PPWR Checklist 2026: These obligations apply now – step by step
The PPWR applies – but where to start? This checklist puts the obligations applicable since 12 August 2026 into a practicable order: eight steps, each with a legal reference. And it shows what can wait because it only takes effect in 2030.
The eight steps
- Clarify product line roles. Producers, manufacturers, importers, distributors – all further obligations depend on the assignment of roles; what is decisive are the actual activities Art. 3(1)(13)–(21), Art. 15–21 PPWR. Watch out for own brands: Here the retailer becomes the producer Art. 21 PPWR. Details: The roles of the PPWR.
- Record packaging portfolio. Per packaging type: type, material, food contact, single-use or reusable. The declaration of conformity must be issued for each packaging type Annex VII No. 4 PPWR – without a clean portfolio, no clean documentation.
- Check material restrictions. Limit values for substances of concern, including PFAS limit values for food contact packaging; request proof from suppliers if necessary Article 5(4) and (5) PPWR.
- Carry out conformity assessment. Internal production control according to module A – under the manufacturer's own responsibility Art. 38, Annex VII No. 1 PPWR.
- Create technical documentation. Description, drawings, list of standards, evaluations, test reports – the minimum elements are set out in Annex VII Annex VII No. 2 PPWR. Instructions: Technical documentation according to PPWR.
- issue an EU declaration of conformity. Following the template in Annex VIII, per packaging type, in Germany optionally in German or English Art. 39, Annex VIII PPWR; § 62 VerpackDG. Details: PPWR Declaration of Conformity.
- Organise storage. Keep documentation and explanation ready for five years (single-use) or ten years (reusable); ensure supply chain information is available for the same periods Art. 15(3), Art. 22 PPWR.
- Check registration and product liability. Manufacturer registration and extended producer responsibility for the manufacturer role Art. 44, 45 PPWR; existing LUCID registrations remain valid, training certificate until the end of 2027 Section 68(16) of the Packaging Act.
What has time – but belongs in the planning
Only from 1st January 2030 will (partly dependent on the enactment of the related legal acts) minimum recycling rates apply: Article 7(1) PPWR, the 50-% void limit Art. 24(1) PPWR, the format prohibitions pursuant to Annex V Art. 25 para. 1 PPWR, the reuse targets Art. 29(1) PPWR and the design for recycling according to performance levels Art. 6(2) PPWR. Anyone developing packaging today that is still supposed to be on the market in 2030 is planning for these requirements now.
Frequently Asked Questions
Where do I start with the PPWR?
With the clarification of roles per product line (Articles 3, 15–21 PPWR) – it determines which of the further steps apply to you. Afterwards: record the portfolio, check substance limits, assess conformity, document, declare.
By when should the obligations have been implemented?
The obligations have applied since 12 August 2026; infringements of the PPWR obligations in Germany are subject to fines from 12 February 2027 (Section 66 (2), Section 68 (17) of the Packaging Act (VerpackDG)).
What applies only from 2030?
These include minimum recycled content requirements (Art. 7), the 50-% void space limit (Art. 24), format restrictions in accordance with Annex V (Art. 25) and reuse targets (Art. 29) – some of which are subject to the adoption of the relevant implementing acts.
From the checklist to the status analysis
PPWR Radar turns this list into your personal roadmap: roles derived, obligations prioritised, document drafts generated – with a deadlines dashboard and alerts for every relevant change.
Start free impact assessment5 questions, no registration – initial assessment of what the PPWR means for your packaging.
This article provides an explanation and overview; it does not constitute legal advice and is no substitute for an assessment of the individual case. Sources: Regulation (EU) 2025/40 (PPWR, OJ L of 22 January 2025), Packaging Law Implementation Act (VerpackDG, Federal Law Gazette 2026 I No. 207). Legal status: 12 August 2026.