PPWR Checklist 2026: What Businesses Should Check Now

For each packaging flow, identify whether you are a manufacturer, producer for EPR, importer, distributor or retailer. Review private labels, online sales and cross-border deliveries.

For Germany, verify registration, brands, system participation and reporting with the ZSVR. Pay particular attention to changed responsibilities for private-label products and imports.

Document sales, grouped, e-commerce and transport packaging: materials, components, weights, suppliers, destination markets and intended purpose.

Check the general principle under Article 6 and document your packaging design. More detailed recyclability performance grades become relevant particularly from 2030, subject to legal acts.

Identify avoidable components, weight and empty space. Record packaging design improvements, and check application dates under Articles 10 and 24.

For food-contact packaging, check applicable restrictions on PFAS under the PPWR. Obtain material and supplier evidence and examine relevant exemptions.

Identify potentially covered plastics and packaging categories. Prepare supplier data and evidence for future minimum recycled-content obligations under Article 7.

Prepare for harmonised material/sorting labels where applicable. Some start dates depend on implementing acts; assess any current legal labelling obligations separately.

Identify whether transport, grouped or beverage packaging is subject to future reuse/refill measures and whether category-specific exceptions apply.

Assign internal owners; verify required technical documentation, conformity assessments/declarations and approvals. Review environmental marketing claims about packaging separately.