The PPWR Readiness Checklist — What You Need Documented Now

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) applies now — it has since 12 August 2026, and its day-one obligations came with no grace period. Enforcement is warning-first while the penalty rules are finalised in early 2027, so what matters is being able to show your documentation when an authority asks. This is the working checklist: what has to be true, in the order that actually gets it done. Print it, assign owners, and work top to bottom.

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1 — Scope: know what you’re responsible for

• ☐Inventory every packaged SKU you place on the EU market — including imports where you’re the economic operator, and don’t forget secondary (grouped) and transport packaging.
• ☐Flag food-contact packaging — trays, wraps, cups, pouches, coated papers. These carry the PFAS restriction and are the highest-risk group.
• ☐Record materials and formats per SKU (material, weight, format) — every later step consumes this data.

2 — Substances: collect the evidence, not just promises

• ☐Ask each packaging supplier for current evidence — laboratory test reports / Certificates of Analysis, not just a “complies with PPWR” statement. For food-contact packaging, packaging must not be placed on the market where PFAS is present at or above 25 ppb for any single PFAS (targeted analysis), 250 ppb for the sum of targeted PFAS, or 50 ppm for PFAS in total including polymeric PFAS. Separately, if total fluorine exceeds 50 mg/kg, you must be able to show on request how much of that fluorine is PFAS and how much isn’t. Heavy metals (lead, cadmium, mercury, hexavalent chromium) must not exceed 100 mg/kg in sum, for all packaging — not just food-contact. Details: the PFAS evidence guide.
• ☐Check the measured values against the thresholds for every material — and record which SKU each certificate covers.
• ☐Note test dates and set renewal reminders — an old report for a since-reformulated material is weak evidence.
• ☐Fix or substitute what fails — reformulation lead times are the part you can’t compress once someone is asking.

3 — Declaration of Conformity: the day-one document

• ☐Draft the Annex VIII Declaration of Conformity for each packaging item/type, backed by the technical documentation from step 2. Full walkthrough with a worked example: the DoC guide.
• ☐Decide who signs — a named person in your organisation takes responsibility; the conformity route is self-assessment (Module A), so no notified body is involved.
• ☐Importers/distributors: collect your suppliers’ DoCs — you must hold them for products you place on the market.

4 — Keep EPR on its own track (it is not the DoC)

• ☐Register with the national EPR scheme(s) in each member state where you sell, and budget the fees — but don’t mistake fee payment for conformity: they are separate obligations. (Rough fee exposure: our free EPR fee estimator.)

5 — Retention and what’s coming next

• ☐Set up retention — the EU Declaration of Conformity and the Annex VII technical documentation must stay retrievable for 5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging was placed on the market — through staff changes and supplier switches.
• ☐Put the later phases on your radar — harmonised labelling (no earlier than August 2028) and recyclability grading (from 2030) will reuse the same SKU and material data you assembled in step 1. Don’t book artwork against the labelling date yet: Article 12(1) applies 24 months after the labelling implementing acts enter into force, or 12 August 2028 — whichever is later. Those acts were themselves due in August 2026 and have not been adopted, so this can only move outwards. Plain-English overview: the PPWR guide.

Where VerdLynx fits

VerdLynx is built around exactly this list: SKU inventory with market flags, supplier CoA collection with AI parsing of the lab values against the thresholds, artwork marking checks, expiry reminders, DoC drafting gated on a passing substance check (a human signs), and a retained archive. Try it free — 10 SKUs, no card needed.

Based on Regulation (EU) 2025/40 and the European Commission’s PPWR guidance (C/2026/3084); verify the current text for your case. General information, not legal advice.