Every step to a pack that passes, drawn out in full.
The PPWR checklist by role: every step from economic-operator role to filed evidence
Last reviewed · Dataset v2026-10-03 · Reviewed by Pauli Parkkinen, General Manager, Toolcat Oy · Checked against the Official Journal text on 4 September 2026.
The PPWR (Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation) runs to 71 articles. Not one of them tells you what to do first. Pick what your company actually is, and watch your own path draw itself. You get every step, what each one needs from you, and the documents the toolkit writes so you do not have to.
Each answer below names the article it comes from. The chart underneath draws the same duties as steps, in order.
What must an importer do under the PPWR from 12 August 2026? (Art 18)
Check that the manufacturer carried out the Art 38 assessment and drew up the Annex VII documentation. Check that the packaging carries the Art 12 label and the Art 15(5)-(6) marks (Art 18(2)). Put your own name and address on the pack (Art 18(3)). Keep a copy of the declaration for 5 or 10 years (Art 18(7)), and register as the producer in your own Member State (Art 3(1)(15)(b), Art 44).
Source: Regulation (EU) 2025/40, Art 18.
What must a manufacturer do? (Art 15)
Run the Art 38 conformity assessment. Draw up the Annex VII technical documentation and the Annex VIII declaration, and keep both for 5 or 10 years (Art 15(2)-(3)). Put a type, batch or serial number on the pack, or in an accompanying document only where its size or nature does not allow it (Art 15(5)). Put your name and postal address on the pack or in a QR code or other data carrier, and only where that is not possible in an Art 12 data carrier or an accompanying document (Art 15(6)).
Source: Regulation (EU) 2025/40, Art 15.
What must a distributor check? (Art 19)
Before you make packaging available, verify that the producer is in the Art 44 register. Verify that the packaging is labelled in accordance with Art 12. Verify that it carries the manufacturer's type, batch or serial number and its name and address and, for imported packaging, the importer's name and address (Art 15(5)-(6), Art 18(3); Art 19(2)). You hold no declaration and no technical file.
Source: Regulation (EU) 2025/40, Art 19.
Am I the importer or the manufacturer under the PPWR?
An importer is established in the Union and places packaging from a third country on the market (Art 3(1)(17)). Buying from another Member State does not make you an importer. You are the manufacturer if you make the packaging or have it made under your own name or trademark (Art 3(1)(13)(a)). Art 21 also counts an importer or distributor that rebrands packaging, or modifies it in a way that could affect its compliance, as the manufacturer. A micro-enterprise whose packaging supplier sits in the Union hands the Art 15 duties to that supplier (Art 15(12); Art 21 second subparagraph).
Source: Regulation (EU) 2025/40, Art 3 and Art 21. See also PPWR for small businesses and micro-enterprises.
Start with what you are.
The duties are not the same for everyone, so the chart does not pretend they are. Choose a role and it draws only your path. Click any step to see, in plain words, what it does and what it needs.
Manufacturer
You make the packaging, or you have it made and sell it under your own name.
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1. Is this even packaging?
Not everything wrapped around a product counts as packaging, and a few things you would never call packaging do. The toolkit asks a short set of plain questions about the item. It marks each part in or out of scope: the box, the bag, the tray, the label, the pallet wrap. Every answer after this one is then about the right thing.
What it needs: what the product is, and everything that leaves your door with it.
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2. Where do you sell it?
Pick the countries. Each one runs its own producer register and its own recycling fees. Until the single EU label arrives, each also sets its own rules for what the pack must show. Choosing markets is the step that turns a general regulation into your specific list of duties.
What it needs: the countries the product is sold in — including the ones you only ship to occasionally.
Art 44 registers, national labelling law
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3. Describe the packaging
Every part gets one row: what it is made of, what it weighs, how big it is. That single table then feeds the recyclability grade, the recycled-content sum, the empty-space check, the fee calculation and the technical file. Nothing here is ever typed a second time.
What it needs: a material and a weight for every component, down to the label and the tape.
Annex VII technical documentation
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4. Harmful substances
Two questions with hard limits behind them. The four heavy metals — lead, cadmium, mercury and chromium VI — may not exceed a combined limit. Food-contact packaging may not contain PFAS (per- and polyfluorinated alkyl substances, often called forever chemicals) at or above any of three limit values. The toolkit shows which limit lands on which part, and what evidence closes it.
What it needs: a signed statement from whoever actually makes the part.
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5. Recyclability and design rules
Can the pack actually be recycled, and is it bigger than it needs to be? The toolkit estimates the recyclability grade from the share of the pack's weight confirmed recyclable. That is a provisional proxy until the Art 6(4) delegated acts set the design-for-recycling criteria. It also measures the empty space inside the box, checks that weight and volume are down to the minimum, and flags the formats the Regulation bans outright.
Four design duties are not 2026 blockers. They are the Art 6 grade floor (1 January 2030 or 24 months after the Art 6(4) delegated acts, whichever is later) and Art 10(1) minimisation (1 January 2030). They are also the Art 24(1) 50 % cap (1 January 2030 or three years after the Art 24(2) act, whichever is later) and the Art 25 format bans (1 January 2030). What binds now is Art 10(2): no false bottoms or purely perceived-volume design. Until 31 December 2029 Art 9(1)-(2) of Directive 94/62/EC also keep applying, but only to its weight and volume minimisation essential requirement (Annex II point 1, first indent; Art 70(1)(b)). Sales-packaging empty space must be minimised by 12 February 2028 (Art 24(4)). Describe your Art 10 minimisation assessment in the technical file (Annex VII point 2(e) covers the Art 6, 10 and 11 assessments); the Art 24 and Art 25 duties are not part of that file.
What it needs: the parts table from the previous step, plus the box and product dimensions.
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6. Recycled content
Plastic parts have to contain a minimum share of recycled plastic. The share is set per packaging type and format, and met as an average per manufacturing plant and year. The toolkit does that arithmetic component by component and shows which parts sit below the target, and by how much.
Recycled-content minima apply from 1 January 2030 or three years after the Art 7(8) implementing act, whichever is later. Plastic parts under 5 % of the unit weight are outside them (Art 7(5)(b)).
What it needs: a recycled-content percentage from each plastic supplier, with something to back it up.
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7. Labels and marks
What the pack has to show: the sorting label once it arrives, and the material code wherever a country already demands one. Your own name and address go on too, so anyone can trace the pack back to you. The toolkit shows the exact set for the markets you picked, and nothing you do not need.
The harmonised label applies from 12 August 2028 or 24 months after the Art 12(6)-(7) implementing acts, whichever is later, with a three-year sell-through (Art 12(12)). Already from 12 August 2026 you may not display labels, marks, symbols or inscriptions likely to mislead or confuse end users about the PPWR sustainability requirements, other packaging characteristics or waste-management options for which the Regulation lays down harmonised labelling (Art 12(8)). The Art 15(5)-(6) and 18(3) identification and name-and-address marks are due now.
What it needs: your company details, and room on the artwork.
Art 12, Art 15, Decision 97/129/EC
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8. The paperwork
Before the pack goes on sale you must have run the conformity assessment, hold a technical file, and have signed an EU Declaration of Conformity. This is the step people dread, and it is the one the toolkit takes off the table almost entirely.
What it needs: the steps above finished — and a signature.
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9. Register and report
This one runs alongside everything above. You register as a producer in your own country for the packaging you first make available there, and in every other country where you sell directly to end users, online or otherwise. In those other countries you also appoint an EPR authorised representative (Art 45(3)). Where a business customer in another country resells the goods, that customer is the producer there instead (Art 3(1)(15)(b)); a business customer that uses the goods itself is an end user, so there you are the producer (Art 3(1)(23)). In each country where you are the producer, you report your packaging by weight and material once a year and pay the fee that follows from those tonnes. In Finland that means joining a producer organisation and living with its price list.
What it needs: your weights per material, per country, per year.
Art 44, Art 45, Finnish Waste Act 646/2011
Every field green. The dashboard shows the product passing: every duty answered, every document on file, every gap closed. That is what ready to ship looks like.
Importer
You bring packaging, or packed goods, into the EU from outside it.
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1. Is this even packaging?
Not everything wrapped around a product counts as packaging, and a few things you would never call packaging do. The toolkit asks a short set of plain questions about the item. It marks each part in or out of scope: the box, the bag, the tray, the label, the pallet wrap. Every answer after this one is then about the right thing.
What it needs: what the product is, and everything that leaves your door with it.
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2. Did your manufacturer do their part?
Importing does not move the design work onto you, but it does make it your problem. Before the goods go on sale you have to satisfy yourself that the manufacturer ran the conformity assessment and drew up the technical file. You also have to keep a copy of their declaration: five years for single-use packaging, ten for reusable. Your own name and address go on the pack as well.
What it needs: a copy of the manufacturer's declaration, and their confirmation that the technical file exists and who keeps it.
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3. Where do you sell it?
Pick the countries. Each one runs its own producer register and its own recycling fees. Until the single EU label arrives, each also sets its own rules for what the pack must show. Choosing markets is the step that turns a general regulation into your specific list of duties.
What it needs: the countries the product is sold in — including the ones you only ship to occasionally.
Art 44 registers, national labelling law
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4. Describe the packaging
Every part gets one row: what it is made of, what it weighs, how big it is. That single table then feeds the recyclability grade, the recycled-content sum, the empty-space check, the fee calculation and the technical file. Nothing here is ever typed a second time.
What it needs: a material and a weight for every component, down to the label and the tape.
Annex VII technical documentation
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5. Harmful substances
Two questions with hard limits behind them. The four heavy metals — lead, cadmium, mercury and chromium VI — may not exceed a combined limit. Food-contact packaging may not contain PFAS (per- and polyfluorinated alkyl substances, often called forever chemicals) at or above any of three limit values. The toolkit shows which limit lands on which part, and what evidence closes it.
What it needs: a signed statement from whoever actually makes the part.
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6. Recyclability and design rules
Can the pack actually be recycled, and is it bigger than it needs to be? The toolkit estimates the recyclability grade from the share of the pack's weight confirmed recyclable. That is a provisional proxy until the Art 6(4) delegated acts set the design-for-recycling criteria. It also measures the empty space inside the box, checks that weight and volume are down to the minimum, and flags the formats the Regulation bans outright.
Four design duties are not 2026 blockers. They are the Art 6 grade floor (1 January 2030 or 24 months after the Art 6(4) delegated acts, whichever is later) and Art 10(1) minimisation (1 January 2030). They are also the Art 24(1) 50 % cap (1 January 2030 or three years after the Art 24(2) act, whichever is later) and the Art 25 format bans (1 January 2030). What binds now is Art 10(2): no false bottoms or purely perceived-volume design. Until 31 December 2029 Art 9(1)-(2) of Directive 94/62/EC also keep applying, but only to its weight and volume minimisation essential requirement (Annex II point 1, first indent; Art 70(1)(b)). Sales-packaging empty space must be minimised by 12 February 2028 (Art 24(4)). Describe your Art 10 minimisation assessment in the technical file (Annex VII point 2(e) covers the Art 6, 10 and 11 assessments); the Art 24 and Art 25 duties are not part of that file.
What it needs: the parts table from the previous step, plus the box and product dimensions.
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7. Recycled content
Plastic parts have to contain a minimum share of recycled plastic. The share is set per packaging type and format, and met as an average per manufacturing plant and year. The toolkit does that arithmetic component by component and shows which parts sit below the target, and by how much.
Recycled-content minima apply from 1 January 2030 or three years after the Art 7(8) implementing act, whichever is later. Plastic parts under 5 % of the unit weight are outside them (Art 7(5)(b)).
What it needs: a recycled-content percentage from each plastic supplier, with something to back it up.
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8. Labels and marks
What the pack has to show: the sorting label once it arrives, and the material code wherever a country already demands one. Your own name and address go on too, so anyone can trace the pack back to you. The toolkit shows the exact set for the markets you picked, and nothing you do not need.
The harmonised label applies from 12 August 2028 or 24 months after the Art 12(6)-(7) implementing acts, whichever is later, with a three-year sell-through (Art 12(12)). Already from 12 August 2026 you may not display labels, marks, symbols or inscriptions likely to mislead or confuse end users about the PPWR sustainability requirements, other packaging characteristics or waste-management options for which the Regulation lays down harmonised labelling (Art 12(8)). The Art 15(5)-(6) and 18(3) identification and name-and-address marks are due now.
What it needs: your company details, and room on the artwork.
Art 12, Art 15, Decision 97/129/EC
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9. The paperwork you check, and the paperwork you keep
Before the goods go on sale, satisfy yourself that the manufacturer ran the Art 38 conformity assessment and holds the Annex VII technical documentation (Art 18(2)(a)). Keep a copy of their EU declaration of conformity for five years, ten for reusable packaging (Art 18(7)). Be able to produce the technical documentation to an authority within 10 days (Art 18(8)). You draw up and sign a declaration yourself in two cases only: you sell under your own name or brand, or you modify the packaging in a way that could affect compliance (Art 21). Then the manufacturer path applies. Are you a micro-enterprise (Recommendation 2003/361/EC as applicable on 11 February 2025) with a packaging supplier located in the Union? Then that supplier counts as the manufacturer for Art 15 (Art 21 second subparagraph).
What it needs: the manufacturer's declaration and technical file on request — and your own name and address on the pack (Art 18(3)).
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10. Register and report
This one runs alongside everything above. You register as a producer in your own country for the packaging you first make available there, and in every other country where you sell directly to end users, online or otherwise. In those other countries you also appoint an EPR authorised representative (Art 45(3)). Where a business customer in another country resells the goods, that customer is the producer there instead (Art 3(1)(15)(b)); a business customer that uses the goods itself is an end user, so there you are the producer (Art 3(1)(23)). In each country where you are the producer, you report your packaging by weight and material once a year and pay the fee that follows from those tonnes. In Finland that means joining a producer organisation and living with its price list.
As the importer you are usually the producer in your own country: the registration and the recycling fees are yours, not the factory's.
What it needs: your weights per material, per country, per year.
Art 44, Art 45, Finnish Waste Act 646/2011
Almost the whole manufacturer path, because importing does not move the duties — it moves who answers for them.
Every field green. The dashboard shows the product passing: every duty answered, every document on file, every gap closed. That is what ready to ship looks like.
Distributor
You resell what someone else already placed on the market.
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1. Is the producer registered?
Before you make someone else's packaging available, check that the producer for that country is on that country's producer register. The producer is whoever first made the packaging available there: your supplier if it is established there, a foreign seller that supplies end users there directly, or you yourself if you brought the goods in from another country (Art 3(1)(15)). It is a lookup rather than paperwork. But doing it is your duty, and not doing it is where distributors get caught.
What it needs: the producer's name and their registration number.
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2. Is the labelling there?
Second check: the pack carries the labelling that market requires, the manufacturer's type, batch or serial number and its name and address, and, for imported packaging, the importer's name and address too. You are not redesigning anything here — you are looking, and refusing to sell what fails.
What it needs: the pack in front of you, and that market's label rules.
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3. Get the paperwork you can get
You are not required to hold the Declaration of Conformity — that stays with whoever placed the packaging on the market. Asking for a copy is still the cheapest insurance there is, and your own customers will ask you for it sooner or later.
What it needs: one request to the company you buy from.
A recommended safeguard, not an Art 19 duty
One catch worth knowing: buy from another EU country and resell at home, and you are the producer here. The register and the fees come with it. The toolkit checks that for you and says so.
Three checks, and you are clear. No technical file, no declaration to sign, no design duties — those belong to whoever placed the packaging on the market. Your job is to look before you sell, and to be able to show that you looked.
Sources: Regulation (EU) 2025/40, Decision 97/129/EC.
Alone, this is a search through 71 articles.
Every box in that chart is a duty someone has to work out. Or a supplier someone has to chase. Or a document someone has to write from scratch. The toolkit turns the whole chain into one guided flow, and writes the documents from the answers you already gave it.
Importer and distributor questions, answered per article
Does an importer need its own declaration of conformity?
Not for goods it resells under the manufacturer's name. It must check that the manufacturer carried out the Annex VII assessment and drew up the documentation (Art 18(2)(a)). It must keep a copy of the EU declaration of conformity (Art 18(7)). Art 21 counts an importer that sells under its own name or trademark, or modifies the packaging in a way that could affect its compliance, as the manufacturer. That importer draws up the declaration itself. Source: Regulation (EU) 2025/40.
How long must an importer keep the declaration?
5 years for single-use packaging, 10 years for reusable packaging. The clock starts on the date the packaging was placed on the market (Art 18(7)). Manufacturers keep the same periods under Art 15(3). Either must hand the documents to an authority within 10 days of a reasoned request (Art 15(10), Art 18(8)). Source: Regulation (EU) 2025/40.
Is an importer the producer for EPR?
Usually yes in its own Member State (Art 3(1)(15)(b)). When it sells directly to end users in another Member State it is the producer there too. There it needs an EPR (extended producer responsibility) authorised representative (Art 3(1)(15)(d), Art 45(3)). Source: Regulation (EU) 2025/40.
Does a distributor need the declaration?
No. Art 19(2) requires it to verify producer registration, the Art 12 label and the Art 15(5)-(6)/Art 18(3) markings. It does not require it to hold the declaration. Fulfilment service providers have their own, narrower duties (Art 20). Source: Regulation (EU) 2025/40.
One guided flow instead of 71 articles.
Every step in the chart maps to a screen in the app, with the paperwork already filled in from what you typed. Start with one product and watch the fields turn green.