The EU’s Packaging and Packaging Waste Regulation (PPWR) is introducing significant changes to packaging compliance across Europe, with new requirements affecting how packaging is designed, manufactured, labelled and placed on the market.
The regulation began applying on 12 August 2026, with further requirements being introduced in stages over the coming years. Businesses placing packaging or packaged products on the EU market must now understand which obligations apply to them and ensure they have the necessary processes in place to demonstrate compliance.
For UK businesses exporting into the EU or supplying Northern Ireland, PPWR may also introduce additional responsibilities, even if they are not based within the EU.
With a wide range of requirements and implementation deadlines to consider, understanding where your business currently stands is an important first step.
To help businesses assess their readiness, we’ve put together a practical six-point PPWR compliance checklist.
1. Have You Identified Your PPWR Obligations?
Before businesses can prepare for PPWR compliance, they need to understand which requirements apply to their activities.
PPWR covers packaging placed on the EU market, regardless of the material used or whether it is household, commercial or industrial packaging.
However, the responsibilities placed on businesses will vary depending on their position within the supply chain. Manufacturers, importers, distributors and producers may each have different obligations, ranging from ensuring packaging meets applicable requirements to maintaining technical documentation and fulfilling Extended Producer Responsibility (EPR) obligations.
Businesses operating across multiple EU Member States may also need to consider country-specific EPR registration and reporting requirements.
Establishing your business’s role within the supply chain will help determine which compliance activities need to be prioritised.
2. Have You Reviewed Your Packaging Composition and Recyclability?
Packaging design and recyclability are central to PPWR, with requirements intended to reduce packaging waste and improve the recyclability of packaging placed on the EU market.
Businesses must consider applicable restrictions on substances in packaging, including restrictions on certain per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.
Looking ahead, PPWR will also introduce harmonised design-for-recycling requirements from 2030, with packaging assessed against recyclability performance criteria.
These future assessments could have significant implications for packaging formats that are difficult to collect, sort or recycle.
Reviewing packaging portfolios now can help businesses identify materials and components that may need to be redesigned before future requirements take effect.
3. Do You Have Accurate Packaging Data and Supplier Information?
Accurate packaging data is essential for demonstrating compliance with PPWR.
Depending on their responsibilities, businesses may need detailed information about packaging materials, composition, weights and other technical characteristics to assess compliance with the relevant requirements.
For businesses managing large or complex packaging portfolios, obtaining this information can be challenging, particularly where packaging components are sourced from multiple suppliers.
Missing, incomplete or inconsistent data can make it difficult to demonstrate compliance and may delay the preparation of required technical documentation.
Businesses should therefore review the quality and accessibility of their existing packaging data and establish processes for obtaining any missing information.
4. Have You Prepared Your Technical Documentation and Declarations of Conformity?
A significant aspect of PPWR compliance is the requirement for businesses to demonstrate that relevant packaging meets applicable regulatory requirements, before being placed on the EU market.
Manufacturers are required to prepare technical documentation and carry out the relevant conformity assessment procedures to demonstrate compliance with applicable provisions.
Where required, an EU Declaration of Conformity must also be drawn up to confirm that the packaging complies with the relevant requirements.
Technical documentation may include packaging specifications, material composition information, test results and other supporting evidence, depending on the applicable requirements.
Other economic operators, including importers and distributors, have their own responsibilities relating to checking compliance information and ensuring that the required documentation is available, before allowing packaging to enter the EU market.
Having the correct documentation in place is an important part of demonstrating compliance and responding to requests from relevant authorities.
5. Are You Preparing for Future PPWR Requirements?
Although PPWR began applying in August 2026, many of its most significant packaging requirements will be introduced over the coming years.
These include new measures relating to packaging recyclability, harmonised labelling, packaging minimisation, recycled content and reuse.
For example, future design-for-recycling requirements will introduce criteria for assessing packaging recyclability, while packaging minimisation provisions will require businesses to consider whether packaging weight and volume have been reduced to the minimum necessary.
Certain packaging formats will also be subject to recycled-content targets, empty-space restrictions or reuse obligations.
The implementation dates and specific requirements will vary depending on the packaging type and relevant provisions, with some details still dependent on further EU legislation.
Businesses should therefore take a longer-term approach to compliance, ensuring that upcoming requirements are considered when making packaging design, procurement and investment decisions.
Preparing for future requirements can help businesses avoid costly last-minute packaging changes and reduce potential disruption to their operations.
6. Do You Have a PPWR Compliance Action Plan?
Understanding PPWR requirements is only one part of achieving compliance. Businesses also need a structured approach to implementing the necessary changes.
This may involve reviewing existing packaging portfolios, identifying gaps in technical documentation, improving supplier data collection processes and assigning responsibilities across internal departments.
For businesses operating in multiple markets or managing complex supply chains, coordinating these activities can be particularly challenging.
Developing a clear compliance action plan can help businesses prioritise their immediate obligations while preparing for requirements that will apply in future years. A structured approach can help businesses manage regulatory changes more effectively and ensure that compliance responsibilities are understood across the organisation.
Questions Businesses Should Ask Themselves
- Have you identified which of your packaging products fall within the scope of PPWR?
- Do you understand your responsibilities as a manufacturer, importer, distributor or producer?
- Have you identified which EU markets you operate in and any associated EPR obligations?
- Have you reviewed your packaging materials against applicable substance restrictions?
- Do you have accurate and up-to-date information about the materials and composition of your packaging?
- Have you identified which technical documentation and conformity assessment obligations apply to your business?
- Do you have the necessary evidence to support your packaging’s compliance with applicable requirements?
- Have you identified which future PPWR requirements will affect your packaging?
What Should You Do If You Identify Compliance Gaps?
If your business has answered ‘no’ or ‘unsure’ to some of the questions above, it may be time to review your current PPWR compliance position.
With different requirements applying to different packaging types and economic operators, businesses may find it difficult to determine which obligations require immediate attention and which should form part of longer-term planning.
The first step is to identify the most relevant requirements, assess your existing compliance processes and establish where additional information, documentation or support may be needed.
Taking a proactive approach can help reduce compliance risks, improve internal processes and ensure businesses are better prepared as further PPWR requirements come into effect.
How Can Clarity Help?
Navigating PPWR can be challenging, particularly for businesses operating across multiple EU markets or managing complex packaging portfolios.
Clarity’s PPWR Compliance Assessment is designed to help businesses understand their obligations, identify potential compliance gaps and develop a practical roadmap for meeting current and future requirements.
Our structured service includes a 90-minute assessment with a PPWR specialist, a review of your supply chain responsibilities and relevant markets, and a bespoke written action plan outlining the next steps towards compliance.
Businesses can also be supported with their EU EPR data reporting obligations through our International Compliance Team.
Unsure whether your business is ready for PPWR?
Find out more about Clarity’s PPWR Compliance Assessment and how our specialists can help you understand your obligations and prepare for the evolving requirements.
