📌 In this article, ESG researcher Rosaida Brahim provides a checklist for businesses looking to see if they're ready to meet the PPWR implementation deadline.
The August 12 2026 implementation deadline for the Packaging and Packaging Waste Regulation (PPWR) is getting closer and closer.
This is a hard deadline -- compliance is mandatory in order for your packaged products to enter the EU market after this date and to avoid fines.
This checklist offers a helpful general guide for businesses who aren't sure what is needed to be PPWR compliant. In order to make such a huge task manageable, we've organized the tasks in 6 categories:
1: Understanding your role and responsibilities in the chain
2: Data management for easy access and auditing
3: Knowing how your product interacts with the PPWR
4: Preparing a solid foundation
5: Risk Assessment
6: Results and next steps
Using this as a guide, businesses will not only get a better idea of what steps they need to take for the upcoming implementation deadline, but also how to set themselves up to successfully meet the PPWR implementation phases that follow it.
| Please note that the following is only a basic checklist; for a full in-depth guide, download the checklist at the end of the article. |
The PPWR has defined a distinct set of roles, each with their own responsibilities. The first step towards compliance is figuring out what role you play, and what is expected of you.
| Manufacturer |
Any natural or legal person that manufactures packaging or a packaged product Responsibilities: Compiling all the technical documentation, writing up the EU Declaration of Compliance (EU-DoC), facilitating the audit process. |
| Supplier |
Any natural or legal person that supplies packaging or packaging material to a manufacturer Responsibilities: Making sure that packaging is PPWR compliant. This also means sharing information with the manufacturers for the technical documentation. When in doubt, packaging should be kept or removed from the market until compliance is assured. |
| Importer |
Any natural or legal person established within the Union that places packaging from a third country on the market Responsibilities: Making sure that packaging is PPWR compliant. This also means sharing information with the manufacturers for the technical documentation. When in doubt, packaging should be kept or removed from the market until compliance is assured. |
| Distributor |
Any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market Responsibilities: Making sure that packaging is PPWR compliant. When in doubt, packaging should be kept or removed from the market until compliance is assured. |
| Attention! |
Are you bringing packaging to an EU Member State for the first time? (YES/NO) Are you adding your brand to pre-fabricated, compliant packaging? (YES/NO) Are you altering pre-fabricated, compliant packaging in a way that might affect its compliance status? (YES/NO) If you've answered YES to any of these questions then you might be a manufacturer! Double check to make sure you've correctly determined your role in the chain. |
PPWR requires extensive documentation to not only reinforce compliance, but also to monitor its impact. Data collection, data sharing, and traceability are important aspects businesses are required to contribute to.
| You have established... | Yes | No |
| How to coordinate compliance throughout the company chain | Ο | Ο |
| Contact information for suppliers that need to be approached for data | Ο | Ο |
| A system to store and share technical documentation for up to 10 years | Ο | Ο |
| Which proper authorities to register with in every EU Member State relevant to your operation | Ο | Ο |
The PPWR demands transparency and traceability. The more information gathered, the more successful your compliance journey.
| You have identified and documented... | Yes | No |
| Your packaging has been tested against the harmonized standards published in the Official Journal | Ο | Ο |
| Whether any of your packaging is subject to exemptions or stricter quality control (e.g. medical packaging, food packaging) | Ο | Ο |
| Where PFAS, inks, coatings, and additives appear in your packaging for eventual removal | Ο | Ο |
The targets set out in the PPWR are staggered, and the requirements set out for August 2026 are going to increase in intensity with every phase.
| You have determined... | Yes | No |
| An action plan with assigned responsibilities and deadlines for each compliance phase | Ο | Ο |
| How to meet the Minimum Recycled Content in Plastic Packaging targets | Ο | Ο |
| How to meet the packaging minimization requirements | Ο | Ο |
| How to implement the harmonized label and QR code requirements | Ο | Ο |
| You have accounted for the possibility of ... | Yes | No |
| The cost of modifying packaging to meet compliance requirements | Ο | Ο |
| Extended producer responsibility fees | Ο | Ο |
| Non-compliance penalties (i.e. fines; removal of packaging from market) | Ο | Ο |
In an ideal situation, you would have been able to check off 'yes' to all the questions. More likely, you have come to realize that you still have some work to do before you're ready to confidently call yourself PPWR compliant.
So what's next?
A checklist like this is a good indicator of how much work goes into compliance, but it doesn't offer much more than insight.
Fortunately, digital solutions have become a helpful management tool for businesses to not only meet ESG regulations, but to thrive under them.
MasterSustainability.today offers one of those solutions: software that provides businesses with the digital tools to manage their ESG compliance journey from beginning to end.
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