product seizures and fines — take this seriously